Central Hudson Gas & Electric Corp. — Pipeline Safety Interpretation

Page 1u.s. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 SEP 1 7 2010 Mr. David W. Merte, P.E. Central Hudson Gas & Electric Corp. 284 South Avenue Poughkeepsie, NY 12601 Dear Mr. Merte: In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated March 22, 2010, you requested an interpretation as to whether Central Hudson Gas & Electric Corporation can utilize plastic pipe that is exposed to ultraviolet light for up to four years. You stated that plastic pipe manufactured by Perfonnance Pipe testing predicts that Driscopipe 8100 series pipe has an outdoor unprotected exposure of at least four years (manufacturer's technical note included). You stated that you have discussed outdoor storage of this pipe with the New York State Department of Public Service - Gas Safety Division Staff (GSD) and that the GSD staffhas indicated that PHMSA does not allow outdoor unprotected storage of plastic pipe for more than two years and has suggested that you request a PHMSA interpretation of this issue. We agree with the GSD staff that plastic pipes should not be exposed to ultraviolet light for more than the plastic pipe manufacturer's recommended maximum period of exposure or a maximum of two years, whichever is less, unless the pipes meet the American Society for Testing of Materials (ASTM) D-2513-99 requirements. The ASTM D-2513-99 is incorporated by reference into 49 CFR Part 192. In this case, two years is less than the manufacturer's recommendation of four years. Section A1.5.7 of ASTM D-2513-99 states: Outdoor Storage Stability-PE pipe stored outdoors and unprotected for at least two years from date of manufacture shall meet all the requirements of this specification. PE pipe stored outdoors for over two years from date of manufacture is suitable for use if it meets the requirements of this specification. The technical note you provided (Technical Note PP 839-TN) states, "ASTM D2513 allows outdoor storage times in excess of two years where the manufacturer has shown that the pipe perfonnance properties are not affected by the extended outdoor storage time." This statement does not appear to refer to the 1999 version of ASTM D-2513 requirements and, therefore, the contents of the Technical Note do not fully qualify PE pipes to meet the requirements of ASTM D-2513-99 when the pipes are stored outdoors unprotected for more than two years. Based on the infonnation you provided, PE pipes that are stored outdoors unprotected in excess of the two year limit do not comply with the 49 CFR Part 192 requirements. The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 22 I hope that this information is helpful to you. If I can be of further assistance, please contact me at 202-366-4046. The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 3RECEIVED MAR 25 1010 .. ~ !Central Hudson ~::::- Gas & Electric Corporation March 22, 2010 Mr. Dino Rathod, P.E. New York State Liaison PHMSA Eastern Regional Office 820 Bear Tavern Road, Suite 306 West Trenton, New Jersey 08628 Dear Mr. Rathod: Central Hudson Gas & Electric Corporation utilizes Driscopipe 8100 Series plastic pipe manufactured by Performance Pipe. We have discussed outdoor storage of this pipe with the New York State Department of Public Service - Gas Safety Division Staff Central Hudson has noted that Performance Pipe testing predicts that Dri copipe 8100 series pipe has an outdoor unprotected exposure of at least four years. P Staff has indicated that PHMSA does not allow outdoor unprotected storage of plastic pipe for more than two years and has suggested that we request a PHMSA interpretation of this Issue. In accordance with AS TM D 2513 AI. 5.7, " .. . PE pipe stored outdoors for over two years from date of manufacture is suitable for use if it meets the requirements of this specification." Performance Pipe publishes a Technical Note PP 839-TN (attached) that indicates Driscopipe 8100 is protected against outdoor exposure through additive formulations. The bulletin further indicates "Accelerated laboratory weathering tests were conducted on the formulations that predict the yellow pipe materials are protected sufficiently to provide a service life of at least four years in outdoor exposure conditions. " I would appreciate your response on the potential maximum term of unprotected outdoor exposure for the storage of plastic pipe in accordance with 49 CFR Part 192 requirements. ------- erte, P .. Section Leader - Gas System Safety and Pipeline Integrity 284 South Avenue Poughkeepsie NY 12601 (845) 452 • 2700 www.CentraIHudson.com#

Page 4e www.performancepipe.com Technical Note PP S39-TN Weatherability Outdoor Storage Limits of Performance Pipe Gas - Distribution Pipe Products PeFformane&Ptpe pofyetnytene;'gS'S'dfstRbU'tjon · piping products are protected from- UV . effects and outdoor exposure to ensure pipe performance requirements are maintained. ASTM 02513 requires that all polyethylene gas pipes produced to the standard must 'be able to 'withstand a minimum of 2 years outdoor 'storage without affecting the pipe's ability to meet the requirements of the standard, ASTM D2513 allows outdoor storage times in excess of 2 years where the manufacturer has shown trIat~~performane& properties are not affected by the extended' outdoorstorage' time. 1 Yellow Pipes Yellow pipes, such as Oriscopipe® 8100 and OriscoPlex® 6500, are protected against ouktoor exposur.e -through, additive 'foFml1latioos. Accelerated'iaboratory weathefing .' tests were conducted on the formulations that predict the yellow pipe materials are protected sufficiently to provide a service life of at least four years in outdoor exposure ,oond1tions. The "accelerated tests measure' 'changes in the ·tensile properties ' of 'the polyethylene materials after exposure to high levels of UV and humidity, Performance Pipe also' conducts' actual field pipe exposure tests to- confirm the acceterated ' laboratory ,weathering test predictions. At periodiC time intervals the . field .exposed pipe samples are tested for melt flow (ASTM 01238 condition 190/2.16), hoop stress/ring tensile (ASTM 01598/ASTM 02290), and ESCR (ASTM 01693, condition C). The test data confirm that there is no measurable change in pipe performance properties after 'over foar'years of outdoor exposure. A summary of the test data is attached. NOTICE. This publication is for informational purposes and is intended for use as a reference guide. II should not be used in place of the advice of a professional engineer. This publication does not contain or confer any warranty or guarantee of any kind. Performance Pipe has made every reasonable effort towards the accuracy of the information contained in this publication, but it may not provide all necessary information, particularly with respect to special or unusual applications. This publication- may be changed from time to time without notice. Contact Performance Pipe to ensure that you have the most current editiOn. I ASTM D2S13-04a Section AI.S. 7 Outdoor Storage Stabiliz.. Bulletin: PP 839-TN Page 1 of3 June 2001 Supersedes all previous publications ® 2001 Chevron Phillips Chemical Company LP Performance Pipe, a division of Chevron Phillips Chemical Company LP PO Box 269006 Plano, TX 76026-9066 Phone: 800-627-0662 Fax: 972-699-7348#

Page 5-- -----J4~ ~"". A Dms/oN 1)1 (afYIO' f'IIltIm OWI/(Al (OM'ANY lP www.performancepipe.com Black Pipes For black pipes, such as Yellowstripe® 8300, the presence of a minimum of 2% carbon black. .pr~per.l.y ·dispersed in the . polyethylene piping material . .pr.ovides IORQ term protection from the potentially damaging affects of UV and outdoor exposure. 'Weathering studies have ' .sRown . that pipe J)l:odl:Jced with. a minimum . 2.00/ 0' concentration of finely divided and evenly dispersed carbon black is protected from the hannful effects of UV radiation for indefinite periods of time.'2 Field experience of piping materials containing a minimum of 2% carbon black confirms that pipe perforrnancedoes not deteriorate after extended years ' of 'service in selected outdoor exposure. Based.on . . ltla.~-ta6ta A cQnd."ded,. PerformancaPipe .. p[(}Vides. the .following. specific. outdoor storage recommendations for the Perfonnance Pipe gas distribution piping products. Q DriscoPlex® 6500 Q DriscopipeiIP 8100 Q Yellowstripe® 8300 4 years 4 years 10 years Ring Tensile vs. Exposure Time 3500 _ :!l00 • .- f i <li00 . ;:000 ii .!! 1500 i ... fOOO 2' 12 500 0 0 10 Zl :!l 40 UVet~u .. (_s) !D 60 2 Plastic Pipe Institute 'Handbook of Polyethylene Pipe' Chapter 8, Aboye Ground Applications Page 2 of 3 June 201)8 SUpersecf",altprevlous publlcatlons @ 2008 Chevron Phillips Chemical Company LP Performance Pipe. a division of Chevron Phillips Chemical Company LP po Box 269006 Plano. TX 76026·9066 Phone: 800-627'()662 Fax: 972-599-7348#

Page 6• • ____ 4~ --/ ? I'sIIoIIMAIIaPR A Oms/oil IJI (HErlOIII'II/tII'S (Hill/{AI (OM'Allr LP www.performancepipe.com Melt Index w. Exposure Time ~ 025 02 i' E 015 i 01 005 0 - ~ 4 ,. ............ - '...-.--. --- -.. 0 10 20 :I) 40 50 60 uve""""u .. (Mmths) ESCR vs Exposure Time c- 'E Ii i .9 ~ lalO HXIO IllO lIlO 400 alO 0 - - - 0 10 20 :I) w e""""UIe (r.tonths) 40 50 Bulletin: PP 83B-TN Page 3 013 June 2008 Supersedes all previous publications ® 2008 Chevron Phillips ChemIcal Company LP Performance Pipe. a division of Chevron Phillips Chemical Company LP PO Box 269006 Plano. TX 75026-9066 Phone: 800-627..0682 Fax: 972-699-7348 -#