{"operation":"document","citation":"PI-01-0110","title":"Washington Utilities and Transportation Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-05-31","effective_on":null,"summary":"PI-01-0110 response to Washington Utilities and Transportation Commission concerning 192.553.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0110.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0110.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0110","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/g01-05-31_Kilpatrick_192.553-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-01-0110\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh St. S.W.\nWashington, D.C. 20590\nMay 31, 2001\nMr. Douglas Kilpatrick, P.E.\nPipeline Safety Director\nWashington Utilities and Transportation Commission\nP.O. Box 47250\nOlympia, WA 98504-7250\nDear Mr. Kilpatrick:\nThis letter is in response to your letter of March 15, 2001, requesting an interpretation of the pipeline\npressure up rating requirements in 49 CFR Part 192, Subpart K.\nYou note that a local distribution company (LDC) wants to up rate a steel pipeline in a Class 3 location\nto a pressure that will produce a hoop stress of less than 30 percent of specified minimum yield strength\n(SMYS). In 1957, the pipe was pressure tested to 465 psig and the LDC established a maximum allowable\noperating pressure (MAOP) of 190 psig based on the highest operating pressure during the five-years prior to\nJuly 1, 1970. The LDC proposes to raise the pressure from 190 psig to 250 psig in four increments of 15 psig.\nYou assert that the up rating procedure described above does not meet the minimum\nrequirement of 49 CFR § 192.553(d), which states that\n. . . a new maximum allowable operating pressure established under this subpart may not\nexceed the maximum that would be allowed under this part for a new segment of pipeline\nconstructed of the same materials in the same location.\nWe agree that the word \"part\" as used in 192.553(d) refers to 49 CFR Part 192, rather than just to Subpart\nK. Therefore, any up rating is limited by the provisions of § 192.619, Maximum allowable operating\npressure; Steel or plastic pipelines.\nThe up rating regulations in Subpart K do not require that a new pressure test be conducted at the\ntime of up rating. And, § 192.555(c), which covers up rating to a pressure that will produce a hoop stress 30\npercent or more of SMYS, explicitly allows the use of a previous pressure test as the basis for MAOP, even if\nthe pipeline was not operated to the MAOP during the five years prior to July 1, 1970. Although the use of a\nprevious pressure test is not mentioned in § 192.557, which covers up rating to a pressure that will produce\na hoop stress less than 30 percent of SMYS, it makes no sense to rely on a previous pressure test for high-\nstress pipe and to disallow it for low-stress pipe. And, in any case, § 192.553(d) clearly states that the new\nMAOP may not exceed the maximum that we would allow for new pipe of the same material at the same\nlocation. Therefore, reliance on a previous pressure test is allowable for up rating to a higher MAOP,\nproviding that the pressure test, de-rated for class location as specified in § 192.619, allows for a maximum\n\n<<<PAGE 2>>>\n\nallowable operating pressure equal to or greater than the proposed up rated pressure.\ncc: Stephanie J. Kreshel, PSE\nDon McCoy, TSI\n\n<<<PAGE 3>>>\n\nIn response to your specific questions:\n1. Do you agree with our interpretation that the LDC must up rate to a pressure using the table and\nfactors found in 49 CFR § 192.619(a)(2)(ii)?\nAnswer: No. The LDC may follow the up rating procedure in 49 CFR Part 192, Subpart K. The up rated\npressure will be limited to the maximum pressure that can be supported by a current or previous pressure\ntest, as de-rated for class location using the factors found in 49 CFR § 192.619(a)(2)(ii).\n2. If you agree, is the factor used based on date installed, or date up rated. In this case would the\nLDC need to up rate to 375 psig (250 x 1.5 — date updated) or 350 psig (250 x 1.4 -- date installed) to\nestablish an MAOP of 250 psig?\nAnswer: Not applicable.\n3. According to § 192.555(c), can a pipeline installed and tested prior to the start of the five-year\nwindow ending July 1, 1970, be up rated to a pressure that will produce a hoop stress of 30 percent or\nmore of SMYS, using the original pressure test as the basis of the MAOP?\nAnswer: Yes. 49 CFR § 192.555(c) states that \". . . an operator may increase the MAOP of a segment of\npipeline constructed by September 12, 1970, to the highest pressure that is permitted under § 192.619,\nusing as test pressure the highest pressure to which the segment of the pipeline was previously subjected.\"\nA new pressure test is not required, unless the old pressure test cannot justify the up rated pressure.\nIf you need further assistance, please call me at (202) 366-4565.\nSincerely yours,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 4>>>\n\nMarch 15, 2001\nRichard Huriaux\nManager of Regulations\nUnited States Department of Transportation\nFederal Office of Pipeline Safety\n400 7th Street, South West, Room 7128\nWashington, District of Columbia 20590\nDear Mr. Huriaux:\nSubject: Clarification of Title 49, Part 192, Subpart K, Uprating\nCan you please provide a clarification for the following situation? A local gas distribution company (LDC)\nwishes to up rate a steel pipeline to a pressure that will produce a hoop stress of less than 30 percent SMYS.\nThe LDC installed the pipeline in 1957 and at that time tested it to 465 psig. The LDC established the MAOP at\n190 psig based on the highest operating pressure incurred during the 5 year window prior to July 1, 1970. The\nLDC now wishes to up rate this pipeline to an MAOP of 250 psig. This pipeline is in a class 3 location. The LDC's\nup rate procedure calls for raising the pressure from 190 psig to 250 psig in 4 increments of 15 psig each. We\nbelieve that the LDC's procedure to raise pressure only to the desired MAOP during the up rate does not meet\nthe minimum requirements of subpart K. We base this interpretation on the fact that Part 192.553(d) states\nthat:\n“\n. . .a new MAOP established under Subpart K may not exceed the maximum that would be allowed\nunder this part for a new segment of pipeline constructed of the same materials in the same location\",\nWe believe that the word part in this paragraph refers to all of Part 192 and this requires the LDC to up rate to\na pressure using the factors in the table from Part 192.619(a)(2)(ii). We also believe that since the table found\nin Part 192.619(a)(2)(ii) contains a note (1) referring to the required use of factors for offshore pipelines that\nthis would imply the necessity to use the factors in this table for onshore pipelines also. One point of\nconfusion for us is the fact that Part 192.555(c) appears to allow the use of a previous pressure test as the\nbasis for MAOP even if the pipeline was not operated to the MAOP during the 5 year window prior to July 1,\n1970.\nAlthough Part 192.555 applies to pipelines that will be operated to a hoop stress of 30 percent or more of\nSMYS it does not make sense that Subpart K would be less stringent for the higher stress pipeline. Our\nquestions to you are:\n1. Do you agree with our above interpretation that the LDC must up rate to a pressure using the table\nand factors found in Part 192.619(a)(2)(ii)?\n2. If you agree with our above interpretation, is the factor used based on date installed, or date up\nrated. In this case would the LDC need to up rate to 375 psig (250 X 1.5 — date up rated) or 350\npsig (250 X 1.4 — date installed) to establish an MAOP of 250 psig?\n3. According to Part 192.555, can a pipeline installed and tested prior to the start of the 5 year window\nending July 1, 1970, be up rated to a pressure that will produce a hoop stress of 30 percent or more\nof SMYS, using the original pressure test as the basis of the MAOP?\nWe would appreciate your help in getting an official clarification resolving this issue. This clarification will\n\n<<<PAGE 5>>>\n\nassist the Washington Utilities and Transportation Commission staff in interpreting and applying the\nrequirements of Subpart K during future up rates. If you have any question or need any additional\ninformation, please contact Scott Rukke at (360)664-1241.\nThank you for your time and assistance.\nSincerely,\nDouglas Kilpatrick, P.E.\nPipeline Safety Director","truncated":false,"body_characters":7925}