{"operation":"document","citation":"PI-14-0005","title":"California Public Utilities Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-01-23","effective_on":null,"summary":"PI-14-0005 response to California Public Utilities Commission concerning 192.517, 192.603, 192.619, 192.621.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-14-0005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-14-0005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-14-0005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2015/California_Public_Utilities_Commission_PI_14_0005_01_16_2014_Part_192.619.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n·1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\n'JAN 2 3 2015\nMr. Joseph P. Como\nActing Director, Office of Ratepayer Advocates\nCalifornia Public Utilities Commission\n505 Van Ness Avenue\nSan Francisco, CA 94102\nDear Mr. Como:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nDecember 4, 2013, the Office of Ratepayer Advocates (ORA) requested a regulatory\ninterpretation of 49 CFR 192.619 regarding the maximum allowable operating pressure (MAOP)\nfor natural gas pipelines. Specifically, ORA asked if the consideration of design pressure in\n§ 192.619(a)(1) is required for pipelines that were placed in service before July 1, 1970. ORA\nasked whether an operator must use the design pressure in§ 192.619(a)(1) as the MAOP for a\nsegment of pipeline that was placed in service before July 1, 1970, if the design pressure is the\nlowest pressure from the methods set forth in§ 192.619(a). In addition, ORA informed PHMSA\nthat the California Public Utilities Commission (CPUC) no longer permits gas operators within\nits jurisdiction to rely on the \"Grandfather Clause\" in§ 192.619(c).\nORA attached PHMSA's letter objecting to the Oklahoma Corporation Commission's (OCC)\nWaiver of Compliance, PHP-08-0074, dated March 17, 2008, and stated that it believes that letter\nto mean that an operator must calculate and consider the design pressure to determine the MAOP\nof pipelines installed prior to July 1, 1970, as well as after that date. ORA asked if its\nunderstanding is correct. ORA stated that the letter's discussion was about distribution lines and\nasked PHMSA to confirm that a MAOP calculated under§ 192.619(a) cannot exceed design\npressure for transmission pipelines installed prior to July 1, 1970.\nORA informed PHMSA that in a recent hearing held by the CPUC, Pacific Gas & Electric\nCompany (PG&E) asserted that it is not required to consider design pressure for a pipeline\nplaced in service before July 1, 1970, that has been subject to a Subpart J strength test. ORA\nstated that PG&E's reasoning was that\"§ 192.619(a)(l) is forward-looking and applies only to\nsegments of new pipeline installed after 1970, the year the Federal regulations became effective.\"\nORA's letter stated that PG&E believes that the regulations aVow it to operate a pipeline placed\nin service prior to July 1, 1970, at a MAOP based on its strength test pressure under\n§ 192.619(a)(2) even if the design pressure is lower.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts pre~ented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nORA stated that it disagrees with PG&E's interpretation because:\n1. 2. 3. Section 192.619(a) does not state the design pressure is inapplicable to pipelines installed\nbefore July 1, 1970;\nThe MAOP requirements under§ 192.619 are part of Subpart L, which govern safe\noperating conditions, and the requirement in§ 192.619(a) appears to be a mandatory\nsafety precaution; and\nORA believes the above mentioned PHMSA letter to the OCC confirms that the design\npressure provision applies to lines placed in operation prior to July 1, 1970.\nORA asks the following questions, and PHMSA's answers are below:\nQuestion 1: When validating the MAOP of pipeline segments placed in operation before\nJuly 1, 1970, and still in operation today, is the operator required to calculate and\nconsider the design pressure pursuant to§ 192.619(a)(1)?\nResponse: Section 192.619(a) states: \"No person may operate a segment of steel or plastic\npipeline at a pressure that exceeds a MAOP determined under paragraph (c) or (d) of this section,\nor the lowest of the following: .... \" Paragraphs (a)(1)- (a)(4) then specify four pressures which\nmust be calculated in order to determine the MAOP. Therefore, the answer is yes.\nThe operator of a pipeline that was placed into service before July 1, 1970, must determine\nMAOP in accordance with§ 192.619. If§ 192.619(a) is used to determine MAOP, the operator\nmust calculate the design pressure in accordance with§ 192.619(a)(l), and use the design\npressure or a lower pressure as the MAOP if that is the lowest of the four pressures described in\nparagraphs (a)(l)- (a)(4). If applicable, an operator may also use the \"Grandfather Clause\" in\n§ 192.619(c) to determine the pipeline segment's MAOP.\nOver time, changes in the population density surrounding a pipeline segment will affect the class\nlocation and MAOP of a pipeline. Section 192.613 requires operators to have a procedure for\ncontinuing surveillance of its facilities to determine and take appropriate action concerning\nchanges in class location. When there are changes to population density along a pipeline\nsegment, § 192.609 requires the operator to conduct a class location study, and\n§ 192.611 details the requirements for confirming or revising the MAOP according to the new\nclass location.\nParagraph (d) of§ 192.611 requires the operator to confirm or revise the MAOP within 24\nmonths of the change in class location. If an operator fails to confirm or revise the MAOP\nwithin 24 months of the change in class location, then§ 192.611 cannot be used and the pipeline\nsegment MAOP must be calculated in accordance with§ 192.619(a), using the design factor that\nappears in§ 192.111 for the new class location.\nThe CPUC may impose more stringent MAOP regulations by establishing them through state\nlaw. PHMSA does not interpret state regulations.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications ofthe Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\nQuestion 2: If the answer to Question 1 is yes, must the operator use its design pressure\nas the MAOP when the design pressure is the lowest pressure calculation required by\n§ 192.619(a)?\nResponse: Yes, if the Grandfather Clause in§ 192.619(c) or the alternative MAOP option in\n§ 192.619(d) is not applicable. If the operator uses§ 192.619(a) to determine MAOP, the\nMAOP would be equal to the lowest value calculated according to paragraphs (a)(l)- (a)(4).\nFor a pre-July 1, 1970 pipeline segment, the operator must determine the MAOP in accordance\nwith§ 192.619(a) unless the operator has documentation that meets the§ 192.619(c)\nrequirements for the entire pipeline segment and elects to use it to establish MAOP.\nIf an operator uses§ 192.619(a) to determine the pipeline segment MAOP, the operator must\nhave records to substantiate the calculations required in paragraphs (a)(1)- (a)(4), including the\nproperties of pipe and pipeline components. Paragraph (a)(l) requires that the pipeline design\npressure be determined in accordance with Subparts C and D, including§ 192.105 which states\nthat the pipeline design pressure must be based upon the current class location design factor and\nthe actual pipe properties which include yield strength (grade), wall thickness, longitudinal joint\nfactor (seam type), maximum operating temperature and pipe' diameter. If the pipeline segment\ncontains pipeline components such as bends, fittings, flanges or valves, the operator would need\nto determine the design pressure of these pipeline components in accordance with applicable\nsections of Subparts C and D of Part 192.\nIf an operator uses the Grandfather Clause in§ 192.619(c) to establish the MAOP, the operator\nmust have documentation of the pipeline segment's condition and operating and maintenance\nhistory, including historical pressure records for the maximum operating pressure to which the\nentire pipeline segment was subjected during the five years prior to July 1, 1970. The\nGrandfather Clause in§ 192.619(c) cannot be used to determine the MAOP after a change in\nclass location. Section 192.611 can be used to revise the MAOP within 24 months after a class\nlocation change; after that deadline, the MAOP must be revised according to§ 192.619(a).\nSections 192.517 and 192.603 require that all records regarding the pipeline MAOP\ndetermination be kept for the life of the pipeline segment, including records of pipe properties,\npipeline component properties, pressure test records, class loqation studies, current class location\ndesignation, and operating history.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\n4\nQuestion 3: Does § 192.619 apply to both transmission lines and distribution lines?\nResponse: Yes. The requirements in § 192.619 apply to both distribution and transmission\nnatural gas pipelines. Section 192.621 contains different standards that apply only to high\npressure distribution systems. States that regulate intrastate natural gas transmission pipelines\nand natural gas distribution pipelines have the right to implement state pipeline regulations that\nexceed the requirements in Part 192.\nIf we can be of further assistance, please contact John Gale, of my staff at 202-366-0434.\nrey D. Wiese\nAssociate Administrator for\nPipeline Safety\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 5>>>\n\nt .. • •• • • •\n_,,_ . .\nORA\nOffice of Ratepayer Advocates\nCalifornia Public Utilities Commission\nJOSEPH P. COMO\nA«:ling Director\n505 Van Ness Avenue\nSan Francisco, California 94102\nTel: 415-703-2381\nFax:415-703-2057\nhttp://ora.ca.gov\nDEC 1 1 2013\nVIA US MAIL\nJohn Gale\nDirector, Standards and Rulemaking\nU.S. Department ofTransportation\nPipeline and Hazardous\nMaterials Safety Administration\nEast Building, Second Floor\n1200 New Jersey Avenue SE\nWashington, D.C. 20590\nDear Mr. Gale,\nThe Office of Ratepayer Advocates (ORA) at the California Public Utilities Commission is\nwriting to the Pipeline and Hazardous Materials Safety Administration (PHMSA) to request an\ninterpretation of the regulation on determining maximum allowable operating pressure (MAOP)\nfor natural gas pipelines, 49 C.F.R. § 192.619. Specifically, do the design MAOP requirements\nof 49 C.F.R. § 192.6 i 9(a)(l) apply to pipelines in service today that were placed in service\nbefore July 1, 1970?1 If a segment of pipeline was placed in service before July I, 1970, and the\ndesign MAOP is the lowest MAOP from the allowable methods of calculating MAOP set forth in\n§ 192.6 19(a), must the operator operate that line under the design MAOP? (Please note that the\nCalifornia Public Utilities Commission (CPUC) no longer permits gas operators within its\njurisdiction to rely on§ 192.619(c), the \"grandfather clause,\" to validate MAOP.\n2)\nIn PHMSA's Waiver of Compliance Order PHP 08-0074, dated March 17, 2008, PHMSA\nprovided an interpretation of 192.619(a)'s MAOP requirements. Under that interpretation,\nPHMSA acknowledged that:\n1 As PHMSA may be aware, in the aftermath of the San Bruno, California pipeline explosion disaster, the California\nPublic Utilities Commission (CPUC) ordered its regulated gas utilities to begin extensive evaluations of records and\nhydrotesting to verify the safety of natural gas pipelines. In particular, gas operators were ordered to validate the\nMAOP of their transmission lines without relying on § 192.6 19(c) (the \"grandfather clause\"). See Calif ornia Public\nUtilities Commission Decision 11 -06-0 17, pp. 18, 31 (June 9, 20 I I), available at\nhttp://docs.cpuc.ca.gov!PublishedDocs/WORD PDF/FINAL DECISION/ 137309.PDF.\n2 See California Public Utilities Commission Decision 11 -06-017, pp. 18, 3 1 (June 9, 20 I I), available at\nhttp://docs.cpuc.ca.gov/PublishedDocsfWORD\nPDF/FTNAL\nDECISION/ 137309.PDF.\n_\n_\nRatepayer Advocates in the Gas, Electric, Telecommunications and Water Industries\n\n<<<PAGE 6>>>\n\nThe Federal pipeline safety regulations in § 192.619(a) limit the MAOP of a\npipeline installed prior to July 1, 1970, to the lowest of the following four\npressures:\n- The design pressure of the weakest dement in the segment per\n§ 192.619(a)(l );\n- The pressure obtained by dividing the pressure to which the segment\nwas tested after construction by the applicable factor per § 192.619(a)(2);\n- The highest actual operating pressure the segment was subjected to\nduring the 5 years preceding July 1, 1970 per § 192.619(a)(3); or\n- The pressure determined by the operator to be the maximum safe\npressure after considering the history of the segment per § 192.619(a)( 4).\nA pipeline operator would need data to support all four pressures listed above to\nestablish the MAOP of a pipeline segment using§ 192.619(a).3\nORA understands this interpretation to mean that an operator must calculate and consider the\ndesign MAOP to determine the MAOP of pipelines installed prior to July 1, 1970 (as well as\nafter that date). Could PHMSA verify that ORA's understanding is correct?\nPHMSA's Waiver of Compliance Order PHP 08-0074, cited above, specifically addresses\ndistribution lines. If the answer to the previous question is yes, does the same requirement to\ncalculate design MAOP for pipelines installed prior to July 1, 1970 also apply to transmission\nlines? ORA's understanding is that the Subpart L requirements regarding how to determine\nMAOP apply both to distribution and transmission lines. Section 192.601 refers to \"the\nminimum requirements for the operation of pipeline facilities\" and § 192.603(a) requires that\n\"[n]o person may operate a segment of pipeline unless in accordance with this subpart\" without\nmaking a distinction between transmission lines or distribution lines.\nIn a recent hearing held by the CPUC, Pacific Gas & Electric Company (PG&E) asserted that it\nis not required to consider design MAOP for a pipeline placed in service before July 1, 1970 that\nhas been subject to a Subpart J strength test. PG&E states that§ 192.619(a)(1) is forward-\nlooking and applies only to segments of new pipeline installed after 1970, the year the federal\nregulations became effective. In PG&E's opinion, the regulations allow it to operate a line\nplaced in use prior to July 1, 1970 based on its strength test pressure MAOP, under\n§ 192.619(a)(2), even when the design MAOP is lower.\n3 PHP 08-0074, p. I (March 17, 2008) (emphasis added).\n2\n\n<<<PAGE 7>>>\n\nORA interprets the regulations differently. ORA's understanding is that when an operator is\ndirected to validate the MAOP of a line operating today, regardless of when it was installed, it\nmust use the MAOP determined by § 192.619(a); that is, the lowest value of pressure calculated\nusing§ 192.619(a)(l), (2), (3) or (4). Thus, ifthe design MAOP is lower than test MAOP, the\ndesign MAOP must be used unless one of the other methods permitted ~nder § 192.619(a) yields\na result that is lower. ORA wishes to verify that its understanding is correct.\nORA has taken this position for a number of reasons. First, Section 192.619(a) does not state that\nthe design MAOP method is inapplicable to pipelines installed before July 1, 1970. Second, the\nMAOP requirements under § 192.619 are part of Subpart L, which governs safe operating\nconditions. The \"operator must use the lower of ..... \"provision of§ 192.619(a) appears to be a\nmandatory safety precaution. Third, PHP 08-0074, referenced above, confirms that the design\nMAOP provision applies to lines placed in operation prior to July I, 1970.\nIn sum, the Office of Ratepayer Advocates asks for the following interpretations:\n1. When validating the MAOP of pipeline segments placed in operation before July 1, 1970\nthat are still operating today, is the operator required to calculate and consider the design\nMAOP pursuant to§ 192.619(a)(l)?\n2. If the answer to Question I is yes, must the operator use its design MAOP when the\ndesign MAOP is the lowest MAOP calculation required by§ 192.6 19(a)?\n3. Does§ 192.619 apply both to transmission lines as well as distribution lines?\nSincerely,\nJoseph P. Como\nActing Director\nOffice of Ratepayer Advocates\nCalifornia Public Utilities Commission\nEnclosure\n3\n\n<<<PAGE 8>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue. SE\nWashington, D.C. 20590\nMAR 1 7 2008\nMr. Dennis Fothergill\nRegulatory Program Manager\nPipeline Safety Department\nTransportation Division\nOklahoma Corporation Commission\nP.O. Box 52000\nOklahoma City, OK 73152-2000\nDear Mr. Fothergill:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA) reviewed your letter of\nJanuary 23, 2008, notifying us that the Oklahoma Corporation Commission (Commission)\ngranted CenterPoint Energy Resources Corp doing business as CenterPoint Energy Oklahoma\nGas (CenterPoint) a waiver of compliance from state regulation 49 CFR 192.619(a)(3) [as\nadopted by the Commission in OAC 165: 20-5-21] for 138 low-pressure distribution system\npipeline segments in Oklahoma. The regulations in § 192.619(a)(3) limit the maximum\nallowable operating pressure (MAOP) of a steel or plastic pipeline segment installed prior to\nJuly 1,1970, to the highest actual operating pressure the segment was subjected to during the 5\nyears preceding July 1, 1970.\nThe Federal pipeline safety regulations in§ 192.619(a) limit the MAOP of a pipeline installed\nprior to July 1, 1970, to the lowest of the following four pressures:\n- The design pressure ofthe weakest element in the segment per§ 192.619(a)(l);\n- The pressure obtained by dividing the pressure to which the segment was tested after\nconstruction by the applicable factor per§ 192.619(a)(2);\n- The highest actual operating pressure the segment was subjected to during the 5 years\nprecedingJuly 1, 1970per§ 192.619(a)(3);or\n- The pressure determined by the operator to be the maximum safe pressure after considering\nthe history ofthe segment per§ 192.619(a)(4).\nA pipeline operator would need data to support all four pressures listed above to establish the\nMAOP of a pipeline segment using§ 192.619(a).\nWhen these rules were first promulgated in 1970, PHMSA recognized that an operator may not\nhave all the pressure data needed for existing pipelines. Therefore, we included in the rules a\n\"grandfather clause\" to allow pipeline operators to establish the MAOP of an existing pipeline\nsegment in satisfactory condition, and considering its operating and maintenance history, at the\nhighest actual operating pressure to which the segment was subjected during the 5 years prior to\nJuly 1, 1970. This \"grandfather clause\" is codified in§ 192.619(c), not§ 192.619(a)(3).\n\n<<<PAGE 9>>>\n\n2\nThe operator at the time the regulations were promulgated in 1970 should have established the\nMAOP for each of these 138 low-pressure segments by using either § 192.619(a) or\n§ 192.619(c). Moreover, there are additional MAOP restrictions for low-pressure distribution\nsystems in§ 192.623. Subsequently, the MAOP of these segments can only be increased in\naccordance with 49 CFR Part 192, Subpart K- Uprating, not§ 192.619(a) or§ 192.619(c), and\nwith consideration of§ 192.623. Accordingly, if CenterPoint wishes to increase the existing\nMAOPs, they should seek relief from the uprating regulations and the low-pressure distribution\nsystem regulations, if required, not from§ 192.619(a)(3).\nUnfortunately, no data was submitted with the waiver grant to PHMSA regarding the existing\nMAOPs of these 138 segments. Nor is it clear why CenterPoint is seeking MAOP relief, if as\nyou state in your letter, \"CenterPoint requested the MAOP for these 138 low pressure gas\ndistribution pipeline segments be established at 1.00 psig, which is the current and historical\nmaximum operating pressure for these segments. \" If these segments have been historically\noperated up to 1.00 psig, then the existing MAOPs must already be at least 1.00 psig or the\nsegments have been historically operated in violation of the pipeline safety regulations. If so,\nthis needs to be addressed before a waiver is granted.\nPHMSA is unable to fully evaluate this waiver grant without additional information. For\nexample, why is CenterPoint establishing MAOPs in 2008 for pipeline segments that have been\noperating for over 50 years? Are there any open enforcement actions regarding the historical\noperation of these segments up to 1.00 psig? How does CenterPoint propose to meet the\nrequirements in § 192.623, when it is known that many gas appliances are rated for 0.5 psig or\nless, not 1.00 psig?\nFor the reasons stated above, PHMSA objects to this waiver and the Commission's order is\nstayed. The Conunission may appeal this matter. However, because the waiver of\n§ 192.619(a)(3) is inappropriate, PHMSA suggests that CenterPoint resubmit its application to\nthe Commission and that the Commission grant a new waiver, if appropriate. The new waiver\ngrant must specifically identify the state pipeline safety regulation the Commission is waiving\nand must include new information from the petitioner to justify granting the waiver. This new\ninformation should include, at a minimum, technical evidence to substantiate that an MAOP of\n1.00 psig for these 138 low-pressure distribution pipeline segments would result in equivalent or\ngreater safety than an MAOP established using the methods currently allowed in the Federal\npipeline safety regulations in 49 CFR Part 192.\n-\nIf you wish to discuss this waiver or any other pipeline safety matter, my staff would be pleased\nto assist you. Please call Barbara Betsock, Acting Director ofRegulations at 202-366-4361 for\nregulatory matters or Alan Mayberry, Director of Engineering and Emergency Support at\n202-366-5124 for technical matters.\nSincerely,\nw d.~\n11 0-v.h\nbn-\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\n\n<<<PAGE 10>>>\n\n28780 Federal Register I Vol. 6I, No. 110 I Thursday. june 6, 1996 I Rules and Regulations\ncorrosion monitoring under § 192.465\nfor the life of the pipe. Most of these\ncommenters declared that 5 years would\nbe adequate, but did not explain why a\nlonger period is excessive. Lacking any\nconvincing documentation to the\ncontrary. RSPA believes the current rule\nshould stay in effect. In our experience.\na history of corrosion monitoring sheds\nlight on the possible causes of a\npipeline's condition. Such history has\nproven to be a valuable resource in\ndeciding the extent and kind of\nremedial action needed when corrosion\nproblems emerge on a pipeline.\nRegarding the proposed 5-year\nretention time for records other than\nthose required by§§ 192.465 (a) and (e)\nand 192.475(b), two commenters said\nthe minimum time should be 3 years to\ncoincide with the longest interval\nbetween inspections. Two others\nsuggested that instead of a set time. we\nadopt a performance standard for record\nretention, basing it on the time needed\nto observe trends. inquire into\ncompliance, or collect superseding data.\nAll these comments provide a\nreasonable basis for record retention.\nHowever, our main concern is that\noperators keep records for a period that\nis compatible with the occurrence of\nroutine compliance investigations.\nTherefore, for simplicity and\nuniformity, we have decided to adopt\nthe proposed 5-year minimum retention\ntime.\nThe state agency that commented\nobjected to the 5-year proposal on\ngrounds that it would sacrifice\ninformation about why external or\natmospheric corrosion control was not\ninstalled on pipelines under §§ 192.455.\n192.457. and 192.479. RSPA believes\nthe loss of this information after 5 years\nwould not be significant, because the\npipelines involved are covered by\nrequirements for periodic inspections or\ntests for corrosion under §§ 192.465 and\n192.481.\nSection 192.553. General Requirements\n(See previous discussion under\n§ 192.14).\nSection 192.607. Determination ofClass\nLocation and Maximum Allowable\nOperating Pressure\nBecause§ 192.607 has no continuing\neffect and the deadlines for compliance\nhave expired. RSPA proposed to remove\n§ 192.607 from part 192.\nFourteen TPSSC members voted for\nthe proposal and one member abstained.\nFive operators, one pipeline-related\nassociation. and one state agency\ncommented on the proposed removal of\n§ 192.607. Four operators and the\nassociation favored the idea. One\noperator and the state agency disagreed\nwith removal, believing the rule is\nneeded to tie a pipeline's maximum\nallowable operating pressure (MAOP) to\nits class location. Similarly, the NAPSR\nreport recommended that we only\nremove the past compliance deadlines\nfrom § 192.607, leaving the rest of the\nrule in place to regulate the relation of\nclass location to stress level on high-\nstress pipelines.\nSection 192.607 was a transitional\nrequirement. Its purpose was to\nestablish plans under which operators\ninitially determined class locat ions and\nconfirmed or revised the MAOPs of\ntheir high-stress pipelines\ncommensurate with their class\nlocations. Section 192.607 provides that\nthe plans had to be executed in\naccordance with § 192.6 11 . This latter\nsection together with § 192.609 are\nsufficient to require that operators have\nup-to-date class location determinations\nfor high-stress pipelines, and maintain\nthe MAOPs of those lines commensurate\nwith their class locations.\nAccordingly, § 192.607 is removed\nfrom part 192.\nSection 192.61 1. Change in Class\nLocation\nSection 192.611 requ ires confirmation\nor revision of a pipeline's MAOP within\n18 months after a change in class\nlocation. RSPA proposed to reorganize\n§ 192.6 1 I to clarify the requirement that\nthe MAOP resulting from confirmation\nor revision may not exceed the\npipeline's previous MAOP. This\nrequirement is currently set forth in\n§ 192.611 (a)(3)(ii), suggesting that it\napplies only to confirmations or\nrevisions under paragraph (a)(3). which\nis not the intent.\nFourteen TPSSC members voted for\nthe proposal and one member abstained.\nFive operators and one pipeline-\nrelated association commented on the\nproposal: each agreed with the proposal.\nSection 192.6 11 is, therefore, adopted as\nproposed in the NPRM.\nSection 192.614, Damage Prevention\nProgram\nTo decrease excavation damage to\npipelines,§ 192.6 14(b)(2) requires\noperators to notify excavators and the\npublic about the need to locate buried\npipelines before excavating. The NPRM\nproposed to amend the rule to clarify\nthat in contrast to the actual notification\nrequired for excavators. only general\nnotification is required for the public.\nGeneral notice can be given through\nnewspapers, radio, television. or other\nmeans of mass communication. as\nappropriate for the public in the vicinity\nof the pipeline.\nFourteen TPSSC members voted for\nthe proposal and one member abstained.\nSix pipeline operators and two\npipeline-related organizations\ncommented. Seven commenters gave\ntheir full or qualified approval and one\ncommenter opposed the proposal. The\nqualified and negative comments were\nthat the rule should inform operators of\nthe acceptable means of notification. We\ndo not feel it is necessary for the rule\nto do so. however. because the available\nmeans of giving general public notice\nare well known. The amendment to\nparagraph (b) (2) is adopted as proposed.\nSection 192.619. Maximum Allowable\nOperating Pressure: Steel or Plastic\nPipelines\nSection 192.619 (a) prescribes six\npressure limits for use in determining\nthe MAOP of steel and plastic pipelines,\nthe lowest of which establishes the\nMAOP. Paragraph (a)(4) limits the\nMAOP of furnace butt welded pipe to 60\npercent of the mill test pressure.\nParagraph (a)(5) limits the MAOP of\nother steel pipe to 85 percent of the\nhighest test pressure to which the pipe\nhas been subjected, whether by mill test\nor by the post installation test.\nRSPA proposed to repeal paragraphs\n(a)( 4) and (a)(5), primarily because mill\ntests are not an adequate MAOP\nconsideration. However, to assure\nconsideration of longitudinal joint\nefficiency. RSPA also proposed, in\nparagraph (a)(2)(iii). that the class\nlocation pressure limit under existing\nparagraph (a)(2)(ii) be reduced for\nfurnace butt welded pipe and lap\nwelded pipe.\nEleven TPSSC members voted for the\nproposal, one member supported it with\na recommended change, two members\nopposed it, and one abstained. A\nmember recommended that RSPA not\nadopt proposed paragraph (a)(2)(iii)\nbecause design pressure (under\nparagraph (a)( I)) adequately covers\nlongitudinal joint concerns.\nRSPA concurs with this view as\nexplained below in response to public\ncomment.\nThirteen operators, four pipeline-\nrelated associations, and one state\nagency commented on the proposed\namendment. Two operators. one\npipeline-related association, and one\nstate agency commented that proposed\nparagraph (a) (2) (iii) could require\noperators to reduce the operating\npressure of some pipelines or test them\nto higher pressures than they previously\nwere tested, possibly damaging the\npipelines. In addition. some\ncommenters stated that proposed\nparagraph (a)(2)(i ii) would duplicate use\nof longi tudinal joint factors.","truncated":false,"body_characters":30185}