{"operation":"document","citation":"PI-20-0009","title":"Public Advocates Office, California PUC — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-04-24","effective_on":null,"summary":"PI-20-0009 response to Public Advocates Office, California PUC concerning 192.113.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-20-0009.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-20-0009.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-20-0009","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/73931/california-public-advocates-office-pi-20-0009-05-07-2020-part-192-113-letter-signed.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMay 7, 2020\nMr. Darwin E. Farrar\nChief Counsel\nPublic Advocates Office\nCalifornia Public Utilities Commission\n505 Van Ness Avenue\nSan Francisco, CA 94102\nDear Mr. Farrar:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated\nMarch 10, 2020, you requested an interpretation of 49 Code of Federal Regulations (CFR) Part\n192. Specifically, you requested an interpretation of § 192.113 as it relates to the longitudinal\njoint factor (E) for steel used under § 192.105 to determine a natural gas pipeline design\nmaximum allowable operating pressure (MAOP).\nYou ask for clarification whether a value of E = 1.0 or E = 0.8 is used to calculate MAOP for\nsteel pipelines with diameter of over four inches, installed after 1970, with an unknown\nlongitudinal joint, and is used in the construction or replacement sections of natural gas\npipelines.\nYou stated that the California Public Utilities Commission recently required its Safety and\nEnforcement Division to oversee an audit of the MAOP-related records of the Southern\nCalifornia Gas Company and San Diego Gas and Electric Company natural gas transmission\nLine 1600. You stated, in the Line 1600 case, the longitudinal joint type in certain segments is\nunknown. However, you stated an auditor who examined the records on the pipeline has stated\nthat because the operator has represented there are no lap weld or furnace butt welds pipe in\nthese segments, an E = 1.0 may be used. You stated this is in contradiction to the requirement\nunder § 192.113 for a type of longitudinal joint that cannot be determined.\nYou stated that the Public Advocates Office seeks PHMSA’s interpretation of the following\nquestions based on the concerns set forth above. PHMSA’s responses follow the questions.\nQuestion 1: Are all Line 1600 segments installed after 49 CFR Part 192 was codified in\n1970, that are over four inches, and that have an unknown longitudinal seam type, required to\nhave a longitudinal joint factor of no greater than 0.8, assuming it is conclusively determined\nthat such segments do not contain lap welds or butt welds (which would necessitate a\nlongitudinal joint factor of no greater than 0.6)?\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form 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 are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nPHMSA Response: Yes, the table included in § 192.113 states that if the type of\nlongitudinal joint cannot be determined, the joint factor to be used must not exceed that\ndesignated for ‘‘Other.’’ For “Other” pipe over 4 inches (102 millimeters) the longitudinal\njoint factor E is 0.8. Methods for determining the pipe joint factor can be based upon factors,\nsuch as whether the pipe diameters, wall thicknesses, yield strength, and manufacturing\nperiod are applicable for that seam type. Also, the seam type can be determined based upon\ninspections of the pipe, such as excavations of the pipe or pipe removals.\nQuestion 2: Given the applicable ASA [American Standard Code for Pressure Piping]\nstandards establishing MAOP, dating back to 1955 and continuing until the codification of\n49 CFR Part 192 in 1970, is it proper to assume a longitudinal joint factor of no greater than\n0.8 for pipe segments installed during that period, which have unknown longitudinal seam\ntypes, and which are over four inches in diameter, even if it is conclusively determined that\nsuch pipes do not contain lap welds or butt welds?\nPHMSA Response: If the longitudinal seam type of a pipeline is unknown, a value of E\nequal to 0.8 must be used in § 192.105 for determining the design pressure of pipelines with\na diameter greater than 4 inches.\nIf the pipelines’ MAOPs were established prior to 1970, under the § 192.619(c)\nrequirements, the operators can operate them under those established MAOPs. However, a\nsegment of pipeline that has been relocated or replaced cannot be returned to service without\nmeeting the testing requirements under § 192.503, as well as the design and pressure test\nrequirements in § 192.619(a)(1-2).\nQuestion 3: Where the answer to question 1 or 2 is yes, does the resulting required reduction\nof the longitudinal joint factor from 1.0 to 0.8 also require that when the design is based upon\nMAOP required under 49 CFR § 192.105 to be reduced by 20%, assuming all other inputs\ninto that formula are accurate and are otherwise unchanged?\nPHMSA Response: Yes, since the MAOP is determined based on the design pressure\nrequirements in § 192.105, and with E being a proportional factor in the equation in\n§ 192.105, then a reduction of E from 1.0 to 0.8 is a 20% reduction in MAOP.\nIf we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nJOHN A\nGALE\nDigitally signed\nby JOHN A GALE\nDate: 2020.05.11\n08:10:55 -04'00'\nJohn A. Gale\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form 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 are not generally applicable, do not create legally-enforceable rights or\nobligations, and are provided to help the specific requestor understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nPublic Advocates Office\nCalifornia Public Utilities Commission\n505 Van Ness Avenue\nSan Francisco, California 94102\nTel: 415-703-1584\nwww.publicadvocaLes.cpuc.ca.gov\nMarch 10, 2020\nJohn Gale\nDirector, Standards and Rulemaking\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nEast Building, Second Floor\n1200 New Jersey Avenue SE\nWashington, D.C. 20590\nDear Mr. Gale:\nThe Public Advocates Office is the independent consumer advocate at the\nCalifornia Public Utilities Commission. We are writing to the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) to request an interpretation of the regulations\nat 49 Code of Federal Regulations (CFR) § 192.113 that address determinations\nregarding the Longitudinal Joint Factor (LJF) for steel pipe, a required factor for\ndetermining the design-based Maximum Allowable Operating Pressure (MAOP) for\nnatural gas pipelines under 49 CFR §192.105.\nSpecifically, we seek to clarify that for pipelines installed after 1970, if a transmission\nline is over four inches, has steel pipe with a type oflongitudinal joint that cannot be\ndetermined because it is unknown, and is used in the construction or replacement\nsections, does 49 CFR §192.113 allow for a Longitudinal Joint Factor value of 1.0, or\nmust the Longitudinal Joint Factor be no greater than 0.8?\nSouthern California Gas Company and San Diego Gas & Electric Line 1600\nThe California Public Utilities Commission (CPUC) recently required its Safety and\nEnforcement Division (SED) to oversee an audit of the MAOP-related records of the\nSouthern California Gas Company (SoCalGas) and San Diego Gas & Electric Company\n\n<<<PAGE 4>>>\n\nPage2\n(SDG&E)1 transmission Line 1600 (Line 1600 Audit).2 In this case, the longitudinal\njoint type in certain segments of a transmission line is unknown. However, an auditor\nwho examined the records on that line has stated that because the operator has\nrepresented there are no lap weld or furnace butt welds pipe in these segments, a 1.0 LJP\nmay be used.J Specifically, the Line 1600 Audit states:\nThere are records for pipe segments that did not have a seam type\nlisted in the pipe specifications. SDG&E performed an internal\nstudy on long seam types based on the history of the company's Pipe\nDesign Standards. No Lap Weld or Furnace Butt Weld pipe was\nused in the construction and replacement sections of Line 1600.\nTherefore, a longitudinal joint factor of 1. 0 can be used when there\nis no specification of seam type on a document.1' ~\nThe Public Advocates Office is concerned with both the operator's and the auditor's\nassertion that the MAOP of design is being properly calculated for Line 1600.\nIt is the Public Advocates Office's understanding that 49 CPR §192.113 requires that, in\ncases where a transmission line is over four inches in diameter, and the type of\nlongitudinal joint cannot be determined, the longitudinal joint factor to be used in the\nformula to calculate the design MAOP must not exceed 0.8.6\nThe Public Advocates Office is also concerned that MAOP of design asserted by both the\noperator and the auditor does not comport with the American Standards Association\n(ASA) standards in effect between 1955 and when 49 CPR Part 192 was adopted in 1970.\nIndeed, the ASA standards in effect from 1955 and 1967 for \"Joint Efficiency\" provide\n1 Collectively the operator.\n1 See D.18-06-028, mimeo, p. 129, Ordering Paragraph 9. Available at:\nhttp://docs.cpuc.ca.gov/PublishedDocs/Publ ished/G000/M.217 /K0 13/2170 13446.pdf\nSee also, Line 1600 MAOP Audit-Interim Report, p. 3. \"RCP was selected as an independent auditor for\nthis audit pursuant to California Public Utilities Commission (CPUC) D.18-06-028 (Decision). The\nCPUC's Safety and Enforcement Division (SEO) is directed to oversee this audit of San Diego Gas &\nElectric Company's (SDG&E) and Southern California Gas Company's (SoCalGas) MAOP records for\nLine 1600.\"\n;! The auditor made this statement based on the knowledge of SoCalGas and SDG&E. The results of this\naudit are provided as Attachment A and the Line 1600 Audit can be found at:\nhttp://docs.cpuc.ca.gov/SearchRes.aspx?docformat=ALL&DocID=323 l 70376\n~ See Attachment C, p. 10, point iii. Emphasis added.\n~ The Line 1600 Audit was publicly provided by the Safety and Enforcement Division in redacted form.\nPublic Advocates Office has received the version that SoCalGas/SDG&E asserts has confidential\ninformation. Public Advocates Office is providing the public version as Attachment A.\n6 All entries in the Line 1600 Audit show that the outside diameter of the pipeline is over four inches.\n\n<<<PAGE 5>>>\n\nPage3\nthat, \"[i]fthe type oflongitudinaljoint can be determined with certainty, the\ncorresponding Longitudinal Joint Factor \"E\" (Table 841.12) may be used. Otherwise, the\nfactor 'E' shall be taken as 0.60 for the pipe 4 inches and smaller, or 0.80 for pipe over 4\ninches.\"1\nThe Public Advocates Office understands that the conclusion that, \"a longitudinal joint\nfactor of 1.0 can be used when there is no specification of seam type on a document,\"\nwould render meaningless the 49 CFR § 192.113 requirement that a pipe over 4 inches in\nthe \"Other\" category have an LJF no greater than 0.8. Relatedly, the Public Advocates\nOffice understands this conclusion would also render meaningless the portion of the table\nunder 49 CFR §192.113 that provides a 0.8 LJF for \"Other\" pipe classes that are not\nshown on that table.\nThe Public Advocates Office also understands that this same conclusion would not\ncomport with the ASA standards in effect from 1955 until the adoption of 49 CFR Part\n192 in 1970, because those standards prescribed a LJF of0.8 for pipe over four inches\nwhere the type of longitudinal joint was uncertain or unknown.\nA review of the record shows pre-1971 and post 1970 audit entries that have imputed\nLJF's of 1.0, even though the records indicate the operator does not know the seam type.\nAll of these entries have unknown pipe manufacturers, and an outside diameter of over\nfour inches.~\nThe Public Advocates Office seeks PHMSA's interpretation of the following questions\nbased on the concerns set forth above:\n1. Are all Line 1600 segments installed after 49 CFR Part 192 was\ncodified in 1970, that are over four inches, and that have an unknown\nlongitudinal seam type, required to have a longitudinal joint factor of no\ngreater than 0.8, assuming it is conclusively determined that such\nsegments do not contain lap welds or butt welds (which would\nnecessitate a longitudinal joint factor of no greater than 0.6)?\n1 See American Standard Code for Pressure Piping (ASA) B31.1.8-1955, \"Gas Transmission and\nDistribution Piping Systems\" §811.27.D, pp. 17-18.\nSee also USA Standard Code for Pressure Piping (USAS) B31.8-1967 \"Gas Transmission and\nDistribution Piping Systems\", §811.253.D, p. 11.\nl! These long seam entries and pipe manufacture entries are redacted in the Line 1600 Audit that was\npublicly provided by SED. SoCalGas has marked these entries as confidential in the data response to the\nPublic Advocates Office. These blacked out entries can be seen beginning on page 19 of 32, with the\ndocument entitled \"Audit Line 1600-Final.\"\n\n<<<PAGE 6>>>\n\nPage4\n2. Given the applicable ASA standards establishing MAOP, dating back to\n1955 and continuing until the codification of 49 CFR Part 192 in 1970,\nis it proper to assume a longitudinal joint factor of no greater than 0.8\nfor pipe segments installed during that period, which have unknown\nlongitudinal seam types, and which are over four inches in diameter,\neven if it is conclusively determined that such pipes do not contain lap\nwelds or butt welds? ,\n3. Where the answer to question 1 or 2 is yes, does the resulting required\nreduction of the LJF from).0 to 0.8 also require that the design based\nMAOP required under 49 CFR §192.105 be reduced by 20%, assuming\nall other inputs into that formula are accurate and are otherwise\nunchanged?\nIf you wish to discuss any questions or concerns, please contact Dr. Nathaniel Skinner,\nPublic Advocates Office Safety Branch Program Manager, at (415) 703-1393.\nDarwin E. Farrar\nChief Counsel\nPublic Advocates Office-\nCalifornia Public Utilities Commission\nEnclosure","truncated":false,"body_characters":14175}