Crosstex — Pipeline Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Chuck Lionberger Pipeline Integrity Specialist Crosstex 8090 Highway 3 128 Pineville. LA 71360 Dear Mr. Lionberger: In two separate letters to the Pipeline and llazardous Materials afety Admini stration (PI IMSA) dated January I I. 20 I 3. you req ue ·ted interpretations of the appl icability of two of the Federal pipeline safety regulations at 49 CfR Part 192. pecificall y. you requested clarification of: ( I) the requirement in § 192. 109 to verify the nominal v:all thickness lo r steel pipe: and (2) the requirement in ~ I 92.507 for pipe pressure testing. With respect to § I 92. I 09. you stated that the second sentence in § I 92. I 09(b) appears to contradict the first sentence. You ask. if when conducti ng digs on old lines to erify pipe data for maximum allowable operating pressure. you must veri fy all lengths or just I 0 percent but not less than I 0 lengths? To explain the requirements of§ I 92. I 09. the entire section is reprinted below: § 192.109 Nominal wall thickness (t) for steel pipe. (a) If the nominal wall thickne s lor steel pipe is not known. it is determined by measuring the thickness of each piece of pipe at quarter points on one end. (b) However, if the pipe i of uniform grade. ize. and thickness and there are more than I 0 lengths. only I 0 percent or the indi\·idual length . . but not less than I 0 lengths, need be measured. The thickness of the lengths that are not measured must be verified by applying a gauge set to the minimum thickness found by the measurement. The nominal wall thicknes to be used in the design formula in § 1 92.1 05 is the next wall thickness found in commercial specifications that is below the average of all the measurements taken. However. the nominal wall thickness used may not be more than 1.14 times the smal lest measurement taken on pipe less than 20 inches (508 millimeters) in outside diameter. nor more than 1.11 time the smallest measurement taken on pipe 20 inches (508 millimeters) or more in outside diameter. The Pipeline and Hazardous Materials Sa fet) Administration. O ffice of Pipeline afet) provide written clarification ofthe Regulation (-19 CFR Part 1 90-1 99) in the fo rm of int..:rpretation letter . These letters rencct the agenc~· current application of the regulation!> to the pccific tact pre. cntcd b~ the per on rcque ting the clarification. Interpretation do not create le ga ll~ -enfo rceable right or obligation and are provided to help the public under tand how to comply with the regulation .#

Page 22 Section 192. 1 09 is under Subpart C of Part 192 whi ch prescribes the minimum requi rements for the design of pipe. Therefore, these measurements are generally done and recorded prior to the pipe being installed and buried. Your question involves a scenario where the pipe is of unifo rm grade, size and thickness and there are more than I 0 lengths. While it is true that onl y I 0 percent ofthe individual lengths, but not less than 10 lengths. need be measured. the thickness of all unmeasured pipes must be verified if yo u elect to incorporate the thickness of these lengths in determining the nominal wall thickness to be used in your design formula. With respect to § 192.507. you asked whether a fl owing gas test with the maximum test pressure below 20 percent of the pipeline·s specified minimum yield strength and the pressure maintained at the designated test pressure could be performed wi thout isolating the section of pipeline being tested. You also ask if this testing method is allowed for either a pressure test or high consequence area (HCA) integrity test. Section 192.507 is reprinted below: § 192.507 Test requirements for pipelines to operate at a hoop stress less than 30 percent of SMYS and at or above 100 psi (689 kPa) gage. Except for service lines and plastic pipel ines. each segment of a pipeline that is to be operated at a hoop stress less than 30 percent of SMYS and at or above I 00 psi (689 kPa) gage must be tested in accordance with the following: (a) The pipeline operator must use a test procedure that wi ll ensure discovery of all potentially hazardous leaks in the egment being tested. (b) If. during the test. the segment is to be stressed to 20 percent or more of SMYS and natural gas, inert gas. or air is the test medium- ( I) A leak test must be made at a pressure between I 00 psi (689 kPa) gage and the pressure required to produce a hoop stress of 20 percent of SM YS; or (2) The line must be walked to check for leaks while the hoop stress is held at approximately 20 percent of SMYS. (c) The pressure must be maintained at or above the test pressure for at least I hour. Subpart J prescribes minimum leak-test and strength-test requirements f or pipelines. and the provisions of§ 192.507 are applicable to tests on new. replaced or relocated pipe. The pipe you would li ke to test is already in service. Yo u would like to perform a fl owi ng gas pressure test without isolating a segment of the pipeline. Without isolating a segment of the pipeline. any increase in pressure would affect the pipeline downstream from the test location. Therefore. we do not believe that the test procedure you described \vould achieve the requirement to maintain constant test pressure in the segment being tested for a peri od of time to ensure discovery of all The Pipeline and Hazardous Materials Safety Adm in istration. Office of Pipeline Safety provides written clarifications of the Regulations ( 49 CFR Parts 190- 199) in the form of interpretation letters. These let1ers reflect the agency's current app lication of the regulat ions to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obl igations and are provided to help the public understand how to comply with the regulations.#

Page 33 potentially hazardous leaks. You also asked if this testing method is allowed for either a pressure test or HCA integrity test. Again. we do not believe the test procedure you described would satisfy the requirement without isolating the segment of pipeline being tested. I hope that this information is helpful to you. If we can be of fu rther assistance. please contact Tewabe Asebe of my staff at (202) 366-5523. Sincerely. Director. Office of Standards and Rulemaking The Pipeline and Hazardous Materials Safety Admin istration, Office of Pipeline Safety provides wrillen clarifications ofthe Regu lations (49 CFR Parts 190- 199) in the form of interpretation leners. These letters renee! the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. lmerpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regu lations.#

Page 4• • CROSSTEX Jeff Wiese,, Associate Administrator US DOT/PHMSA/OPS PHP-1 1200 New Jersey Avenue, SE East Bldg, 2nd Floor Washington, DC 20590 .-t-'.· t.•·. Mr. Wtese, I wouid like to get an interpretation of 192.109 (b). The second sentence in this section reads "The thickness of the :engths that are not measured must be verified by applying a gauge set to thE minimum thickness found by the measurement." The previous statement in this section indic;ates that under certain conditions not all lengths of pipe need be measured to determine wall thickness. The quoted statement above seems to contradict that statement saying "the lengths not measure must be verified. When conducting digs on old lines to verify pipe data for MAOP purposes do we have to verify all lengths or just "10 percent but not less than 10 lengths"? Sincerely, chq::~Lz!J Pipeline Integrity Specialist charles.lionberger@crosstexenergy.com 318-619-5681 Office 318-447-3568 mobile 318-619-5719 fax 8090 Hwy. 3128 • Pineville, LA 71360 Phone 318.445.8225 • Fax 318.619.5719 • www.crosstexenergy.com NASDAQ NMS - XTEX & XTXI#

Page 5CROSSTEX January 11, 2013 Jeff Wiese Associate Administrator US DOT/PHMSA/OPS PHP-1 1200 New Jersey Avenue; SE East Bldg, 2nd Floor Washington, DC 20590 ~~N 18 2013 Mr. Wiese, I would ilke to get an interpretation of 192.507 (a) & (c). These two sections appear to allow a flowing gas test (test section is not isolated and gas continues to flow to customer during test) as long as the maximum test pressure is not at or above 20% SMYS and the pressure does not drop below the designated test pressure. It also appears to allow leak detection to determine if there is a leak during the test. Is it possible under 192.507 to perform a pressure test while not isolating a section of pipeline, and increasing the pressure using gas while checking for leaks using leak detection equipment (i.e. flame ionization pack)? The pressure increase would be under 20% and would not exceed MAOP. Is this allowed for either a Pressure test, or HCA integrity test? Sincerely, Chuck Lionberger Pipeline Integrity Specialist charles.lionberger@crosstexenergy.com 318-619-5681 Office 318-447-3568 mobile 318-619-5719 fax 8090 Hwy. 3128 II Pineville, LA 71360 Phone 318.445.8225 • Fax 318.619.5719 II www.crosstexenergy.com NASDAQ NMS - XTEX & XTXI#