{"operation":"document","citation":"PI-01-0108","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-01-0108 response to Mardi Gras Transportation System concerning 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0108.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0108.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0108","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/g01-04-21_Owen_192.619-msfX.pdf","body":"<<<PAGE 1>>>\n\nPI-01-0108\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh St., S.W.\nWashington, D.C. 20590\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 49 CFR\n192.619(a)(2)(ii). You asked if we concur with your understanding of that standard as it applies to piping that\nconnects 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 includes a pig\nlauncher assembly and traditional fixed riser piping that begins at the hull deck and extends below the\nwaterline to a hang off point. The second part consists of a flexjoint and steel catenary piping that begins at\nthe hang off point and connects to a pipeline on the water bottom. You would like to comply with\n§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\nsecond part.\nSection 192.619(a)(2)(ii) requires a safety factor of 1.25 for certain offshore pipeline segments not\nlocated on an offshore platform. For segments that are located on an offshore platform, including a pipe riser,\nthe factor is 1.5. Based on our evaluation of the design, it appears that the first part of the piping is the only\npart that is actually \"on an offshore platform.\" The second part is not in contact with or supported by the\nplatform itself. Therefore, we believe your 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 contact me at\n(202) 366-4595.\nSincerely,\nStacey L Gerard\nAssociate Administrator for Pipeline Safety","truncated":false,"body_characters":1844}