{"operation":"document","citation":"PI-18-0008","title":"IHI E&C International Corp. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-06-19","effective_on":null,"summary":"PI-18-0008 response to IHI E&C International Corp..","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0008.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0008.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0008","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/58191/ihi-pi-18-0008-06-18-2018-part-193.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue SE\nWashington DC 20590\nJUN 18 2018\nMr. Thomas Donaldson\nProject Director,\nElba Liquefaction Project\nIHI E&C International Corp.\n1080 Eldridge Parkway\nSuite 1300\nHouston, TX 77077\nDear Mr. Donaldson:\nIn a March 7, 2018, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you requested an interpretation of 49 CFR Part 193. Specifically, you requested an\ninterpretation about whether marking with die-stamping was permitted on a 24-inch diameter,\nstainless steel pipeline with nominal ¼-inch wall thickness (NPS 24, schedule 1 OS) that will be\nused as LNG vapor lines (i.e. lines 1218 and 1219) designed for -270°F and will operate at\napproximately -220°F. Though you did not cite to a specific section of Part 193 in your request,\nPHMSA notes that the marking requirement at issue is incorporated by reference in § § 193.2013\nand 193 .23 03. You also reference your January 2017 interpretation request regarding the\napplicability of§ 192.63, Marking of Material, and National Fire Protection Associate (NFPA)\n59A Section 6.3.5, Pipe Marking. PHMSA responded in an email on January 22, 2017 stating\nthat die-stamping is permitted under certain circumstances under Part 192. However, the\nregulations for Part 192 do not apply to Part 193; therefore, that interpretation does not apply to\nyour current request.\nNFPA 59A (2001 ed. incorporated by reference, see§§ 193.2013, 2303) incorporates by\nreference American Society of Mechanical Engineers International (ASME) B31.3 (1996) which\nrequires that pipes be marked. You stated that your position is that the provisions in Section\n6.3.5 ofNFPA 59A related to pipe marking are not applicable to this pipeline because Section\n6.3 is \"titled Installation, and as such is reasonably interpreted to apply to activities that occur\npost manufacture.\" You have already installed die-stamped pipe and stated that your pipe meets,\nin addition to the 2001 edition ofNFPA 59A, all the applicable requirements of American\nSociety for Testing and Materials (ASTM) A358, ASTM A999 and ASME B31.3.\nSection 193.2301 states that \"Each LNG facility constructed after March 31, 2000 must comply\nwith requirements of this part and ofNFPA-59A-2001... In the event of a conflict between this\npart and NFPA 59A, this part prevails.\" Under§ 193.2303, construction acceptance, \"no person\nmay place in service any component until it passes all applicable inspections and tests prescribed\nby this subpart and NFPA-59A-2001...\" NFPA 59A (2001), Chapter 6, Piping Systems and\nComponents, Section 6.1.1, requires all piping systems to be in accordance with ASME B31.3,\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the fonn of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nProcess Piping (1996), and states that the additional provisions of Chapter 6 apply ''to piping\nsystems and components for flammable liquids and flammable gases with service temperatures\nbelow-20°F (-29°C).\" The other standards referenced in your request, ASTM A358, ASTM\nA999 and ASME B31.3, have been incorporated by reference into NFPA-59A (2001), however,\nthey do not address die-stamping.\nSection 6.3.5 ofNFPA 59A-2001 states:\n6.3.5 Pipe Marking. Markings on pipe shall comply with the following:\n(a) Markings shall be made with a material compatible with the basic material or with a\nround-bottom, low-stress die.\nException: Materials less than ¼-inch (6.35 mm) in thickn,ess shall not be die-stamped\n(b) Marking materials that are corrosive to the pipe material shall not be used. Under\nsome conditions, marking materials con4tining carbon or heavy metals can cause\ncorrosion of aluminum. Marking materials containing chloride or sulfur compounds\ncause corrosion of some stainless steels. Chalk, wax-base crayons, or marking inks with\norganic coloring shall be permitted to be used.\nSection 6.3.5 of the 2001 edition ofNFPA 59A is applicable for pipe marking when the pipe is\nused for an LNG Facility under Part 193, which includes pipe manufacturing, installation during\noriginal construction or during operations or maintenance activities when the pipe used in piping\nsystems and components for flammable fluids and flammable gases with service temperatures\nbelow -20° F. This provision states that when marking a pipeline, any pipe less than ¼-inch in\nwall thickness shall not be die-stamped for pipe used in piping systems and components for\nflammable fluids and flammable gases with service temperatures below -20° F. Die-stamped\npipe of less than ¼-inch in thickness used in piping systems and componerits for flammable\nfluids and flammable gases with service temperatures below -20° F is therefore not permitted for\nuse in LNG pipeline facilities subject to Part 193.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\nYou stated that \"If Section 6.3.5 of the NFPA 59A were applicable to the project, it is your\nposition that the reference to thickness refers to nominal thickness.\" Contrary to your statement\nthat ''NFPA has been known to specify actual thickness vs. nominal thickness,\" NFPA 59A\n(2001) does not reference \"nominal thickness.\" The term \"nominal thickness,\" therefore, does\nnot apply to Section 6.3.5. Nominal wall thickness represents the defined thickness with a plus\nor minus allowable tolerance. While your pipe has a nominal wall thickness of ¼-inch, there is\nno guarantee that the actual wall thickness is ¼-inch. The pipe material may be \"less than ¼-inch\n(6.35 mm) in thickness\" and therefore die-stamping is not permitted.\nIfwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\n.G e\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the fonn of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nIHI\nMarch 7, 2018\nElba Liquefaction Project\nIHI Job No: H1502610\nMr. John A. Gale\nDirector of Standards and Rulemaking\nOffice of Pipeline Safety\nRoom 24-310\n1200 New Jersey Ave, SE\nWashington DC 20590:\nDear Mr. Gale,\nIHI E&C International Corporation (IHI} requests a formal written letter of interpretation pursuant to 49\nC.F.R. Part 190.ll(b} concerning the applicability of the Department of Transportation's(DOT}\nregulations at 49 C.F.R. Part 193 to the marking of NPS 24, schedule lOS pipe used in the construction of\nthe Elba Island Expansion Facility Project. Additionally, we request expedited treatment of this matter\ngiven the project schedule.\nBACKGROUND\nOn January 17, 2017 IHI made an informal request regarding the applicability of Regulations 192.63 (b}\nand (c}; 49 CFR 192.63 Marking of Material; and NFPA 59A Section 6.3.5 Pipe Marking. Specifically, IHI\nwas seeking clarification that field die stamping is a marking applied post manufacture, and that the\nrequirements associated with blunt or rounded edges of the marking only apply when a die stamp\nmarking is applied. IHI also sought clarification regarding the interpretation of the NFPA's use of the\nwording \"materials less than J4 in. thickness,\" namely that the measurement of J4 in. refers to a nominal\nsize not an actual size. On January 22, 2017, IHI received an email from a representative at the DOT\nidentifying when cold die stamping is allowed, as well as, an interpretation regarding thickness to mean\nnominal wall thickness. On January 29, 2017 IHI sent a letter to Southern LNG Company L.L.C. and Elba\nLiquefaction Company L.L.C. the Owners of the Elba Island Expansion Facility. This letter was forwarded\nto the DOT by the Owner. Following, the DOT's receipt of the January 29th letter, IHI received an email\nfrom the DOT stating 49 CFR 192 and 195 do not apply to LNG Facilities rather the applicable code is 49\nCFR 193. The communication went on to outline the DOT's comments and/or concerns regarding the\ndocumentation provided. This letter will respond to the conclusions of that interpretation, the requests\nfor additional documentation and will serve as I Hi's request for a formal interpretation on this matter.\nSection 6.3.5 of the NFPA 59A is not applicable to this project. This section is titled Installation, and as\nsuch is reasonably interpreted to apply to activities that occur post manufacture. It is I Hi's position that\nSection 6.3.5 of NFPA 59A-2001 does not apply to marking performed in the process of manufacturing.\nThe pipe in question was embossed marked during the manufacturing process by Butting, please see\nAppendix 1, the MTR.\n(1) If Section 6.3.5 of the NFPA 59A were applicable to the project, it is I Hi's position that the\nreference to thickness refers to nominal thickness. In regard to the J4 inch thickness mentioned\nin Section 6.3.5 of NFPA 59A-2001, it does not state actual measured thickness or nominal\nIHI E&C International Corporation\n1080 Eldridge Parkway, Ste. 1300, Houston, TX 77077\nTel +1713270 3100\nPage 1\n\n<<<PAGE 5>>>\n\nIHI\nthickness. If it can be agreed that 6.3.5 does not apply to manufacturers marking, the X inch\nreference to thickness is not relevant. NFPA has been known to specify actual thickness vs.\nnominal thickness but in this case did not. It is due to this lack of clarity that IHI interprets X inch\nto be nominal thickness since it is common practice to refer to pipe thickness nominally in\naccordance with ASME Code.\n(2) Yes there is sufficient thickness for pressure containment after die stamping, if die stamping had\nbeen used as the applicable marking. The corrosion allowance used in the B31.3 calculations for\nthe stainless steel pipe in question was determined to be 0.00 inch since the product in the line\nis not corrosive to 304/304L stainless steel. The calculated wall thickness required is 0.174 inch.\nThe nominal wall thickness of the pipe is 0.250 inch; the mill under-tolerance permitted by\nASTM A358 is 0.01 inch and the depth of the embossing is 0.012 inch. Therefore, the thickness\nof pipe available for pressure containment at the point of the embossing is 0.250 - 0.01 - 0.012 =\n0.228 inch. There is, therefore, sufficient thickness for pressure containment in accordance with\nASME B31.3 - 2014.\n(3) The pipe in question was manufactured in accordance with ASTM A358. Material Test Reports\n(MTRs) are attached as documentation of this point. ASME B31.3-2014 was the design code.\nASTM A358 is a listed material in ASME B31.3-2014. ASTM A358 nor ASTM A999 specify the type\nof marking to be used. Butting, who is the manufacturer of the pipe in question, utilizes\nembossing of the base material using round bottom low stress letters and digits prior to forming\nand welding of the base material into pipe. After marking, the pipe is cold formed, welded,\nsolution annealed, picked and passivated. If the 'passive', chromium-rich, oxide film that forms\nnaturally on the surface of the steel was damaged during the embossing process, it would be\nrestored during the process of heat treating, pickling and passivating. The act of embossing the\nbase material in the mill is non-damaging to the pipe and does not compare to the act of field\nstamping. Please refer to attached STATEMENT of PIPE MARKING provided by Butting.\nButting is a reputable manufacturer producing approximately 20,000 tons of stainless steel pipe\nannually made in this manner. They have been marking their pipe by the same means since the 1990s\nand have supplied pipe to LNG projects around the world including several approved and operating LNG\nproject in the US.\nBased on the above facts and the interpretations of the Code, it is the position of IHI and Butting that\nthe embossed pipe in question, as supplied, meets all the applicable requirements of ASTM A358, ASTM\nA999 and ASME B31.3, as well as, NFPA 59A-2001.\nSincerely,\nProject Director\nElba Liquefaction Project\nCc IHI Eric Kahre, Edward Ramirez, Matthew Delong, Jason Smith, Tiffany Cawthorne\nIHI E&C International Corporation\n1080 Eldridge Parkway, Ste. 1300, Houston, TX 77077\nTel +1713270 3100\nPage 2\n-'·'\n-\n\"\n'","truncated":false,"body_characters":13260}