{"operation":"document","citation":"PI-13-0001","title":"Crosstex — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2014-06-10","effective_on":null,"summary":"PI-13-0001 response to Crosstex concerning 192.109, 192.507.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-13-0001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-13-0001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-13-0001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2013/Crosstex-PI-13-0001-06-12-2013-Part192.109_and_507.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\nMr. Chuck Lionberger\nPipeline Integrity Specialist\nCrosstex\n8090 Highway 3 128\nPineville. LA 71360\nDear Mr. Lionberger:\nIn two separate letters to the Pipeline and llazardous Materials afety Admini stration (PI IMSA)\ndated January I I. 20 I 3. you req ue ·ted interpretations of the appl icability of two of the Federal\npipeline safety regulations at 49 CfR Part 192. pecificall y. you requested clarification of:\n( I) the requirement in § 192. 109 to verify the nominal v:all thickness lo r steel pipe: and (2) the\nrequirement in ~ I 92.507 for pipe pressure testing.\nWith respect to § I 92. I 09. you stated that the second sentence in § I 92. I 09(b) appears to\ncontradict the first sentence. You ask. if when conducti ng digs on old lines to erify pipe data\nfor maximum allowable operating pressure. you must veri fy all lengths or just I 0 percent but not\nless than I 0 lengths?\nTo explain the requirements of§ I 92. I 09. the entire section is reprinted below:\n§ 192.109 Nominal wall thickness (t) for steel pipe.\n(a) If the nominal wall thickne s lor steel pipe is not known. it is determined by\nmeasuring the thickness of each piece of pipe at quarter points on one end.\n(b) However, if the pipe i of uniform grade. ize. and thickness and there are\nmore than I 0 lengths. only I 0 percent or the indi\\·idual length . . but not less than\nI 0 lengths, need be measured. The thickness of the lengths that are not measured\nmust be verified by applying a gauge set to the minimum thickness found by the\nmeasurement. The nominal wall thicknes to be used in the design formula in\n§ 1 92.1 05 is the next wall thickness found in commercial specifications that is\nbelow the average of all the measurements taken. However. the nominal wall\nthickness used may not be more than 1.14 times the smal lest measurement taken\non pipe less than 20 inches (508 millimeters) in outside diameter. nor more than\n1.11 time the smallest measurement taken on pipe 20 inches (508 millimeters) or\nmore in outside diameter.\nThe Pipeline and Hazardous Materials Sa fet) Administration. O ffice of Pipeline afet) provide written\nclarification ofthe Regulation (-19 CFR Part 1 90-1 99) in the fo rm of int..:rpretation letter . These letters rencct\nthe agenc~· current application of the regulation!> to the pccific tact pre. cntcd b~ the per on rcque ting the\nclarification. Interpretation do not create le ga ll~\n-enfo rceable right or obligation and are provided to help the\npublic under tand how to comply with the regulation .\n\n<<<PAGE 2>>>\n\n2\nSection 192. 1 09 is under Subpart C of Part 192 whi ch prescribes the minimum requi rements for\nthe design of pipe. Therefore, these measurements are generally done and recorded prior to the\npipe being installed and buried. Your question involves a scenario where the pipe is of unifo rm\ngrade, size and thickness and there are more than I 0 lengths. While it is true that onl y I 0 percent\nofthe individual lengths, but not less than 10 lengths. need be measured. the thickness of all\nunmeasured pipes must be verified if yo u elect to incorporate the thickness of these lengths in\ndetermining the nominal wall thickness to be used in your design formula.\nWith respect to § 192.507. you asked whether a fl owing gas test with the maximum test pressure\nbelow 20 percent of the pipeline·s specified minimum yield strength and the pressure maintained\nat the designated test pressure could be performed wi thout isolating the section of pipeline being\ntested. You also ask if this testing method is allowed for either a pressure test or high\nconsequence area (HCA) integrity test.\nSection 192.507 is reprinted below:\n§ 192.507 Test requirements for pipelines to operate at a hoop stress less than\n30 percent of SMYS and at or above 100 psi (689 kPa) gage.\nExcept for service lines and plastic pipel ines. each segment of a pipeline that is to\nbe operated at a hoop stress less than 30 percent of SMYS and at or above I 00 psi\n(689 kPa) gage must be tested in accordance with the following:\n(a) The pipeline operator must use a test procedure that wi ll ensure discovery of\nall potentially hazardous leaks in the egment being tested.\n(b) If. during the test. the segment is to be stressed to 20 percent or more of\nSMYS and natural gas, inert gas. or air is the test medium-\n( I) A leak test must be made at a pressure between I 00 psi (689 kPa) gage and the\npressure required to produce a hoop stress of 20 percent of SM YS; or\n(2) The line must be walked to check for leaks while the hoop stress is held at\napproximately 20 percent of SMYS.\n(c) The pressure must be maintained at or above the test pressure for at least\nI hour.\nSubpart J prescribes minimum leak-test and strength-test requirements f or pipelines. and the\nprovisions of§ 192.507 are applicable to tests on new. replaced or relocated pipe. The pipe you\nwould li ke to test is already in service. Yo u would like to perform a fl owi ng gas pressure test\nwithout isolating a segment of the pipeline. Without isolating a segment of the pipeline. any\nincrease in pressure would affect the pipeline downstream from the test location. Therefore. we\ndo not believe that the test procedure you described \\vould achieve the requirement to maintain\nconstant test pressure in the segment being tested for a peri od of time to ensure discovery of all\nThe Pipeline and Hazardous Materials Safety Adm in istration. Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190- 199) in the form of interpretation letters. These let1ers reflect\nthe agency's current app lication of the regulat ions to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obl igations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\npotentially hazardous leaks. You also asked if this testing method is allowed for either a\npressure test or HCA integrity test. Again. we do not believe the test procedure you described\nwould satisfy the requirement without isolating the segment of pipeline being tested.\nI hope that this information is helpful to you. If we can be of fu rther assistance. please contact\nTewabe Asebe of my staff at (202) 366-5523.\nSincerely.\nDirector. Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Admin istration, Office of Pipeline Safety provides wrillen\nclarifications ofthe Regu lations (49 CFR Parts 190- 199) in the form of interpretation leners. These letters renee!\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. lmerpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regu lations.\n\n<<<PAGE 4>>>\n\n• • CROSSTEX\nJeff Wiese,,\nAssociate Administrator\nUS DOT/PHMSA/OPS\nPHP-1\n1200 New Jersey Avenue, SE\nEast Bldg, 2nd Floor\nWashington, DC 20590\n.-t-'.· t.•·.\nMr. Wtese,\nI wouid like to get an interpretation of 192.109 (b). The second sentence in this section reads\n\"The thickness of the :engths that are not measured must be verified by applying a gauge set to\nthE minimum thickness found by the measurement.\" The previous statement in this section\nindic;ates that under certain conditions not all lengths of pipe need be measured to determine\nwall thickness. The quoted statement above seems to contradict that statement saying \"the\nlengths not measure must be verified.\nWhen conducting digs on old lines to verify pipe data for MAOP purposes do we have to verify\nall lengths or just \"10 percent but not less than 10 lengths\"?\nSincerely,\nchq::~Lz!J\nPipeline Integrity Specialist\ncharles.lionberger@crosstexenergy.com\n318-619-5681 Office\n318-447-3568 mobile\n318-619-5719 fax\n8090 Hwy. 3128 • Pineville, LA 71360\nPhone 318.445.8225 • Fax 318.619.5719 • www.crosstexenergy.com\nNASDAQ NMS - XTEX & XTXI\n\n<<<PAGE 5>>>\n\nCROSSTEX\nJanuary 11, 2013\nJeff Wiese\nAssociate Administrator\nUS DOT/PHMSA/OPS\nPHP-1\n1200 New Jersey Avenue; SE\nEast Bldg, 2nd Floor\nWashington, DC 20590\n~~N 18 2013\nMr. Wiese,\nI would ilke to get an interpretation of 192.507 (a) & (c). These two sections appear to allow a\nflowing gas test (test section is not isolated and gas continues to flow to customer during test)\nas long as the maximum test pressure is not at or above 20% SMYS and the pressure does not\ndrop below the designated test pressure. It also appears to allow leak detection to determine if\nthere is a leak during the test.\nIs it possible under 192.507 to perform a pressure test while not isolating a section of pipeline,\nand increasing the pressure using gas while checking for leaks using leak detection equipment\n(i.e. flame ionization pack)? The pressure increase would be under 20% and would not exceed\nMAOP.\nIs this allowed for either a Pressure test, or HCA integrity test?\nSincerely,\nChuck Lionberger\nPipeline Integrity Specialist\ncharles.lionberger@crosstexenergy.com\n318-619-5681 Office\n318-447-3568 mobile\n318-619-5719 fax\n8090 Hwy. 3128 II Pineville, LA 71360\nPhone 318.445.8225 • Fax 318.619.5719 II www.crosstexenergy.com\nNASDAQ NMS - XTEX & XTXI","truncated":false,"body_characters":9342}