# California Public Utilities Commission — Pipeline Safety Interpretation

- **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:** Not available
- **summary:** PI-14-0005 response to California Public Utilities Commission concerning 192.517, 192.603, 192.619, 192.621.
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- **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>>>

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
·1200 New Jersey Ave, S.E.
Washington, D.C. 20590
'JAN 2 3 2015
Mr. Joseph P. Como
Acting Director, Office of Ratepayer Advocates
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Dear Mr. Como:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated
December 4, 2013, the Office of Ratepayer Advocates (ORA) requested a regulatory
interpretation of 49 CFR 192.619 regarding the maximum allowable operating pressure (MAOP)
for natural gas pipelines. Specifically, ORA asked if the consideration of design pressure in
§ 192.619(a)(1) is required for pipelines that were placed in service before July 1, 1970. ORA
asked whether an operator must use the design pressure in§ 192.619(a)(1) as the MAOP for a
segment of pipeline that was placed in service before July 1, 1970, if the design pressure is the
lowest pressure from the methods set forth in§ 192.619(a). In addition, ORA informed PHMSA
that the California Public Utilities Commission (CPUC) no longer permits gas operators within
its jurisdiction to rely on the "Grandfather Clause" in§ 192.619(c).
ORA attached PHMSA's letter objecting to the Oklahoma Corporation Commission's (OCC)
Waiver of Compliance, PHP-08-0074, dated March 17, 2008, and stated that it believes that letter
to mean that an operator must calculate and consider the design pressure to determine the MAOP
of pipelines installed prior to July 1, 1970, as well as after that date. ORA asked if its
understanding is correct. ORA stated that the letter's discussion was about distribution lines and
asked PHMSA to confirm that a MAOP calculated under§ 192.619(a) cannot exceed design
pressure for transmission pipelines installed prior to July 1, 1970.
ORA informed PHMSA that in a recent hearing held by the CPUC, Pacific Gas & Electric
Company (PG&E) asserted that it is not required to consider design pressure for a pipeline
placed in service before July 1, 1970, that has been subject to a Subpart J strength test. ORA
stated that PG&E's reasoning was that"§ 192.619(a)(l) is forward-looking and applies only to
segments of new pipeline installed after 1970, the year the Federal regulations became effective."
ORA's letter stated that PG&E believes that the regulations aVow it to operate a pipeline placed
in service prior to July 1, 1970, at a MAOP based on its strength test pressure under
§ 192.619(a)(2) even if the design pressure is lower.
The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written
clarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect
the agency's current application of the regulations to the specific facts pre~ented by the person requesting the
clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the
public understand how to comply with the regulations.

<<<PAGE 2>>>

2
ORA stated that it disagrees with PG&E's interpretation because:
1. 2. 3. Section 192.619(a) does not state the design pressure is inapplicable to pipelines installed
before July 1, 1970;
The MAOP requirements under§ 192.619 are part of Subpart L, which govern safe
operating conditions, and the requirement in§ 192.619(a) appears to be a mandatory
safety precaution; and
ORA believes the above mentioned PHMSA letter to the OCC confirms that the design
pressure provision applies to lines placed in operation prior to July 1, 1970.
ORA asks the following questions, and PHMSA's answers are below:
Question 1: When validating the MAOP of pipeline segments placed in operation before
July 1, 1970, and still in operation today, is the operator required to calculate and
consider the design pressure pursuant to§ 192.619(a)(1)?
Response: Section 192.619(a) states: "No person may operate a segment of steel or plastic
pipeline at a pressure that exceeds a MAOP determined under paragraph (c) or (d) of this section,
or the lowest of the following: .... " Paragraphs (a)(1)- (a)(4) then specify four pressures which
must be calculated in order to determine the MAOP. Therefore, the answer is yes.
The operator of a pipeline that was placed into service before July 1, 1970, must determine
MAOP in accordance with§ 192.619. If§ 192.619(a) is used to determine MAOP, the operator
must calculate the design pressure in accordance with§ 192.619(a)(l), and use the design
pressure or a lower pressure as the MAOP if that is the lowest of the four pressures described in
paragraphs (a)(l)- (a)(4). If applicable, an operator may also use the "Grandfather Clause" in
§ 192.619(c) to determine the pipeline segment's MAOP.
Over time, changes in the population density surrounding a pipeline segment will affect the class
location and MAOP of a pipeline. Section 192.613 requires operators to have a procedure for
continuing surveillance of its facilities to determine and take appropriate action concerning
changes in class location. When there are changes to population density along a pipeline
segment, § 192.609 requires the operator to conduct a class location study, and
§ 192.611 details the requirements for confirming or revising the MAOP according to the new
class location.
Paragraph (d) of§ 192.611 requires the operator to confirm or revise the MAOP within 24
months of the change in class location. If an operator fails to confirm or revise the MAOP
within 24 months of the change in class location, then§ 192.611 cannot be used and the pipeline
segment MAOP must be calculated in accordance with§ 192.619(a), using the design factor that
appears in§ 192.111 for the new class location.
The CPUC may impose more stringent MAOP regulations by establishing them through state
law. PHMSA does not interpret state regulations.
The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written
clarifications ofthe Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect
the agency's current application of the regulations to the specific facts presented by the person requesting the
clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the
public understand how to comply with the regulations.

<<<PAGE 3>>>

3
Question 2: If the answer to Question 1 is yes, must the operator use its design pressure
as the MAOP when the design pressure is the lowest pressure calculation required by
§ 192.619(a)?
Response: Yes, if the Grandfather Clause in§ 192.619(c) or the alternative MAOP option in
§ 192.619(d) is not applicable. If the operator uses§ 192.619(a) to determine MAOP, the
MAOP would be equal to the lowest value calculated according to paragraphs (a)(l)- (a)(4).
For a pre-July 1, 1970 pipeline segment, the operator must determine the MAOP in accordance
with§ 192.619(a) unless the operator has documentation that meets the§ 192.619(c)
requirements for the entire pipeline segment and elects to use it to establish MAOP.
If an operator uses§ 192.619(a) to determine the pipeline segment MAOP, the operator must
have records to substantiate the calculations required in paragraphs (a)(1)- (a)(4), including the
properties of pipe and pipeline components. Paragraph (a)(l) requires that the pipeline design
pressure be determined in accordance with Subparts C and D, including§ 192.105 which states
that the pipeline design pressure must be based upon the current class location design factor and
the actual pipe properties which include yield strength (grade), wall thickness, longitudinal joint
factor (seam type), maximum operating temperature and pipe' diameter. If the pipeline segment
contains pipeline components such as bends, fittings, flanges or valves, the operator would need
to determine the design pressure of these pipeline components in accordance with applicable
sections of Subparts C and D of Part 192.
If an operator uses the Grandfather Clause in§ 192.619(c) to establish the MAOP, the operator
must have documentation of the pipeline segment's condition and operating and maintenance
history, including historical pressure records for the maximum operating pressure to which the
entire pipeline segment was subjected during the five years prior to July 1, 1970. The
Grandfather Clause in§ 192.619(c) cannot be used to determine the MAOP after a change in
class location. Section 192.611 can be used to revise the MAOP within 24 months after a class
location change; after that deadline, the MAOP must be revised according to§ 192.619(a).
Sections 192.517 and 192.603 require that all records regarding the pipeline MAOP
determination be kept for the life of the pipeline segment, including records of pipe properties,
pipeline component properties, pressure test records, class loqation studies, current class location
designation, and operating history.
The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written
clarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect
the agency's current application of the regulations to the specific facts presented by the person requesting the
clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the
public understand how to comply with the regulations.

<<<PAGE 4>>>

4
Question 3: Does § 192.619 apply to both transmission lines and distribution lines?
Response: Yes. The requirements in § 192.619 apply to both distribution and transmission
natural gas pipelines. Section 192.621 contains different standards that apply only to high
pressure distribution systems. States that regulate intrastate natural gas transmission pipelines
and natural gas distribution pipelines have the right to implement state pipeline regulations that
exceed the requirements in Part 192.
If we can be of further assistance, please contact John Gale, of my staff at 202-366-0434.
rey D. Wiese
Associate Administrator for
Pipeline Safety
The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written
clarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect
the agency's current application of the regulations to the specific facts presented by the person requesting the
clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the
public understand how to comply with the regulations.

<<<PAGE 5>>>

t .. • •• • • •
_,,_ . .
ORA
Office of Ratepayer Advocates
California Public Utilities Commission
JOSEPH P. COMO
A«:ling Director
505 Van Ness Avenue
San Francisco, California 94102
Tel: 415-703-2381
Fax:415-703-2057
http://ora.ca.gov
DEC 1 1 2013
VIA US MAIL
John Gale
Director, Standards and Rulemaking
U.S. Department ofTransportation
Pipeline and Hazardous
Materials Safety Administration
East Building, Second Floor
1200 New Jersey Avenue SE
Washington, D.C. 20590
Dear Mr. Gale,
The Office of Ratepayer Advocates (ORA) at the California Public Utilities Commission is
writing to the Pipeline and Hazardous Materials Safety Administration (PHMSA) to request an
interpretation of the regulation on determining maximum allowable operating pressure (MAOP)
for natural gas pipelines, 49 C.F.R. § 192.619. Specifically, do the design MAOP requirements
of 49 C.F.R. § 192.6 i 9(a)(l) apply to pipelines in service today that were placed in service
before July 1, 1970?1 If a segment of pipeline was placed in service before July I, 1970, and the
design MAOP is the lowest MAOP from the allowable methods of calculating MAOP set forth in
§ 192.6 19(a), must the operator operate that line under the design MAOP? (Please note that the
California Public Utilities Commission (CPUC) no longer permits gas operators within its
jurisdiction to rely on§ 192.619(c), the "grandfather clause," to validate MAOP.
2)
In PHMSA's Waiver of Compliance Order PHP 08-0074, dated March 17, 2008, PHMSA
provided an interpretation of 192.619(a)'s MAOP requirements. Under that interpretation,
PHMSA acknowledged that:
1 As PHMSA may be aware, in the aftermath of the San Bruno, California pipeline explosion disaster, the California
Public Utilities Commission (CPUC) ordered its regulated gas utilities to begin extensive evaluations of records and
hydrotesting to verify the safety of natural gas pipelines. In particular, gas operators were ordered to validate the
MAOP of their transmission lines without relying on § 192.6 19(c) (the "grandfather clause"). See Calif ornia Public
Utilities Commission Decision 11 -06-0 17, pp. 18, 31 (June 9, 20 I I), available at
http://docs.cpuc.ca.gov!PublishedDocs/WORD PDF/FINAL DECISION/ 137309.PDF.
2 See California Public Utilities Commission Decision 11 -06-017, pp. 18, 3 1 (June 9, 20 I I), available at
http://docs.cpuc.ca.gov/PublishedDocsfWORD
PDF/FTNAL
DECISION/ 137309.PDF.
_
_
Ratepayer Advocates in the Gas, Electric, Telecommunications and Water Industries

<<<PAGE 6>>>

The Federal pipeline safety regulations in § 192.619(a) limit the MAOP of a
pipeline installed prior to July 1, 1970, to the lowest of the following four
pressures:
- The design pressure of the weakest dement in the segment per
§ 192.619(a)(l );
- The pressure obtained by dividing the pressure to which the segment
was tested after construction by the applicable factor per § 192.619(a)(2);
- The highest actual operating pressure the segment was subjected to
during the 5 years preceding July 1, 1970 per § 192.619(a)(3); or
- The pressure determined by the operator to be the maximum safe
pressure after considering the history of the segment per § 192.619(a)( 4).
A pipeline operator would need data to support all four pressures listed above to
establish the MAOP of a pipeline segment using§ 192.619(a).3
ORA understands this interpretation to mean that an operator must calculate and consider the
design MAOP to determine the MAOP of pipelines installed prior to July 1, 1970 (as well as
after that date). Could PHMSA verify that ORA's understanding is correct?
PHMSA's Waiver of Compliance Order PHP 08-0074, cited above, specifically addresses
distribution lines. If the answer to the previous question is yes, does the same requirement to
calculate design MAOP for pipelines installed prior to July 1, 1970 also apply to transmission
lines? ORA's understanding is that the Subpart L requirements regarding how to determine
MAOP apply both to distribution and transmission lines. Section 192.601 refers to "the
minimum requirements for the operation of pipeline facilities" and § 192.603(a) requires that
"[n]o person may operate a segment of pipeline unless in accordance with this subpart" without
making a distinction between transmission lines or distribution lines.
In a recent hearing held by the CPUC, Pacific Gas & Electric Company (PG&E) asserted that it
is not required to consider design MAOP for a pipeline placed in service before July 1, 1970 that
has been subject to a Subpart J strength test. PG&E states that§ 192.619(a)(1) is forward-
looking and applies only to segments of new pipeline installed after 1970, the year the federal
regulations became effective. In PG&E's opinion, the regulations allow it to operate a line
placed in use prior to July 1, 1970 based on its strength test pressure MAOP, under
§ 192.619(a)(2), even when the design MAOP is lower.
3 PHP 08-0074, p. I (March 17, 2008) (emphasis added).
2

<<<PAGE 7>>>

ORA interprets the regulations differently. ORA's understanding is that when an operator is
directed to validate the MAOP of a line operating today, regardless of when it was installed, it
must use the MAOP determined by § 192.619(a); that is, the lowest value of pressure calculated
using§ 192.619(a)(l), (2), (3) or (4). Thus, ifthe design MAOP is lower than test MAOP, the
design MAOP must be used unless one of the other methods permitted ~nder § 192.619(a) yields
a result that is lower. ORA wishes to verify that its understanding is correct.
ORA has taken this position for a number of reasons. First, Section 192.619(a) does not state that
the design MAOP method is inapplicable to pipelines installed before July 1, 1970. Second, the
MAOP requirements under § 192.619 are part of Subpart L, which governs safe operating
conditions. The "operator must use the lower of ..... "provision of§ 192.619(a) appears to be a
mandatory safety precaution. Third, PHP 08-0074, referenced above, confirms that the design
MAOP provision applies to lines placed in operation prior to July I, 1970.
In sum, the Office of Ratepayer Advocates asks for the following interpretations:
1. When validating the MAOP of pipeline segments placed in operation before July 1, 1970
that are still operating today, is the operator required to calculate and consider the design
MAOP pursuant to§ 192.619(a)(l)?
2. If the answer to Question I is yes, must the operator use its design MAOP when the
design MAOP is the lowest MAOP calculation required by§ 192.6 19(a)?
3. Does§ 192.619 apply both to transmission lines as well as distribution lines?
Sincerely,
Joseph P. Como
Acting Director
Office of Ratepayer Advocates
California Public Utilities Commission
Enclosure
3

<<<PAGE 8>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue. SE
Washington, D.C. 20590
MAR 1 7 2008
Mr. Dennis Fothergill
Regulatory Program Manager
Pipeline Safety Department
Transportation Division
Oklahoma Corporation Commission
P.O. Box 52000
Oklahoma City, OK 73152-2000
Dear Mr. Fothergill:
The Pipeline and Hazardous Materials Safety Administration (PHMSA) reviewed your letter of
January 23, 2008, notifying us that the Oklahoma Corporation Commission (Commission)
granted CenterPoint Energy Resources Corp doing business as CenterPoint Energy Oklahoma
Gas (CenterPoint) a waiver of compliance from state regulation 49 CFR 192.619(a)(3) [as
adopted by the Commission in OAC 165: 20-5-21] for 138 low-pressure distribution system
pipeline segments in Oklahoma. The regulations in § 192.619(a)(3) limit the maximum
allowable operating pressure (MAOP) of a steel or plastic pipeline segment installed prior to
July 1,1970, to the highest actual operating pressure the segment was subjected to during the 5
years preceding July 1, 1970.
The Federal pipeline safety regulations in§ 192.619(a) limit the MAOP of a pipeline installed
prior to July 1, 1970, to the lowest of the following four pressures:
- The design pressure ofthe weakest element in the segment per§ 192.619(a)(l);
- The pressure obtained by dividing the pressure to which the segment was tested after
construction by the applicable factor per§ 192.619(a)(2);
- The highest actual operating pressure the segment was subjected to during the 5 years
precedingJuly 1, 1970per§ 192.619(a)(3);or
- The pressure determined by the operator to be the maximum safe pressure after considering
the history ofthe segment per§ 192.619(a)(4).
A pipeline operator would need data to support all four pressures listed above to establish the
MAOP of a pipeline segment using§ 192.619(a).
When these rules were first promulgated in 1970, PHMSA recognized that an operator may not
have all the pressure data needed for existing pipelines. Therefore, we included in the rules a
"grandfather clause" to allow pipeline operators to establish the MAOP of an existing pipeline
segment in satisfactory condition, and considering its operating and maintenance history, at the
highest actual operating pressure to which the segment was subjected during the 5 years prior to
July 1, 1970. This "grandfather clause" is codified in§ 192.619(c), not§ 192.619(a)(3).

<<<PAGE 9>>>

2
The operator at the time the regulations were promulgated in 1970 should have established the
MAOP for each of these 138 low-pressure segments by using either § 192.619(a) or
§ 192.619(c). Moreover, there are additional MAOP restrictions for low-pressure distribution
systems in§ 192.623. Subsequently, the MAOP of these segments can only be increased in
accordance with 49 CFR Part 192, Subpart K- Uprating, not§ 192.619(a) or§ 192.619(c), and
with consideration of§ 192.623. Accordingly, if CenterPoint wishes to increase the existing
MAOPs, they should seek relief from the uprating regulations and the low-pressure distribution
system regulations, if required, not from§ 192.619(a)(3).
Unfortunately, no data was submitted with the waiver grant to PHMSA regarding the existing
MAOPs of these 138 segments. Nor is it clear why CenterPoint is seeking MAOP relief, if as
you state in your letter, "CenterPoint requested the MAOP for these 138 low pressure gas
distribution pipeline segments be established at 1.00 psig, which is the current and historical
maximum operating pressure for these segments. " If these segments have been historically
operated up to 1.00 psig, then the existing MAOPs must already be at least 1.00 psig or the
segments have been historically operated in violation of the pipeline safety regulations. If so,
this needs to be addressed before a waiver is granted.
PHMSA is unable to fully evaluate this waiver grant without additional information. For
example, why is CenterPoint establishing MAOPs in 2008 for pipeline segments that have been
operating for over 50 years? Are there any open enforcement actions regarding the historical
operation of these segments up to 1.00 psig? How does CenterPoint propose to meet the
requirements in § 192.623, when it is known that many gas appliances are rated for 0.5 psig or
less, not 1.00 psig?
For the reasons stated above, PHMSA objects to this waiver and the Commission's order is
stayed. The Conunission may appeal this matter. However, because the waiver of
§ 192.619(a)(3) is inappropriate, PHMSA suggests that CenterPoint resubmit its application to
the Commission and that the Commission grant a new waiver, if appropriate. The new waiver
grant must specifically identify the state pipeline safety regulation the Commission is waiving
and must include new information from the petitioner to justify granting the waiver. This new
information should include, at a minimum, technical evidence to substantiate that an MAOP of
1.00 psig for these 138 low-pressure distribution pipeline segments would result in equivalent or
greater safety than an MAOP established using the methods currently allowed in the Federal
pipeline safety regulations in 49 CFR Part 192.
-
If you wish to discuss this waiver or any other pipeline safety matter, my staff would be pleased
to assist you. Please call Barbara Betsock, Acting Director ofRegulations at 202-366-4361 for
regulatory matters or Alan Mayberry, Director of Engineering and Emergency Support at
202-366-5124 for technical matters.
Sincerely,
w d.~
11 0-v.h
bn-
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety

<<<PAGE 10>>>

28780 Federal Register I Vol. 6I, No. 110 I Thursday. june 6, 1996 I Rules and Regulations
corrosion monitoring under § 192.465
for the life of the pipe. Most of these
commenters declared that 5 years would
be adequate, but did not explain why a
longer period is excessive. Lacking any
convincing documentation to the
contrary. RSPA believes the current rule
should stay in effect. In our experience.
a history of corrosion monitoring sheds
light on the possible causes of a
pipeline's condition. Such history has
proven to be a valuable resource in
deciding the extent and kind of
remedial action needed when corrosion
problems emerge on a pipeline.
Regarding the proposed 5-year
retention time for records other than
those required by§§ 192.465 (a) and (e)
and 192.475(b), two commenters said
the minimum time should be 3 years to
coincide with the longest interval
between inspections. Two others
suggested that instead of a set time. we
adopt a performance standard for record
retention, basing it on the time needed
to observe trends. inquire into
compliance, or collect superseding data.
All these comments provide a
reasonable basis for record retention.
However, our main concern is that
operators keep records for a period that
is compatible with the occurrence of
routine compliance investigations.
Therefore, for simplicity and
uniformity, we have decided to adopt
the proposed 5-year minimum retention
time.
The state agency that commented
objected to the 5-year proposal on
grounds that it would sacrifice
information about why external or
atmospheric corrosion control was not
installed on pipelines under §§ 192.455.
192.457. and 192.479. RSPA believes
the loss of this information after 5 years
would not be significant, because the
pipelines involved are covered by
requirements for periodic inspections or
tests for corrosion under §§ 192.465 and
192.481.
Section 192.553. General Requirements
(See previous discussion under
§ 192.14).
Section 192.607. Determination ofClass
Location and Maximum Allowable
Operating Pressure
Because§ 192.607 has no continuing
effect and the deadlines for compliance
have expired. RSPA proposed to remove
§ 192.607 from part 192.
Fourteen TPSSC members voted for
the proposal and one member abstained.
Five operators, one pipeline-related
association. and one state agency
commented on the proposed removal of
§ 192.607. Four operators and the
association favored the idea. One
operator and the state agency disagreed
with removal, believing the rule is
needed to tie a pipeline's maximum
allowable operating pressure (MAOP) to
its class location. Similarly, the NAPSR
report recommended that we only
remove the past compliance deadlines
from § 192.607, leaving the rest of the
rule in place to regulate the relation of
class location to stress level on high-
stress pipelines.
Section 192.607 was a transitional
requirement. Its purpose was to
establish plans under which operators
initially determined class locat ions and
confirmed or revised the MAOPs of
their high-stress pipelines
commensurate with their class
locations. Section 192.607 provides that
the plans had to be executed in
accordance with § 192.6 11 . This latter
section together with § 192.609 are
sufficient to require that operators have
up-to-date class location determinations
for high-stress pipelines, and maintain
the MAOPs of those lines commensurate
with their class locations.
Accordingly, § 192.607 is removed
from part 192.
Section 192.61 1. Change in Class
Location
Section 192.611 requ ires confirmation
or revision of a pipeline's MAOP within
18 months after a change in class
location. RSPA proposed to reorganize
§ 192.6 1 I to clarify the requirement that
the MAOP resulting from confirmation
or revision may not exceed the
pipeline's previous MAOP. This
requirement is currently set forth in
§ 192.611 (a)(3)(ii), suggesting that it
applies only to confirmations or
revisions under paragraph (a)(3). which
is not the intent.
Fourteen TPSSC members voted for
the proposal and one member abstained.
Five operators and one pipeline-
related association commented on the
proposal: each agreed with the proposal.
Section 192.6 11 is, therefore, adopted as
proposed in the NPRM.
Section 192.614, Damage Prevention
Program
To decrease excavation damage to
pipelines,§ 192.6 14(b)(2) requires
operators to notify excavators and the
public about the need to locate buried
pipelines before excavating. The NPRM
proposed to amend the rule to clarify
that in contrast to the actual notification
required for excavators. only general
notification is required for the public.
General notice can be given through
newspapers, radio, television. or other
means of mass communication. as
appropriate for the public in the vicinity
of the pipeline.
Fourteen TPSSC members voted for
the proposal and one member abstained.
Six pipeline operators and two
pipeline-related organizations
commented. Seven commenters gave
their full or qualified approval and one
commenter opposed the proposal. The
qualified and negative comments were
that the rule should inform operators of
the acceptable means of notification. We
do not feel it is necessary for the rule
to do so. however. because the available
means of giving general public notice
are well known. The amendment to
paragraph (b) (2) is adopted as proposed.
Section 192.619. Maximum Allowable
Operating Pressure: Steel or Plastic
Pipelines
Section 192.619 (a) prescribes six
pressure limits for use in determining
the MAOP of steel and plastic pipelines,
the lowest of which establishes the
MAOP. Paragraph (a)(4) limits the
MAOP of furnace butt welded pipe to 60
percent of the mill test pressure.
Paragraph (a)(5) limits the MAOP of
other steel pipe to 85 percent of the
highest test pressure to which the pipe
has been subjected, whether by mill test
or by the post installation test.
RSPA proposed to repeal paragraphs
(a)( 4) and (a)(5), primarily because mill
tests are not an adequate MAOP
consideration. However, to assure
consideration of longitudinal joint
efficiency. RSPA also proposed, in
paragraph (a)(2)(iii). that the class
location pressure limit under existing
paragraph (a)(2)(ii) be reduced for
furnace butt welded pipe and lap
welded pipe.
Eleven TPSSC members voted for the
proposal, one member supported it with
a recommended change, two members
opposed it, and one abstained. A
member recommended that RSPA not
adopt proposed paragraph (a)(2)(iii)
because design pressure (under
paragraph (a)( I)) adequately covers
longitudinal joint concerns.
RSPA concurs with this view as
explained below in response to public
comment.
Thirteen operators, four pipeline-
related associations, and one state
agency commented on the proposed
amendment. Two operators. one
pipeline-related association, and one
state agency commented that proposed
paragraph (a) (2) (iii) could require
operators to reduce the operating
pressure of some pipelines or test them
to higher pressures than they previously
were tested, possibly damaging the
pipelines. In addition. some
commenters stated that proposed
paragraph (a)(2)(i ii) would duplicate use
of longi tudinal joint factors.
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