{"operation":"document","citation":"PHMSA Guidance, Letter to State Pipeline Safety Program Managers regarding Plastic Pipe Rule","title":"Letter to State Pipeline Safety Program Managers regarding Plastic Pipe Rule","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-03-12","effective_on":"2020-03-12","summary":"Letter to State Pipeline Safety Program Managers regarding Plastic Pipe Rule Document Notice of Exercise of Enforcement Discretion - Plastic Pipe Rule.pdf (420.92 KB) PHMSA is not intending to enforce certain requirements as applies to those types of plastic pipeline facilities. Issued Date: Thursday, March 12, 2020","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-guidance-letter-state-pipeline-safety-program-managers-regarding-a0f2c696.json","markdown":"https://regulus.evalyn.ai/document/phmsa-guidance-letter-state-pipeline-safety-program-managers-regarding-a0f2c696.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-guidance-letter-state-pipeline-safety-program-managers-regarding-a0f2c696","source_url":"https://www.phmsa.dot.gov/regulatory-compliance/phmsa-guidance/letter-state-pipeline-safety-program-managers-regarding","body":"Letter to State Pipeline Safety Program Managers regarding Plastic Pipe Rule\n\nDocument\n\n Notice of Exercise of Enforcement Discretion - Plastic Pipe Rule.pdf (420.92 KB)\n\n        PHMSA is not intending to enforce certain requirements as applies to those types of plastic pipeline facilities.\n\n          Issued Date: Thursday, March 12, 2020\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nWashington, DC 20590\n1200 New Jersey Avenue, SE\nMaterials Safety\nPipeline and Hazardous\nAdministration\nMarch 12, 2020\nAttention: State Pipeline Safety Program Managers\nPHMSA has identified two implementation issues with the Plastic Pipe Rule. I'm writing to\ncommunicate PHMSA's intentions to address them and provide recommendations to the States.\nCompliance with Category 1 requirements for large diameter (4 inches or greater)\ntransition fittings:\nYou may recall PHMSA received a petition for reconsideration from the American Gas\nAssociation (AGA) on December 20, 2018,' shortly after the Plastic Pipe Rule was published, to\nexempt mechanical fittings with nominal pipe sizes of 4 inches or greater from the Category 1\nrequirements in 49 CFR 192.281 (e) (4)\n§192.281 Plastic pipe.\n*****\n(e) Mechanical joints. Each compression type mechanical joint on plastic pipe must\ncomply with the following:\n*****\n(3) All mechanical fittings must meet a listed specification based upon the applicable\nmaterial.\n(4) All mechanical joints or fittings installed after January 22, 2019, must be Category 1\nas defined by a listed specification for the applicable material, providing a seal plus\nresistance to a force on the pipe joint equal to or greater than that which will cause no less\nthan 25% elongation of pipe, or the pipe fails outside the joint area if tested in accordance\nwith the applicable standard.\nAGA raised issues with the commercial availability of fittings 4 inches or larger that meet the\nrequirements. The biggest issue appeared to be with availability of transition couplings for\nplastic to metallic connections, particularly plastic to cast iron connections.\n' Available on regulations.gov at https://www.regulations.gov/document?D-PHMSA-2014-0098-0063.\n\n<<<PAGE 2>>>\n\nState Pipeline Safety Program Managers\nPage 2\nPHMSA provided a response to AGA on March 1, 2019, of its intentions to delay the compliance\ndeadline for Category 1 requirements for joints between metallic and plastic pipe with a nominal\nsize of 4 or greater until January 22, 2020. The date was intended to help provide additional time\nto develop and test larger mechanical fittings that can meet the Category 1 performance standard\nof §192.281 (e)(4), along with other requirements in newly incorporated fitting standards such as\nASTM F1924 and ASTM F1948 invoked through §192.281 (e)(3).\nWhile manufacturers have made progress in testing their large diameter fittings they could not\nquite get all tests completed by January 22, 2020. One manufacturer indicated they would\ncomplete all required tests for the full range of sizes by the week of February 3 and another\nindicated that they may need until August. Even with the fittings starting to be commercially\navailable, AGA has communicated that it could take their members up to six months to train\npersonnel and update procedures. Part of that timing includes time needed to receive fittings and\nswap out any non-compliant fittings in their inventory, such as Category 3 that were previously\nallowed prior to the Plastic Pipe Rule but no longer allowed post rule, in addition to the time\nneeded to update procedures and provide training to staff on any design changes.\nAfter consideration of the information presented, PHMSA is not intending to enforce the\nrequirements of §§192.281 (e)(3) or 192.281 (e)(4) for joints between metallic and plastic pipe\nwith a nominal pipe size of 4 or greater until August 31, 2020, and recommends States do the\nsame.\nIdeally operators would wait until the fittings are fully tested, available, and integrated into their\nsupply chain, procedures, and training prior to being installed. If they don’t install non-\ncompliant fittings there is no enforcement issue. However, if operators do need to install fittings\nwhose testing results are still being evaluated, they should implement a tracking and traceability\nprogram to know where those fittings are located. Such fittings must be replaced if the design\nsubsequently fails testing by the manufacturer. In some cases, supplemental restraint may also\nbe needed to meet the requirement. Operators should also obtain letters from their manufacturer\non status of testing, availability of fittings, and any training and procedural changes anticipated.\nFusion Qualification: Considering Alternative Procedures to ASTM F2620 for\nPolyethylene (PE):\nAGA submitted a petition on August 23, 2019 requesting PHMSA amend §§ 192.281 and\n192.285 to allow alternatives to ASTM F2620 for qualifying joining procedures and joiners.\n§192.281 Plastic pipe.\n*****\n(c) Heat-fusion joints. Each heat fusion joint on a PE pipe or component, except for\nelectrofusion joints, must comply with ASTM F2620-12 (incorporated by reference in\n§192.7) and the following:\n*****\n§192.285 Plastic pipe: Qualifying persons to make joints.\n\n<<<PAGE 3>>>\n\nState Pipeline Safety Program Managers\nPage 3\n*****\n(b) The specimen joint must be:\n*****\n(2) In the case of a heat fusion, solvent cement, or adhesive joint:\n(i) Tested under any one of the test methods listed under §192.283(a), or for PE heat\nfusion joints (except for electrofusion joints) visually inspected and tested in accordance\nwith ASTM F2620-12 (incorporated by reference, see §192.7) applicable to the type of\njoint and material being tested;\nThe AGA stated many utilities have been using previously qualified heat fusion procedures\ndeveloped by the industry and published by the Plastic Pipe Institute (PPI), such as PPI TR-33\n“Generic Butt Fusion Joining Procedure for Field Joining of Polyethylene Pipe” and PPI TR-41\n“Generic Saddle Fusion Joining Procedure for Polyethylene Gas Piping”, that deviate from\nASTM F2620 in some aspects. Some operators also developed their own procedures. AGA\nnoted that while the rule preamble talked about the potential for other procedures to be\nacceptable if an operator can demonstrate any differences are sound and provide an equivalent or\nsuperior level of safety compared to ASTM F2620, the actual rule language doesn’t appear to\nprovide an option for alternative procedures.\nIn a November 18, 2019, response to the AGA, PHMSA indicated it will consider amending\n§§ 192.281(c) and 192.285(b)(2)(i) consistent with the discussion in the preamble of the Plastic\nPipe Final Rule to allow the use of written procedures other than ASTM F2620 that are\ndemonstrated to provide an equivalent or superior level of safety. PHMSA is also considering\nwhether it would be appropriate to incorporate by reference the 2019 version of ASTM F2620,\nwhich includes a note that ties ASTM F2620 with the PPI procedures mentioned in the petition,\nin a future rulemaking.\nIn the interim until a rulemaking is proposed and ultimately finalized, PHMSA is planning to\nenforce this requirement consistent with the language in the preamble and recommends States do\nthe same.\nSincerely,\nZach Barrett\nDirector, State Programs","truncated":false,"body_characters":7276}