{"operation":"document","citation":"PI-03-0105","title":"Commonwealth of Pennsylvania Public Utility Commission Bureau of Transportation and Safety — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-06-11","effective_on":null,"summary":"PI-03-0105 response to Commonwealth of Pennsylvania Public Utility Commission Bureau of Transportation and Safety concerning 192.11.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-03-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-03-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-03-0105","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2003/g03-06-11_Metro_192.11-lmx.pdf","body":"<<<PAGE 1>>>\n\nPI-03-0105\nU. S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh St., S.W.\nWashington, D.C. 20590\nJune 11, 2003\nMr. Paul Metro\nSupervisor, Gas Safety Division\nPennsylvania Public Utility Commission\nBureau of Transportation and Safety\n400 North Street, 300 Barto\nHarrisburg, PA 17105-3265\nDear Mr. Metro:\nThis is in response to your request of January 29, 2002, for an interpretation of the gas pipeline\nsafety regulations at 49 CFR 192.59(b)(3) related to the reuse of polyethylene pipe.\nPPL Gas Utilities Corporation (PPL) intends to convert a polyethylene distribution system from\npropane vapor service to natural gas service, and has requested an interpretation. PPL's position is that:\n. . . in accordance with § 192.11, Petroleum gas systems, the propane distribution system is\nalready subject to Part 192. New polyethylene pipe was installed in 1988, and met the\nrequirements of § 192.11, along with the requirements of § 192.50(a). Because the piping\nsystem is already qualified under § 192.59(a), the plastic pipe should not be considered\n\"used\" and subject to both § 192.59(a) and § 192.5(b).\nPPL recognizes that liquid propane can have an effect on plastic pipe, including possible problems\nwith fusibility. They also note that the system has been operated in accordance with 49 CFR Part 192,\n\"Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards,\" and\nANSI/NFPA 58, \"Standard for the Storage and Handling of Liquefied Petroleum Gases,\" which limits the\noperating pressure of polyethylene piping carrying propane to 30 psig. The PPL system has been\noperating at a pressure of 10 psig, which would not result in deleterious condensation.\nThere is no question that the piping in question has been transporting propane vapor and that\nsuch service has been subject to 49 CFR Part 192. Therefore, the only question is whether use of this\npiping system for natural gas service is allowable under § 192.59(b)(3). This section allows the use of used\nplastic pipe for natural gas service if it was manufactured in accordance with a listed specification, if it is\nresistant to chemicals, if it is free of visible defects, if its dimensions are still within tolerances of the\nspecification to which it was manufactured, and if it has been used only in natural gas service.\nWe do not consider changing the gas service from propane vapor to natural gas for pipe that\nhas always been in compliance with 49 CFR Part 192 to constitute the use of \"used plastic pipe\" as\ncontemplated in § 192.59(b)(3). Therefore, conversion of a jurisdictional polyethylene plastic distribution\nsystem from propane vapor service to natural gas service is acceptable.\nIf you have any further questions about the pipeline safety regulations, please contact me at\n(202) 366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nPPL Gas Utilitites\n555 Camargo Road\nQuarryville, PA 17566-9210\nOctober 11, 2001\nDear Mr. Finnan:\nPPL Gas Utilities Corporation (PPL) operates gas pipelines in Pennsylvania, and is subject to pipeline\nsafety regulations as outlined in Pennsylvania Title 52, Chapter 59, which incorporates the federal\nregulations implemented in 49 CFR Part 191, 192, 193, and 199. PPL desires to convert a polyethylene\ndistribution system from propane vapor service to natural gas service, and respectively requests an\ninterpretation of 49 CFR 192.59 Plastic pipe.\nThe Pennsylvania Public Utilities Commission expressed concern that conversion of a plastic distribution\nsystem from propane vapor to natural gas service would not meet the requirements of 192.59 (b) (3)\nwhich states:\n(b) Used plastic pipe is qualified for use under this part if:...\n(3) It has been used only in natural gas service.\nPPL's position is that in accordance with 192.11 Petroleum gas systems, the propane distribution system\nis already subject to Part 192. New polyethylene pipe was installed in 1988, and met the requirements of\n192.11, along with the requirements of 192.59 (a). Because the piping system is already qualified under\n192.59 (a), the plastic pipe should not be considered \"used\" and subject to both 192.59(a) and 192.59 (b).\nPPL recognizes the possible effect that liquid propane can have plastic pipe, including possible problems\nwith future fusion operations. Based on the actual operating temperatures and pressures of the system,\npropane condensates are very unlikely. The system has been operated in accordance with the NFPA 58\nLP-Gas Code, which limits the operating pressure of polyethylene piping to 30 psig. At 30 psig, propane\ncondensation would not occur until the temperature reaches 10 degrees Fahrenheit. At the actual\noperating pressure of 10 psig, condensation would not have occurred unless the temperature reached 20\ndegrees Fahrenheit.\nPPL contends that changing gas service, from propane vapor to natural gas, is in compliance with\nexisting Part 192 requirements. The conversion of service will not compromise public safety, and the\nconversion is being prompted by a request of our customers. If the conversion is not allowed, the piping\nsystem will be replaced at a significant cost to PPL, and the public will be subject to additional\ninconveniences during construction activities.\nPPL Gas Utilities strives to operate a safe pipeline system and to be in compliance with state and federal\nregulations. We respectfully request that you seek clarification as to whether continued utilization of\nplastic pipe, qualified under Part 192, becomes \"used\" pipe, if the pipeline changes from propane vapor\nservice to natural gas service.\nWe would appreciate a prompt response, and you can contact me at 717-560-2750 if you have any\nquestions.\nSincerely,\nRobert F. Beard, P.E.\nManager\nEngineering and Technical Services\n\n<<<PAGE 3>>>\n\nCOMMONWEALTH OF PENNSYLVANIA\nPUBLIC UTILITY COMMISSION\nBUREAU OF TRANSPORTATION AND SAFETY\nOctober 18, 2001\nMR RICHARD HURIAUX, OFFICE OF TECH & REGS\nDOT/RSPA/OPS DP S-12\n400 SEVENTH STREET SW ROOM 7128\nWASHINGTON DC 20590\nREF: PLASTIC PIPE REQUEST FOR INTERPRETATION (192.59)\nDear Mr. Huriaux:\nAttached is a copy of a letter from PPL Gas Utilities requesting an interpretation related to the\nreuse of polyethelene pipe which previously had been utilized for the distribution of a propane-air\nmixed gas. Part 192.59(b)(3) allows reuse of pipe if \"it has been used only in natural gas service\". We have\nreservations about the reuse of this pipe due to the possibility of the liquid propane precipitating out\nand the effects the liquid might have on the integrity of the pipe. Also there is a question as to whether a\npropane- air mixture qualifies as natural gas for the purpose of 192.59. This propane-air mixture was not\nfed into a distribution system but was the only gas in this piping.\nThe petitioner has requested a prompt response in order that they may proceed with the use or\nreplacement of the pipe in question.\nThank you in advance for your cooperation in this matter.\nYou may call me at (717) 787-1063 or e-mail me at finnan@puc.state.pa.us with any questions.\nVery truly yours,\nJoseph T. Finnan, Supervisor\nGas Safety Division\nBureau of Transportation and Safety","truncated":false,"body_characters":7233}