{"operation":"document","citation":"PI-10-0013","title":"Pipestream, Inc — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-11-18","effective_on":null,"summary":"PI-10-0013 response to Pipestream, Inc concerning 192.309, 192.485, 192.487, 192.713, 192.717, 195.585.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-10-0013.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-10-0013.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-10-0013","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/Pipeline/2010/PI-10-0013.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department 1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nNOV 1 8 2010\nMr. Raymond N. Burke\nPipestream, Inc.\nExecutive Vice President and COO\n6955 High Life Drive\nHouston, TX. 77066\nDear Mr. Burke:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nApril 22, 2010, you requested an interpretation ofthe Federal Pipeline Safety Regulations\nrelating to pipe repairs at 49 CFR §§ 192.309(b), 192.485(a), 192.487(a), 192.713(a)(2) and\n192.717(b)(5) and 49 CFR § 195.585(a)(2). You noted that these regulations were amended in\n1999 to allow alternative repair of unacceptable damages, dents, imperfections, corrosion, and\nleaks\"... by a method that reliable engineering tests and analyses show can permanently restore\nthe serviceability ofthe pipe.\"\nYou requested information from PHMSA on how the gas and hazardous liquid pipeline safety\nregulations address the following questions:\n1. Do these regulations limit the number of discrete applications or the length of\napplication of alternative repair systems?\n2. Can alternative repair systems be used to increase the pressure capacity of a span\nofpipeline above the original maximum operating pressure in response to revised\noperating demands?\n3. Can alternative repair systems be used to address the need to lower stress levels in\nthe base pipe in response to a change in class location or other revised operating\nconditions?\nOur responses to your questions are as follows:\nResponse 1: The regulations do not prescribe a particular limit to the number ofdiscrete\napplications of an alternative repair method. The engineering test data for the material to\nbe used must clearly demonstrate that the alternative repair method will restore the\noriginal design strength ofthe pipe, but will also perform in the pipeline environment in\nwhich it is installed, including withstanding secondary stresses of loading, pipe\nmovement, soil movement, and external loads, for the length ofservice for which it is\nintended. While the 1999 rule (64 FR 69660, December 14, 1999) allows alternative\nThe Pipeline and Hazardous Materials Safety Administration, Office ofPipeline 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 ofthe 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<<<PAGE 2>>>\n\n2\nrepair methods for individual repairs on corroded or damaged steel pipe in natural gas\npipelines or corroded steel pipe in hazardous liquid pipelines where appropriate, an\noperator of a pipe joint having sufficient defects should carefully consider all reliable\nmethods ofrepair before installing an excessive number of alternative repairs.\nResponse 2: No. The regulations require pipeline operators to repair their pipelines as\nnecessary to maintain safety and serviceability. No repair method can be used to increase\nthe original design strength or the pressure of a segment ofpipeline above the established\nmaximum operating pressure.\nResponse 3: No. A change in Class Location is not a repair issue. The stress level and\nmaximum operating pressure ofa given section ofpipe is based on the original material\nand design specifications, not the material used to repair the pipe. Therefore, operators\nmust continue to follow the requirements of §§ 192.609 and 192.611 to confirm or revise\nthe MAOP as necessary upon a change in Class Location, regardless ofwhether an\nalternative repair method was used to perform a repair.\nI hope that this information is helpful to you. If I can be of further assistance, please contact me\nat (202) 366-4046.\nSincerely,\n.~4J\nA/~Gale\nDirector, Office of Standards\nand Rulemaking\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<<<PAGE 3>>>\n\nAPR 28 2010\nPIPESTREAM\nPipestream, Inc.\n6955 High Ufe Drive\nHouston, TX 77066\nApril 22, 2010\nMr. John Gale\nDirector, Office of Regulations\nU.s. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nOffice of Pipeline Safety (PHP-30)\nEast Building, E24-312\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nRe: Request for Interpretation of 49 CFR §§192.309(b), .485(a), .487(a), .713(a)(2) and .717(b)(5) and\n49 CFR 195.585(a)(2).\nDear Mr. Gale:\nPipestream Inc. requests a written interpretation of the federal gas and hazardous liquid pipeline safety\nregulations at 49 CFR §192.309(b), Repair of steel pipe; §192.485(a), Remedial measures: Transmission\nlines; §192.487(a), Remedial measures: Distribution lines other than cast iron or ductile iran lines;\n§192.713(a)(2), Transmission lines: Permanent field repair of imperfections and damages;\n§192.717(a)(5), Transmission lines: Permanent field repair of leaks; and 49 CFR §195.585(a)(2), What\nmust I do to correct corroded pipe? This request is submitted in compliance with §190.11(b)(1),\nAvailability of Written Interpretations.\nUnder the older federal pipeline safety regulations, which are based on standards ASME B31.8 (1968)\nand ASME B31.4 (1966), gas and hazardous liquid pipeline operators were required to repair pipelines\nby one of only two methods: 1) replace the pipe, or 2) repair it by installing a full-encirclement split\nsleeve. These requirements were very prescriptive and discouraged development of new, more efficient\nrepair methods.\nIn 1999 the Office of Pipeline Safety adopted performance-based requirements for pipeline repair (Final\nRule December 14, 1999; 64 FR 69662). Each of the above-cited sections of the pipeline regulations was\nupdated using nearly identical language to allow alternative repair of unacceptable damages, dents,\nimperfections, corrosion, and leaks\n\".•• by a method that reliable engineering tests and analyses show can\npermanently restore the serviceability of the pipe.\"\nThis language was adopted after years of experience by dozens of gas pipeline companies using the\nthen-new Clock Spring\" repair wrap under authority of a waiver. This more permissive language\nrecognized the need for flexibility, encouraged development of new repair technologies, and allowed\nPipestream Inc. 6955 High Ufe Drive; Houston, TX. 77066 www.pipestream.com\n\n<<<PAGE 4>>>\n\npipeline companies tc ~ef~ct the most effective repair technique. These changes also placed on the\noperator the duty to provide full engineering support for the reliability of new repair techniques.\nIn recent years dozens of new repair techniques have been developed and applied under the new\nregulations. Most are non-metallic composite wraps with varying capabilities. Most are used to address\na spot weakness in a pipe, including dents, gouges, corrosion, and leaks. These repair wrap products are\nusually only a few feet in length, but can be used in multiple applications over hundreds of feet of pipe.\nThese close-spaced, multiple applications of repair wrap products have not been challenged by state or\nfederal regulators.\nThe alternative repair language cited above appears to allow any repair method that can restore pipe to\nits original capability, provided it is supported by \"reliable engineering tests and analyses.\" This appears\nto encompass both non-metallic and metallic repair methods. Therefore, the rule does not appear to\nlimit the application of these techniques, but rather is a general performance rule applicable to spot\nrepairs, to multiple spot repairs, or to continuous repairs along hundreds of feet of pipe.\nAmong new methods for repairing and restoring pipe to full functionality is our Pipestream® XHab™\ntechnology. It is a high-strength steel composite wrap that can be applied as a spot repair wrap or as a\nlonger wrap in up to 200 foot increments. Multiple wrap applications can restore pipe to full pressure\ncapacity over extended lengths of pipeline. XHab™ expands the toolbox of repair techniques available\nto pipeline operators. More information on Pipestream® is available on our website:\nwww.pipestream.com.\nWe believe the use of metallic composite repair methods (or any qualified repair method) are allowable\nunder the regulations and are not limited by length of application or number of applications.\nNevertheless, to ensure clarity we request a Letter of Interpretation of the above-cited sections of the\ngas and hazardous liquid pipeline safety regulations to address the following questions:\n1. Do these regulations limit the number of discrete applications or the length of application of\nalternative repair systems?\n2. Can alternative repair systems be used to increase the pressure capacity of a span of pipeline\nabove the original maximum operating pressure in response to revised operating demands?\n3. Can alternative repair systems be used to address the need to lower stress levels in the base\npipe in response to a change in class location or other revised operating conditions?\nThank you for your consideration of this request. We look forward to clarification of these important\nand timely regulatory issues.\nSincerely,\nRaymond N. Burke\nExecutive Vice President and COO\nPipestream Inc. 6955 High Life Drive; Houston, TX. 77066 www.pipestream.com\n\n<<<PAGE 5>>>\n\ncc: Mr. Jeff Wiese\nAssociate Administrator for Pipeline Safety\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nOffice of Pipeline Safety (PHP-1)\nEast Building, E22-326\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nPipestream Inc. 6955 High Life Drive; Houston, TX. 77066 www.pipestream.com","truncated":false,"body_characters":10154}