{"operation":"document","citation":"PI-09-0015","title":"Pipeline Safety Interpretation PI-09-0015","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-08-18","effective_on":null,"summary":"PI-09-0015 concerning 192.513, 192.557.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0015","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2009/PI-09-0015.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nAUG 1 8 2009\nMr. Paul Cabot\nGPTC Secretary\nGas Piping Technology Committee (GPTC)\nAmerican Gas Association\n400 North Capitol Street, NW\nSuite 450\nWashington, DC 20001\nDear Mr. Cabot:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nOctober 19,2006, you requested an interpretation of the applicability of the Federal pipeline\nsafety regulations in 49 CFR Part 192 to plastic natural gas pipelines. Specifically, you\nrequested an interpretation of 49 CFR §§ 192.513(c), 192.557(c), and 192.619(a)(2)(i) as they\nrelate to uprating polyethylene (PE) pipelines. You used the example of a 4-inch PE pipeline\nwith a design pressure rating of 100 psig, tested to 75 psig at the time of construction, with a\nmaximum allowable operating pressure (MAOP) of 50 psig. You suggested an approach to\nuprating such a line to 60 psig in increments without testing the pressure and asked whether your\napproach would be permissible under current regulations.\nYou correctly noted that § 192.557( c) permits uprating a pipeline by increasing line pressure in\nincrements. You referenced a November 14, 1973, Office of Pipeline Safety interpretation for\nsteel pipelines that permitted incremental uprating of steel pipelines without a pretest. You\nstated your belief that if this interpretation were applied to plastic pipelines, uprating\nincrementally in accordance with § 192.557( c) would be acceptable without testing the pressure.\nYou expressed your view that it would be acceptable to incrementally increase the pressure to the\nnew MAOP without testing it to 1.5 times the new MAOP.\nAs the regulatory agency with primary responsibility. for pipeline safety in the U.S., PHMSA is\nobligated to ensure the pipeline safety requirements provide an adequate margin of safety. In\ncarrying out our responsibilities, we appreciate receiving input and views from all stakeholders\nand particularly appreciate the views of the GPTC. In this case, however, we can not agree that\nthe above referenced interpretation can be applied to plastic pipelines. Under § 192.619 the\nMAOP requirements for steel and plastic pipelines are not the same. For plastic pipelines\n§ 192.619(a)(2)(i) requires the following:\nThe Pipeline and Hazardous Materials Safety Administration. Otlice of Pipcline Safety provides written clarifications of the\nRegulations (49 CFR Parts 190-199) in the form of interpretation letters. These lettcrs reflect the agency's current appl ication of\nthe regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-\nenforceable rights or obligations and are provided to hdp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\n§ 192.619 - (a) Except as provided in paragraph (c) of this section, no person may\noperate a segment of steel or plastic pipeline at a pressure that exceeds the lowest\nof the following:\n(1) ...\n(2) The pressure obtained by dividing the pressure to which the segment was\ntested after construction as follows:\n(i) For plastic pipe in all locations, the test pressure is divided by a factor\nof 1.5.\nWe agree that § 192.557 allows the uprating ofPE pipelines. However, § 192.619 (a)(2)(i)\nrequires the operator to increase the uprating test pressure to 1.5 times the new MAOP in order to\nmeet the lowest limiting factor for the new MAOP. Therefore, in order for the operator to\nincrease the MAOP from 50 psig to 60 psig, a pressure test to 1.5 times the new MAOP (90 psi g)\nmust be conducted to comply with the § 192.619 (a)(2)(i) requirements. I In addition, other\napplicable requirements must be met including:\n• Following procedures prior to uprating (§ 192.557(b)(1 »;\n• Checking rating of applicable appurtenances for the test pressure; and\n• Meeting and maintaining operating conditions to ensure pressure increments as required\nby the uprating (§ 192.553(a».\nI hope that this information is helpful to you. If I can be of further assistance, please contact me\nat (202) 366-4046.\nSincerely,\nI Note that § 192.553 was amended on September 15,2003, [68 FR 53895] to make direct reference to § 192.619\nand clarify the uprating requirements. This amendment addressed the concern that the previous language referring\nto \"this part\" was potentially being applied differently among the States. This was a key focus of the work done\nunder the State Industry Regulatory Review Committee (SIRRC) II in recognizing the principal differences between\nstrength test vs. leak test. The SIRRC II formulated the proposed language to state these would be subjected to\nincremental pressure increases to the desired new MAOP with an additional leak survey to be performed no sooner\nthan 10 days and no later than 30 days after the date the last pressure increase is achieved.\nThe Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety provides written clarifications of the\nRegulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of\nthe regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-\nenforceable rights or obligations and are provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nPaul Cabot\nGPTC Secretary\n(202) 824-7312\nFax (202) 824-9122\npcabot@aga.org\nOctober 19, 2006\nRichard D. Huriaux\nManager Regulations\nOffice of Pipeline Safety (DPS -10), RSPA\nU.S. Department of Transportation\n400 Seventh Street, SW Room 7128\nWashington, DC 20590-001\nRe: Uprating plastic pipelines to 100 psi or below does not require additional testing\nDear Mr. Huriaux:\nThe Gas Piping Technology Committee (GPTC) consists of about 80 members with technical\nexpertise in natural gas distribution, transmission, and gathering systems. Its membership is\nbalanced between gas distribution operators, gas transmission operators, manufacturers, and\ngeneral interest personnel such as federal and state regulators. The GPTC is an Independent\ntechnical committee and has been an American National Standards Institute (ANSI) accredited\ncommittee since 1992 and has the ANSI committee designation of ANSI/GPTC Z380. The\nAmerican Gas Association (AGA) has been the Secretariat to this committee since 1990.\nThe GPTC respectfully requests an interpretation on the application of several sections of Title\n49, Part 192, Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety\nStandards, specifically Sections 192.513(c), 192.557(c) and Section 192.619(a)(2)(i) as these\nrelate to uprating PE pipelines.\nGiven the example:\nA 4\" PE pipeline, with a design pressure rating of 100 psig, was initially tested at the time of\nconstruction to 75 psig in accordance with Section 192.513(c). This gave the pipeline an MAOP\nof 50 psig as defined in 192.619(a)(2)(i).\nNow, going forward, an operator has interest in uprating the above referenced pipeline to a\nhigher MAOP of 60 psig.\nPage 1 of 2\n\n<<<PAGE 4>>>\n\nThe new MAOP of 60 psig can be approached and established by increasing line pressure in\nincrements up to the 60-psig limit. The GPTC considers the above uprating procedure to be\nacceptable based on the interpretation of referenced code sections. Further, the GPTC is aware\nOPS previously provided a similar interpretation dated November 14, 1973 for steel pipelines\noperating below 100 psig. In that interpretation under question 3, OPS stated, \"Section\n192.557(c) requires only that the new MAOP be approached in increments. In uprating, the\npretest to 90 psig would not be required.\" This interpretation is attached as a reference.\nTherefore, the GPTC respectfully requests OPS to affirm the above interpretation is also\napplicable for plastic pipelines operating at 100 psig or below. The affirmation would confirm\nthat Section 192.557(c) does not require the total pressure increase to be 1.5 times the proposed\nMAOP, instead the total pressure would be increased up to the proposed MAOP in increments.\nYour prompt consideration would be appreciated.\nSincerely,\nPaul Cabot\nGPTC Secretary\nAmerican Gas Association\ncc: Marek\nFrantz\nSlagle\nattachment: 11/14/73 OPS Interpretation\nPage 2 of 2\n\n<<<PAGE 5>>>\n\nNovember 14, 1973\nMr. John Searcy\nTennessee Public Service Commission\nCordell Hull Building\nNashville, TN 37219\nDear Mr. Searcy:\nIn your letter of October 3, 1973, you requested interpretations of various sections of Part 192, Title 49,\nCFR, that related to maximum allowable operating pressures (MAOP), certain test requirements, and\nuprating. Your specific questions and the Office of Pipeline Safety (OPS) answers are:\nQuestion 1: Re: Maximum allowable operating pressures\n\"192.619(a)(2) requires that test pressure values be used as criteria for determining maximum allowable\noperating pressures; however, it applies only to steel operating at or above 100 psi and plastic.\n\"192.621 covers all materials including cast iron and ductile iron; however, it does not require that test\npressure values be used as criteria for determining maximum allowable operating pressures.\n\"Therefore, I conclude that, for steel operating below 100 psi and for cast iron and ductile iron operating at\nany pressure, test pressure valves are not required criteria for determining maximum allowable operating\npressures. Is this your interpretations?\"\nQuestions 2: Re: Test requirements\n\"192.507(b) provides test requirements for pipelines of all materials operating at or above 100 psi and less\nthan 30% SMYS and requires test pressure values between 100 psi and those required to produce 20%\nSMYS. However, it does not specify what the values will be. 192.619 would determine the test pressure\nvalues within this range for steel and plastic by relating them to maximum allowable operating pressure.\nHowever, 192.619 does not apply to cast iron and ductile iron.\n\"192.509 covers pipelines of all materials operating at or below 100 psi, and requires 10 psi or 90 psi as\ntest pressures.\n\"The conclusion here would be that values of test pressures can be established in any pressure range for\nsteel and plastic, and for cast iron and ductile iron operating at or below 100 psi; however, there is no\nrequired test pressure value for cast iron and ductile iron operating above 100 psi. Is this the proper\ninterpretation?\"\nAnswer to Questions 1 & 2\nDB\nC:\\WP51\\INTERPRT\\192\\619\\73-11-14.N\n1\n\n<<<PAGE 6>>>\n\nTest requirements for pipelines to operate at or below 100 psig is established by Section 192.509 based\nupon the intended MAOP and is applicable with the exception of service lines and plastic pipe. Cast iron\nand ductile iron pipelines would be included under this section if the intended MAOP is 100 psig or less.\nFor pipelines to operate at a hoop stress of less than 30 percent SMYS but more than 100 psig, Section\n192.507 is applicable, with limitations on the MAOP for steel and plastic pipelines being set by Section\n192.619.\nYour interpretation is correct. There is no specific test pressure required for cast iron and ductile iron\noperating above 100 psig and up to 30 percent of SMYS. However, the operator must comply with the\nrequirements of Sections 192.507 and 192.53.\nQuestion 3: Re: Uprating\n\"192.557(c) provides that an increase in maximum allowable operating pressure must be made in\nincrements. However, the following questions arise:\n\"(1) If the maximum allowable operating pressure it to be increased within the 1 psi to 100 psi\nrange, and no test records are available, must it be tested to 90 psi first, in accordance with\n192.509, and if so, must the test pressure be approached in the increments specified in\n192.557(c)?\n\"(2) Or, does 192.557(c) require only that the new maximum allowable operating pressure\nitself be approached in the increments required?\nAnswer to Question 3\nSection 192.557(c) requires only that the new MAOP be approached in increments. In uprating, the pretest\nto 90 psig would not be required.\nIf we may assist further, please let us know.\nSincerely,\n/signed/ Cesar De Leon\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\619\\73-11-14.N\n2","truncated":false,"body_characters":12281}