# Mardi Gras Transportation System — Pipeline Safety Interpretation

- **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:** Not available
- **summary:** PI-01-001 response to Mardi Gras Transportation System concerning 192.619.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/PI01001.pdf
**body:**

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• U.S. Department
400 Seventh St., S.W
of Transportation
Washington, D.C. 20590
Research and
Special Programs
Administration
AUG 2 1 2001
Mr. Les Owen
Pipeline Operations Coordinator
Mardi Gras Transportation System
10777 Clay Road
Houston, TX 77041
Dear Mr. Owen:
I am responding to your letter of July 10, 2001, regarding the federal safety standard in
49 CFR 192.619(a)(2)(ii). You asked if we concur with your understanding of that standard as it
applies to piping that connects facilities on an offshore platform to an underwater pipeline.
As described in your letter and attached drawing, the piping is in two parts. The first part
includes a pig launcher assembly and traditional fixed riser piping that begins at the hull deck
and extends below the waterline to a hang off point. The second part consists of a flexjoint and
steel catenary piping that begins at the hang off point and connects to a pipeline on the water
bottom. You would like to comply with § 192.619(a)(2)(ii) by applying a safety factor of 1.5 to
the first part of the piping and a factor of 1.25 to the second part:
Section 192.619(a)(2)(ii) requires a safety factor of 1.25 for certain offshore pipeline
segments not located on an offshore platform. For segments that are located on an offshore
platform, including a pipe riser, the factor is 1.5. Based on our evaluation of the design, it
appears that the first part of the piping is the only part that is actually "on an offshore platform."
The second part is not in contact with or supported by the platform itself. Therefore, we believe
your intended application of § 192.619(a)(2)(ii) is correct.
I hope this information is useful to you. If I can provide any further assistance, please
contact me at (202) 366-4595.
Sincerely,
Marlach
Stacey L.
Associatd Administrator
for Pipeline Safety
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