{"operation":"document","citation":"PI-10-0003","title":"Central Hudson Gas & Electric Corp. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-09-17","effective_on":null,"summary":"PI-10-0003 response to Central Hudson Gas & Electric Corp. concerning 192.321.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-10-0003.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-10-0003.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-10-0003","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2010/PI-10-0003.pdf","body":"<<>>\n\nu.s. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nSEP 1 7 2010\nMr. David W. Merte, P.E.\nCentral Hudson Gas & Electric Corp.\n284 South Avenue\nPoughkeepsie, NY 12601\nDear Mr. Merte:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nMarch 22, 2010, you requested an interpretation as to whether Central Hudson Gas & Electric\nCorporation can utilize plastic pipe that is exposed to ultraviolet light for up to four years. You\nstated that plastic pipe manufactured by Perfonnance Pipe testing predicts that Driscopipe\n8100 series pipe has an outdoor unprotected exposure of at least four years (manufacturer's\ntechnical note included).\nYou stated that you have discussed outdoor storage of this pipe with the New York State\nDepartment of Public Service - Gas Safety Division Staff (GSD) and that the GSD staffhas\nindicated that PHMSA does not allow outdoor unprotected storage of plastic pipe for more than\ntwo years and has suggested that you request a PHMSA interpretation of this issue.\nWe agree with the GSD staff that plastic pipes should not be exposed to ultraviolet light for more\nthan the plastic pipe manufacturer's recommended maximum period of exposure or a maximum\nof two years, whichever is less, unless the pipes meet the American Society for Testing of\nMaterials (ASTM) D-2513-99 requirements. The ASTM D-2513-99 is incorporated by reference\ninto 49 CFR Part 192. In this case, two years is less than the manufacturer's recommendation of\nfour years. Section A1.5.7 of ASTM D-2513-99 states:\nOutdoor Storage Stability-PE pipe stored outdoors and unprotected for at least two\nyears from date of manufacture shall meet all the requirements of this specification. PE\npipe stored outdoors for over two years from date of manufacture is suitable for use if it\nmeets the requirements of this specification.\nThe technical note you provided (Technical Note PP 839-TN) states, \"ASTM D2513 allows\noutdoor storage times in excess of two years where the manufacturer has shown that the pipe\nperfonnance properties are not affected by the extended outdoor storage time.\" This statement\ndoes not appear to refer to the 1999 version of ASTM D-2513 requirements and, therefore, the\ncontents of the Technical Note do not fully qualify PE pipes to meet the requirements of ASTM\nD-2513-99 when the pipes are stored outdoors unprotected for more than two years. Based on\nthe infonnation you provided, PE pipes that are stored outdoors unprotected in excess of the two\nyear limit do not comply with the 49 CFR Part 192 requirements.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<>>\n\n2\nI hope that this information is helpful to you. If I can be of further assistance, please contact me\nat 202-366-4046.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<>>\n\nRECEIVED MAR 25 1010 .. ~\n!Central Hudson ~::::-\nGas & Electric Corporation\nMarch 22, 2010\nMr. Dino Rathod, P.E.\nNew York State Liaison\nPHMSA Eastern Regional Office\n820 Bear Tavern Road, Suite 306\nWest Trenton, New Jersey 08628\nDear Mr. Rathod:\nCentral Hudson Gas & Electric Corporation utilizes Driscopipe 8100 Series\nplastic pipe manufactured by Performance Pipe. We have discussed outdoor storage of\nthis pipe with the New York State Department of Public Service - Gas Safety Division\nStaff Central Hudson has noted that Performance Pipe testing predicts that Dri copipe\n8100 series pipe has an outdoor unprotected exposure of at least four years. P Staff\nhas indicated that PHMSA does not allow outdoor unprotected storage of plastic pipe for\nmore than two years and has suggested that we request a PHMSA interpretation of this\nIssue.\nIn accordance with AS TM D 2513 AI. 5.7, \" .. . PE pipe stored outdoors for over\ntwo years from date of manufacture is suitable for use if it meets the requirements of this\nspecification.\" Performance Pipe publishes a Technical Note PP 839-TN (attached) that\nindicates Driscopipe 8100 is protected against outdoor exposure through additive\nformulations. The bulletin further indicates \"Accelerated laboratory weathering tests\nwere conducted on the formulations that predict the yellow pipe materials are protected\nsufficiently to provide a service life of at least four years in outdoor exposure\nconditions. \"\nI would appreciate your response on the potential maximum term of unprotected\noutdoor exposure for the storage of plastic pipe in accordance with 49 CFR Part 192\nrequirements.\n-------\nerte, P ..\nSection Leader - Gas System Safety and Pipeline Integrity\n284 South Avenue\nPoughkeepsie NY 12601\n(845) 452 • 2700\nwww.CentraIHudson.com\n\n<<>>\n\ne\nwww.performancepipe.com\nTechnical Note PP S39-TN\nWeatherability\nOutdoor Storage Limits of Performance Pipe\nGas - Distribution Pipe Products\nPeFformane&Ptpe pofyetnytene;'gS'S'dfstRbU'tjon · piping products are protected from- UV .\neffects and outdoor exposure to ensure pipe performance requirements are\nmaintained. ASTM 02513 requires that all polyethylene gas pipes produced to the\nstandard must 'be able to 'withstand a minimum of 2 years outdoor 'storage without\naffecting the pipe's ability to meet the requirements of the standard, ASTM D2513\nallows outdoor storage times in excess of 2 years where the manufacturer has shown\ntrIat~~performane& properties are not affected by the extended' outdoorstorage'\ntime.\n1\nYellow Pipes\nYellow pipes, such as Oriscopipe® 8100 and OriscoPlex® 6500, are protected against\nouktoor exposur.e -through, additive 'foFml1latioos. Accelerated'iaboratory weathefing .'\ntests were conducted on the formulations that predict the yellow pipe materials are\nprotected sufficiently to provide a service life of at least four years in outdoor exposure\n,oond1tions. The \"accelerated tests measure' 'changes in the ·tensile properties ' of 'the\npolyethylene materials after exposure to high levels of UV and humidity, Performance\nPipe also' conducts' actual field pipe exposure tests to- confirm the acceterated '\nlaboratory ,weathering test predictions. At periodiC time intervals the . field .exposed\npipe samples are tested for melt flow (ASTM 01238 condition 190/2.16), hoop\nstress/ring tensile (ASTM 01598/ASTM 02290), and ESCR (ASTM 01693, condition\nC). The test data confirm that there is no measurable change in pipe performance\nproperties after 'over foar'years of outdoor exposure. A summary of the test data is\nattached.\nNOTICE. This publication is for informational purposes and is intended for use as a reference guide. II should not be used in place of the\nadvice of a professional engineer. This publication does not contain or confer any warranty or guarantee of any kind. Performance Pipe has\nmade every reasonable effort towards the accuracy of the information contained in this publication, but it may not provide all necessary\ninformation, particularly with respect to special or unusual applications. This publication- may be changed from time to time without notice.\nContact Performance Pipe to ensure that you have the most current editiOn.\nI ASTM D2S13-04a Section AI.S. 7 Outdoor Storage Stabiliz..\nBulletin: PP 839-TN\nPage 1 of3\nJune 2001 Supersedes all previous publications\n® 2001 Chevron Phillips Chemical Company LP\nPerformance Pipe, a division of\nChevron Phillips Chemical Company LP\nPO Box 269006\nPlano, TX 76026-9066\nPhone: 800-627-0662\nFax: 972-699-7348\n\n<<>>\n\n--\n-----J4~\n~\"\".\nA Dms/oN 1)1 (afYIO' f'IIltIm OWI/(Al (OM'ANY lP\nwww.performancepipe.com\nBlack Pipes\nFor black pipes, such as Yellowstripe® 8300, the presence of a minimum of 2% carbon\nblack. .pr~per.l.y\n·dispersed in the . polyethylene piping material . .pr.ovides IORQ term\nprotection from the potentially damaging affects of UV and outdoor exposure.\n'Weathering studies have ' .sRown . that pipe J)l:odl:Jced with. a minimum . 2.00/ 0'\nconcentration of finely divided and evenly dispersed carbon black is protected from the\nhannful effects of UV radiation for indefinite periods of time.'2 Field experience of\npiping materials containing a minimum of 2% carbon black confirms that pipe\nperforrnancedoes not deteriorate after extended years ' of 'service in selected outdoor\nexposure.\nBased.on . . ltla.~-ta6ta A cQnd.\"ded,. PerformancaPipe .. p[(}Vides. the .following. specific.\noutdoor storage recommendations for the Perfonnance Pipe gas distribution piping\nproducts.\nQ DriscoPlex® 6500\nQ DriscopipeiIP 8100\nQ Yellowstripe® 8300\n4 years\n4 years\n10 years\nRing Tensile vs. Exposure Time\n3500\n_ :!l00 • .-\nf i >>\n\n•\n•\n____ 4~\n--/ ?\nI'sIIoIIMAIIaPR\nA Oms/oil IJI (HErlOIII'II/tII'S (Hill/{AI (OM'Allr LP\nwww.performancepipe.com\nMelt Index w. Exposure Time\n~\n025\n02\ni'\nE 015\ni 01\n005\n0\n-\n~\n4\n,.\n............ -\n'...-.--. ---\n-..\n0\n10\n20 :I) 40 50 60\nuve\"\"\"\"u .. (Mmths)\nESCR vs Exposure Time\nc-\n'E\nIi\ni\n.9\n~\nlalO\nHXIO\nIllO\nlIlO\n400\nalO\n0\n-\n-\n-\n0\n10\n20 :I)\nw e\"\"\"\"UIe (r.tonths)\n40\n50\nBulletin: PP 83B-TN\nPage 3 013\nJune 2008 Supersedes all previous publications\n® 2008 Chevron Phillips ChemIcal Company LP\nPerformance Pipe. a division of\nChevron Phillips Chemical Company LP\nPO Box 269006\nPlano. TX 75026-9066\nPhone: 800-627..0682\nFax: 972-699-7348\n-","truncated":false,"body_characters":10537}