{"operation":"document","citation":"PI-01-001","title":"Mardi Gras Transportation System — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-08-21","effective_on":null,"summary":"PI-01-001 response to Mardi Gras Transportation System concerning 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/PI01001.pdf","body":"<<<PAGE 1>>>\n\n• U.S. Department\n400 Seventh St., S.W\nof Transportation\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nAUG 2 1 2001\nMr. Les Owen\nPipeline Operations Coordinator\nMardi Gras Transportation System\n10777 Clay Road\nHouston, TX 77041\nDear Mr. Owen:\nI am responding to your letter of July 10, 2001, regarding the federal safety standard in\n49 CFR 192.619(a)(2)(ii). You asked if we concur with your understanding of that standard as it\napplies to piping that connects facilities on an offshore platform to an underwater pipeline.\nAs described in your letter and attached drawing, the piping is in two parts. The first part\nincludes a pig launcher assembly and traditional fixed riser piping that begins at the hull deck\nand extends below the waterline to a hang off point. The second part consists of a flexjoint and\nsteel catenary piping that begins at the hang off point and connects to a pipeline on the water\nbottom. You would like to comply with § 192.619(a)(2)(ii) by applying a safety factor of 1.5 to\nthe first part of the piping and a factor of 1.25 to the second part:\nSection 192.619(a)(2)(ii) requires a safety factor of 1.25 for certain offshore pipeline\nsegments not located on an offshore platform. For segments that are located on an offshore\nplatform, including a pipe riser, the factor is 1.5. Based on our evaluation of the design, it\nappears that the first part of the piping is the only part that is actually \"on an offshore platform.\"\nThe second part is not in contact with or supported by the platform itself. Therefore, we believe\nyour intended application of § 192.619(a)(2)(ii) is correct.\nI hope this information is useful to you. If I can provide any further assistance, please\ncontact me at (202) 366-4595.\nSincerely,\nMarlach\nStacey L.\nAssociatd Administrator\nfor Pipeline Safety","truncated":false,"body_characters":1837}