# Bureau Veritas North America, Inc. — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-16-0002
- **title:** Bureau Veritas North America, Inc. — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2016-07-18
- **effective on:** Not available
- **summary:** PI-16-0002 response to Bureau Veritas North America, Inc. concerning 192.107, 192.113.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0002.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0002.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0002
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/Pipeline/2016/PI_16_0002.pdf
**body:**

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590
JUL 18 2016
Mr. Nate Chandler
Mechanical Engineer
Bureau Veritas North America, Inc.
Industry, Power and Utilities Group
180 Promenade Circle, Suite 150
Sacramento, CA 95834
Dear Mr. Chandler:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated
January 11, 2016, you requested an interpretation of 49 CFR Part 192. You asked what the value
·for the longitudinal joint factor (E) in 49 CFR 192.113 should be in determining the yield
strength (S) for steel pipe in 49 CFR 192.107.
You stated that Part 192 Subpart C - Pipe Design requires that the yield strength to be used in
the design formula in 49 CFRl 92.105 is 24,000 psi if a pipe's specification or tensile properties
are unknown. Also, you stated the longitudinal joint factor (E) should be employed in the yield
strength calculation because the quality of the material properties, and the quality of joint are two
separate and distinct items required to be accounted for the calculation.
You stated that your understanding of§§ 192.107 and 192.113 is that for unknown pipe material
with unknown seam, the specified minimum yield strength value used in the denominator of the
percent specified minimum yield strength calculation should be 14,400 psi (24,000 x 0.6) using
the E value of 0.6. Therefore, you asked if your understanding of the yield strength
determination is correct.
In addition, PHMSA asked you to provide us with an example of the numerator and denominator
values for yield strength calculations. You responded to our follow up questions on April 4,
2016, as follows:
1. You assumed SMYS to be 30,000 psi (no tensile data available) because the operator thinks
this is what it should be based on inconclusive records, from 30's, 40's, 50's or 60's or 70's,
and has "no tensile," data for these vintages to support 30ksi.
2. You stated that the operator is unsure about wall thickness or seam joint of this vintage pipe
based on lack of records.
3. You asked if the calculation for percentage SMYS is equal to= 30,000/(30,000*0.6) x 100
using the 30,000 psi and E factor of 0.6 in the denominator, or equal to=
30,000/(24,000*0.6) x 100 using 24,000 psi and E factor of 0.6 in the denominator, or equal
to= 30,000/24,000 x 100 using 24,000 psi in the denominator and without E factor?
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 2>>>

2
Our responses to your April 4, 2016, email are as follows:
1) It is incorrect to assume 30,000 psi for a pipeline without proper records and your
calculations would increase the percentage SMYS than decrease it. Per§ 192.107(b)(2),
a yield strength of 24,000 psi should be used for a steel pipeline with unknown yield
strength.
2) When a pipe's wall thickness is unknown, the wall thickness is determined by the method
used in § 192.109. If a pipe's longitudinal seam type is not known, it is determined using
the information in§ 192.113.
3) Your values chosen for yield strength and related calculations are incorrect. Under
§ 192.105, an accurate yield strength is required to determine the design pressure of a
pipeline. Your calculations are therefore incorrect, as you use an estimated, and
inaccurate, SMYS within these calculations.
If you chose to use the§§ 192.107 and 192.113 requirements instead of tensile testing, for
unknown pipe material, you must use 24,000 psi yield strength to determine the design pressure
in§ 192.105. Pipe mechanical properties of diameter, wall thickness, pipe grade (strength) and
longitudinal seam type are then used in the design pressure formula of§ 192.105, along with any
derating based upon operational temperatures and derating factors in§ 192.115. Ifwe can be of
further assistance, please contact Tewabe Asebe at 202-366-5523.
Sincerely,
Director, Office of Standards
and Rulemaking
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 3>>>

January 11,
2016
49 CF
FR 192 Requ
uest for Inte
erpretation
Subpar
rts C & L
%S
SMYS Calcu
lations for U
Unknown
P
Pipe Materia
al & Unknow
wn Seam
Mr. John Ga
ale, Director
r
Standards a
and Rulema
aking
Pipeline and
d Hazardou
s Materials
U.S. Depart
tment of Tra
n
ansportation
1200 New J
ersey Aven
ue S.E.
Washington
n, DC 20590
0-0001
Email: John
n.Gale@dot.g
gov
Safety Adm
ministration (
(PHP-30)
Re: Prior
r Emails on
12/17/2015,
attached PD
DF file
Dear Mr. Ga
ale:
At the reque
est of one of
f your staff m
members, I h
have capture
ed the essen
nce of my ea
arlier e-mail r
requests
for interpreta
ation, in this
s abbreviated
d letter. But
t first, a little
about BV, in
n the event y
you have no
ot heard of
us before no
ow.
Founded in
1828, Burea
u Veritas has
s developed
a worldwide
e network to h
help busines
sses, agencie
es and
organization
ns assess, att
tain and dem
monstrate com
mpliance with
h standards
and regulatio
ons in the fie
elds of
Quality, Hea
alth & Safety,
, Environmen
ntal and Soci
ial Accountab
bility (QHSE-
-SA). The co
ompany’s foc
cus is on
protecting its
s clients’ bran
nds, assets a
and business
s. Our service
es have set t
the standard
d for compreh
hensive,
client focuse
ed solutions t
to environme
ental liabilities
s, structural i
integrity, emp
ployee health
h and safety
concerns
as well as re
egulatory com
mpliance issu
ues. Bureau V
Veritas has s
served the q
uality assura
ance, testing
and
expediting n
eeds of the p
power gener
ration and dis
stribution ind
ustry worldw
wide. Working
g in concert w
with
agencies, ve
endors, owne
ers and prog
ram manage
ers, we have
developed a
and tailored o
our procedur
res to meet
the stringent
t needs of ou
ur clients.
During one o
of our review
ws related to a
an NGL (natu
ural gas line)
) and regulat
tions 49 CFR
R 192 specific
cally, we
have discove
ered a point
of concern a
and request a
a formal inter
rpretation of t
the applicab
le sections o
of the code.
Our clarificat
tion is specif
fically addres
ssed to the re
ecommended
d calculation
s for %SMYS
S. This is us
sually some
calculated h
oop stress a
t a particular
r pressure (n
umerator) div
vided by SM
MYS (demonin
nator) in term
ms resoled
in terms of p
percent. The
specific con
ncern is what
t value to use
e for the deno
ominator of t
the %SMYS
calculation
as it applies
to “unknown
n pipe materi
al with unkno
own seam ty
ype.”
S
Subpart C-P
ipe Design, i
is very clear
that 24,000
psi and a joi
nt factor, E,
are to be em
mployed in th
e absence
o
of tensile dat
ta (49 CFR 1
192.107 & 11
13). It is clea
ar that the co
ode, in this se
ection, consi
ders the qua
ality of the
m
material prop
perties and th
he quality of
joint to be tw
wo separate
and distinct
items that ar
re required to
o be
a
accounted fo
or. However
, when calcu
ulating %SMY
YS values fo
or pre-1970 u
unknown exis
sting pipe ma
aterial with
u
unknown join
nt factor for s
strength testi
ng, the code
e is not clear
specific to th
he demomin
ator.
C
Conservative
e engineering
g judgement
t, and implica
ations of Sub
bpart C, wou
ld indicate th
hat for unkno
own pipe
m
material with
unknown se
eam, the SM
MYS value, us
sed in the de
enominator o
of the %SMY
YS calculation
n would be
B u r e a u
u V e r i t as N
N o r t h A m e r i
i c a , I nc .
Main: (916) 725-4
4200
180 Prome
enade Circle, Suite 1
150
Sacramento
o, CA 95834
Fax: (916) 725-8
8242
www.us.bureauver
ritas.com

<<<PAGE 4>>>

2
24,000 psi x
0.6 = 14,400
0 psi. Typica
ally, the joint
factor, E, is
ignored in th
he denomina
ator. As such
h, 14,400
p
psi would be
used in the
denominato
r of the %SM
MYS calculat
tion for unkno
own pipe ma
aterial having
g an
u
unknown sea
am weld. Th
he percent di
fference in %
%SMYS calc
culations, bet
tween 24,000
0 psi or 14,4
400 psi,
k
keeping all o
other valuable
es constant,
would be 66
6.7%. Such a
a difference
could put the
e pipe line ov
ver a 30%
o
of SMYS thre
eshold for str
rength testin
g 1 hour ver
rsus 8 hours,
, in isolated i
nstances, de
epending on
the MAOP
t
the operator
is attempting
g to qualify th
he line to.
I
In summary,
Subpart-C r
regulations in
ndicates that
t "unknown" p
pipe has two
o unknown fa
actors, mater
rial quality
a
and seam we
eld quality. In
n the absenc
ce of tensile d
data or quali
ty control rec
cords, from t
the factory, w
which, if
a
available, sh
ould include
the seam w
eld of the "un
nknown," pip
pe in questio
on, the most c
conservative
e of both
f
factors shoul
ld be employ
yed (e.g; 24,0
000 psi and
E=0.6). In co
ontrast, new
pipe is tensi
le tested acr
ross the
s
seam weld a
and therefore
e, SMYS for n
new pipe wo
ould include t
the seam we
eld joint quali
ty and the jo
oint factor,
E
E, would not
be required
or would be
E=1. Howev
ver, it is the p
presumption
that this is n
not the case
f
for, "unknow
n," pipe prod
duced decad
es earlier, an
nd SMYS' =
SMYS x 0.6
6 = 24,000 x
0.6 =14.400
psi would
b
be the conse
ervative engin
neering appr
roach to take
e since the m
maximum %S
SMYS is at th
he minimum
d
denominator
r and maximu
um numerato
or.
[
[Note: It is un
nderstood tha
at the operat
tor, can dete
ermine the m
inimum and
maximum st
trength test
p
parameters.
Therefore, fi
inal MAOP w
will be determ
mined by test
t. It is also kn
nown that thi
is may be a g
gap in
t
the CFR cod
de, and there
efore, an indu
ustry wide co
oncern. How
wever, it is no
oted here as
a code inter
pretation
c
concern only
y.]
B
Based on wh
here the NGL
L industry ha
as come from
m and the dire
ection the DO
OT and NGL
L operators w
wish to go,
i
t would be h
elpful to hav
ve an interpre
etation in this
s matter.
S
Sincerely,
N
Nate Chandl
er, PE
M
Mechanical E
Engineer
I
Industry, Pow
wer & Utilities
s Group
B
Bureau Verit
as North Am
merica, Inc.
w
www.us.Bure
eauVeritas.c
com
w
www.Bureau
uVeritas.com
m
cc
c: Tewabe
Asebe, DO
OT
B u r e a u
u V e r i t as N
N o r t h 180 Prome
enade Circle, Suite 1
150
Sacramento
o, CA 95834
A m e r i
i c a , I nc .
Main: (916) 725-4
4200
Fax: (916) 725-8
8242
www.us.bureauver
ritas.com

<<<PAGE 5>>>

Request for Formal Interpretation -Revision
Nate Chandler to: infocntr 12/17/2015 11:44 AM
From: Nate Chandler/USA/VERITAS
To: infocntr@dot.gov
Revised to change P (stress) to S (stress).
To Whom it May Concern:
After calling the PHMSA Information line, I was directed to address my request, for interpretation, to this
email. needed.
If by mistake I have reached the incorrect email, please reply and help me redirect my request as
This email may be forward, as required, among PHMSA personnel only, at this time. I would request it
remain confidential between PHMSA and BV, and not be posted on the PHMSA interpretation website
until receipt of the interpretation, followed by a review and approval of the text to be shared with the
public, be obtained. I hope this request is acceptable. Corporate intellectual property and contract
confidentiality requirements should be honored.
During an engineering review of documentation, authorized by one of our clients, our engineer raised a
point of concern. Since then engineers on the technical staff have been in debate about this point. We
are now looking for a formal interpretation of the engineer's findings. It has to do with the correct way to
calculate %SMYS for "unknown," pre-1970 pipe, or just unknown pipe. Considering that the engineer's
presumptions have a significant effect on %SMYS results which can change from below 30% to above
above 40%, it's important for the operator to have a clear classification based on accurate %SMYS
calculations for their Integrity Management Program (IMP).
Without further wording, to confuse the issue, let me copy and place the findings of the engineer below:
Quoted Findings:
"Per 49 CFR 192.107 and 49 CFR 192.113 clearly state that both a SMYS value of 24,000 "and" a
longitudinal joint factor of E=0.6 (E=JF for this discussion) should be used for "unknown" or "pre-1970,"
pipe in calculating Design Pressures and %SMYS. SMYS and Joint Factor, E, represent two
independent factors. One for unknown material quality and the other for unknown seam joint quality, as
the old pipe was produced from the factory and lays in the ground today.. Therefore, a conservative
engineering approach to the %SMYS calculation would factor both into the denominator of the %SMYS
calculation as %SMYS = [S/(24,000 x 0.6)] x 100 = [S/14,400] x 100, versus %SMYS = [S/24,000] x100.
In summary, the code indicates that "unknown" pipe has two unknown factors, material quality and seam
weld quality. In the absence of tensile data or quality control records, from the factory, which, if available,
should include the seam weld of the "unknown," pipe in question, the most conservative of both factors
should be employed (e.g; 24,000 psi and E=0.6). In contrast, new pipe is tensile tested across the seam
weld and therefore, SMYS for new pipe would include the seam weld joint quality and the joint factor, E,
would not be required or would be E=1. However, it is the engineers presumption that this is not the case
for, "unknown," pipe and SMYS' = SMYS x 0.6 = 24,000 x 0.6 =14.400 psi.
Note: It is understood that the operator, can determine the minimum and maximum strength test
parameters. Therefore, final MAOP will be determined by test. It is also known that this may be an gap in
the CFR code, and therefore, industry wide, however, it is noted here as a code interpretation concern
only. "

<<<PAGE 6>>>

.......End of Quoted Findings
Although the regulations are clear with respect to new pipe and pressure calculations for such pipe, it is
not explicit as to the precise form of calculating %SMYS for "unknown," pipe. The engineer's concern is
specifically related to "unknown," pipe "as specified by the operator," per CFR guidelines. The concern is
that material and seam welding flaws produced from the factory in the 30's, 40's and 50's may not be
reliable, especially for operator proclaimed "unknown," or non-tensile tested pipe. The "intent," and
"spirit," of the code appear to be that operators, and engineers, should take the most conservative
approach for questionable conditions not precisely or explicitly covered in the code. Operators, do not
always take such an approach since they are driven to optimize and maximize existing infrastructure,
thereby minimizing costs.
As all good, conservative engineers do, when in doubt, they take the most conservative approach. As
such, it is expected the operator will question the finding, since they historically have not employed the
Joint Factor, E, in their denominator for %SMYS calculations relative to "unknown," pipe. We are hoping
to get an interpretation from PHMSA as supporting basis to our finding, or to remove the concern
depending on the PHMSA interpretation received. Typically, the operator only uses the SMYS value of
the unknown pipe for %SMYS calculations that ultimately, get placed into the IMP systems with respect to
"unknown," pipe. In most cases 24,000 psi is used and no joint factor is applied, or E=1 is employed, even
for "unknown," seam welded pipe.
Thank you for your time and effort in this matter. I hope I have made our question and request clear for
PHMSA to render a technical review and interpretation. Please call or email for further clarification., as
needed. An estimated time frame to render an interpretation would be helpful if it can be provided.
Thank you,
Nate Chandler , P.E.
Mechanical Engineer - Industry / Power & Utilities
Bureau Veritas North America, Inc.
180 Promenade Circle, Suite 150
Sacramento, CA 95834
P: 916.617.2028
F: 916.617.2068
D: 916.514.4519
Nate.Chandler@us.bureauveritas.com
www.us.bureauveritas.com/energyusa
Management Systems Global Certifications:
ISO 9001:2008 – Quality ● ISO 14001:2004 – Environmental ● OHSAS 18001:2007 – Health & Safety
NOTICE:
This message contains confidential information.
To know more, please click on the following link: http://disclaimer.bureauveritas.com
 Please consider the environment before printing this e-mail
Chandler_Nate.vcf Chandler_Nate.vcf
----- Forwarded by Nate Chandler/USA/VERITAS on 12/17/2015 11:42 AM -----
From: Nate Chandler/USA/VERITAS
To: infocntr@dot.gov
Date: 12/16/2015 01:57 PM
Subject: Request for Formal Interpretation

<<<PAGE 7>>>

Revised for spelling, punctuation and grammar 1:55pm, 12/16/2015.
To Whom it May Concern:
After calling the PHMSA Information line, I was directed to address my request, for interpretation, to this
email. needed.
If by mistake I have reached the incorrect email, please reply and help me redirect my request as
This email may be forward, as required, among PHMSA personnel only, at this time. I would request it
remain confidential between PHMSA and BV, and not be posted on the PHMSA interpretation website
until receipt of the interpretation, followed by a review and approval of the text to be shared with the
public, be obtained. I hope this request is acceptable. Corporate intellectual property and contract
confidentiality requirements should be honored.
During an engineering review of documentation, authorized by one of our clients, our engineer raised a
point of concern. Since then engineers on the technical staff have been in debate about this point. We
are now looking for a formal interpretation of the engineer's findings. It has to do with the correct way to
calculate %SMYS for "unknown," pre-1970 pipe, or just unknown pipe. Considering that the engineer's
presumptions have a significant effect on %SMYS results which can change from below 30% to above
above 40%, it's important for the operator to have a clear classification based on accurate %SMYS
calculations for their Integrity Management Program (IMP).
Without further wording, to confuse the issue, let me copy and place the findings of the engineer below:
Quoted Findings:
"Per 49 CFR 192.107 and 49 CFR 192.113 clearly state that both a SMYS value of 24,000 "and" a
longitudinal joint factor of E=0.6 (E=JF for this discussion) should be used for "unknown" or "pre-1970,"
pipe in calculating Design Pressures and %SMYS. SMYS and Joint Factor, E, represent two
independent factors. One for unknown material quality and the other for unknown seam joint quality, as
the old pipe was produced from the factory and lays in the ground today.. Therefore, a conservative
engineering approach to the %SMYS calculation would factor both into the denominator of the %SMYS
calculation as %SMYS = [P/(24,000 x 0.6)] x 100 = [P/14,400] x 100, versus %SMYS = [P/24,000] x100.
In summary, the code indicates that "unknown" pipe has two unknown factors, material quality and seam
weld quality. In the absence of tensile data or quality control records, from the factory, which, if available,
should include the seam weld of the "unknown," pipe in question, the most conservative of both factors
should be employed (e.g; 24,000 psi and E=0.6). In contrast, new pipe is tensile tested across the seam
weld and therefore, SMYS for new pipe would include the seam weld joint quality and the joint factor, E,
would not be required or would be E=1. However, it is the engineers presumption that this is not the case
for, "unknown," pipe and SMYS' = SMYS x 0.6 = 24,000 x 0.6 =14.400 psi.
Note: It is understood that the operator, can determine the minimum and maximum strength test
parameters. Therefore, final MAOP will be determined by test. It is also known that this may be an gap in
the CFR code, and therefore, industry wide, however, it is noted here as a code interpretation concern
only. "
.......End of Quoted Findings
Although the regulations are clear with respect to new pipe and pressure calculations for such pipe, it is
not explicit as to the precise form of calculating %SMYS for "unknown," pipe. The engineer's concern is
specifically related to "unknown," pipe "as specified by the operator," per CFR guidelines. The concern is
that material and seam welding flaws produced from the factory in the 30's, 40's and 50's may not be
reliable, especially for operator proclaimed "unknown," or non-tensile tested pipe. The "intent," and

<<<PAGE 8>>>

"spirit," of the code appear to be that operators, and engineers, should take the most conservative
approach for questionable conditions not precisely or explicitly covered in the code. Operators, do not
always take such an approach since they are driven to optimize and maximize existing infrastructure,
thereby minimizing costs.
As all good, conservative engineers do, when in doubt, they take the most conservative approach. As
such, it is expected the operator will question the finding, since they historically have not employed the
Joint Factor, E, in their denominator for %SMYS calculations relative to "unknown," pipe. We are hoping
to get an interpretation from PHMSA as supporting basis to our finding, or to remove the concern
depending on the PHMSA interpretation received. Typically, the operator only uses the SMYS value of
the unknown pipe for %SMYS calculations that ultimately, get placed into the IMP systems with respect to
"unknown," pipe. In most cases 24,000 psi is used and no joint factor is applied, or E=1 is employed, even
for "unknown," seam welded pipe.
Thank you for your time and effort in this matter. I hope I have made our question and request clear for
PHMSA to render a technical review and interpretation. Please call or email for further clarification., as
needed. An estimated time frame to render an interpretation would be helpful if it can be provided.
Thank you,
Nate Chandler , P.E.
Mechanical Engineer - Industry / Power & Utilities
Bureau Veritas North America, Inc.
180 Promenade Circle, Suite 150
Sacramento, CA 95834
P: 916.617.2028
F: 916.617.2068
D: 916.514.4519
Nate.Chandler@us.bureauveritas.com
www.us.bureauveritas.com/energyusa
Management Systems Global Certifications:
ISO 9001:2008 – Quality ● ISO 14001:2004 – Environmental ● OHSAS 18001:2007 – Health & Safety
NOTICE:
This message contains confidential information.
To know more, please click on the following link: http://disclaimer.bureauveritas.com
 Please consider the environment before printing this e-mail
- **truncated:** false
- **body characters:** 23055