{"operation":"document","citation":"PI-20-0011","title":"Southern California Gas Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2020-06-15","effective_on":null,"summary":"PI-20-0011 response to Southern California Gas Company concerning 192.113.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-20-0011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-20-0011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-20-0011","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/74296/san-diego-gas-and-electric-and-southern-california-gas-company-pi-20-0011-08-13-2020-part192-113.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration August, 13, 2020\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMr. Travis Sera\nDirector of Integrity Management\nSouthern California Gas Company\n555 W. Fifth Street\nLos Angeles, CA 90013\nDear Mr. Sera:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated\nMay 4, 2020, you requested an interpretation of 49 Code of Federal Regulations (CFR) Part 192.\nSpecifically, you requested an interpretation of § 192.113 as it relates to the longitudinal joint\nfactor (E) for steel used under § 192.105 to determine a natural gas pipeline maximum allowable\noperating pressure (MAOP).\nYou stated that San Diego Gas & Electric and Southern California Gas Company are aware of a\nMarch 10, 2020, submission to PHMSA by the Public Advocates Office for an interpretation of\nthe Longitudinal Joint Factor for Line 1600. You stated that your request relates to the Line\n1600, a 50-mile San Diego Gas & Electric gas transmission pipeline located in San Diego\nCounty, California. Finally, you stated that “through this request, SDG&E and SoCalGas seek to\nconfirm that the operator’s possession of company Standard Specifications for Line Pipe and\nhistorical work order documents which both state a requirement that 16-inch pipe meet the\nAmerican Petroleum Institute (API) 5L/5LX Pipe Specification, and thus affirmatively rules out\npipe classes with LJFs less than 1.0 because API 5L does not allow furnace butt welds on pipe\nover 4-inches or any “other” pipe class with an LJF less than 1.0, are sufficient to establish a\nLongitudinal Joint Factor of 1.0.”\nIn support of your request, you provided background information and documents. You ask\nwhether a longitudinal joint factor of 1.0 is properly determined based on historical records\nunder § 192.113, if the historical records for the 50-mile 16-inch diameter Line 1600 pipeline\nmeets Specification API 5L or 5LX, when such Specification required a pipe class with a\nlongitudinal joint factor of 1.0.\nAs stated in our May 7, 2020 letter to the Public Advocates Office, the longitudinal joint factor\nto be used in the design formula in § 192.105 is determined in accordance with the table listed\nfor § 192.113. Methods for determining the pipe joint factor can be based upon different factors,\nsuch as whether the pipe diameter(s), wall thickness(es), yield strength, and manufacturing\nperiod are applicable for that seam type. Also, the seam type can be determined based upon\ninspections (excavations or pipe removals) of the pipe in accordance with the testing parameters\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\n(spacing for tests and whether destructive or nondestructive) in §§ 192.107, 192.109,\n192.619(a)(4), or 192.624 as applicable. Further, the table included in § 192.113 states that if the\ntype of longitudinal 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 joint\nfactor E is 0.8.\nYour request, although couched in terms of seeking an interpretation on the application of a\nspecific regulation to Line 1600, is more properly viewed as a request for a declaratory judgment\nfrom PHMSA to resolve a factual dispute between you and the California Advocates Office as it\nrelates to the longitudinal seam type for Line 1600. The information provided to us by the\nAdvocates Office is that the longitudinal seam type is unknown, which requires a factor E of 0.8.\nThe information provided by you, in contrast, purports to establish that the seam type is known\nand a factor E of 1.0 is appropriate under the regulation.\nPHMSA provides written clarifications of the Federal pipeline safety regulations that reflect the\nagency's current application of the regulations to the specific facts presented by the person\nrequesting the clarification. Interpretations are not generally applicable, do not create legally-\nenforceable rights or obligations, and are provided to help the specific requestor understand how\nto comply with the regulations. In this case, San Diego Gas & Electric and Southern California\nGas Company are disputing the California Public Advocates Office’s presented information and,\ntherefore, are requesting that PHMSA resolve a factual issue. PHMSA is not in a position to\nvalidate one party’s assertion of facts over the other. Accordingly, PHMSA suggests that both\nparties resolve the factual dispute through physical inspection of the pipeline in question, or\nthrough other appropriate means.\nIf we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\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\nTravis Sera\nDirector - Integrity Management\n555 W. Fifth Street\nLos Angeles, CA 90013\nTel: 213.244.5072\nTSera@socalgas.com\nMay 4, 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\nRe: Request for Regulatory Interpretation, San Diego Gas & Electric and Southern California Gas\nCompany’s Line 1600\nDear Mr. Gale:\nSan Diego Gas & Electric (SDG&E) and Southern California Gas Company (SoCalGas) write to request the\nPipeline and Hazardous Materials Safety Administration (PHMSA) interpret Title 49 Code of Federal\nRegulations (CFR) Part 192.113, which addresses the Longitudinal Joint Factor for steel pipe, a required factor\nfor determining Maximum Allowable Operating Pressure (MAOP) for natural gas pipelines under 49 CFR\n192.105. This request relates to Line 1600, a 50-mile SDG&E gas transmission pipeline located in San Diego\nCounty, California.\nSDG&E and SoCalGas are aware of a March 10, 2020 submission to your office by the Public Advocates\nOffice (CalPA), the consumer advocate of the California Public Utilities Commission (CPUC), requesting an\ninterpretation of the Longitudinal Joint Factor for Line 1600.\n1 Though related, this request differs from the\nCalPA submission in that SDG&E and SoCalGas provide additional information to inform PHMSA’s\ninterpretation. Specifically, this submission includes: (a) the historical records underlying SDG&E’s,\nSoCalGas’, the CPUC’s Safety and Enforcement Division’s (SED) and the independent auditor’s (RCP, Inc.)\nconclusions that the correct Longitudinal Joint Factor (LJF) for all segments of Line 1600 is 1.0; (b) direct\nexamination records for certain segments of Line 1600; and (c) in-line inspection (ILI) data for the pipeline.\n1 PHMSA’s certified State enforcement agency is the CPUC’s Safety and Enforcement Division (SED), not CalPA.\n1\n\n<<<PAGE 4>>>\n\nSection 192.113 provides: “The longitudinal joint factor to be used in the design formula in §192.105 is\ndetermined in accordance with” the table found in Section 192.113, which includes specific Longitudinal Joint\nFactors for pipe classes found under Specification “API 5L” (including API 5LX).2 For 16-inch pipe, the LJF\nfor such pipe classes is 1.0. Section 192.113 further provides: “If the type of longitudinal joint cannot be\ndetermined, the joint factor to be used must not exceed that designated for ‘Other.’\" which is 0.80. Here,\nhowever, as set forth below, SDG&E and SoCalGas determined that the type of longitudinal joints on Line\n1600 are those identified in API Specification 5L, and all of those have an LJF of 1.0\nSDG&E, SoCalGas, SED and RCP all determined that the type of longitudinal joint on Line 1600 could be\nascribed to one of the pipe classes under Specification API 5L/5LX for which the LJF is 1.0 based upon\nhistorical records. Through this request, SDG&E and SoCalGas seek to confirm that the operator’s possession\nof company Standard Specifications for Line Pipe and historical work order documents which both state a\nrequirement that 16-inch pipe meet the American Petroleum Institute (API) 5L/5LX Pipe Specification, and\nthus affirmatively rules out pipe classes with LJFs less than 1.0 because API 5L does not allow furnace butt\nwelds on pipe over 4-inches or any “other” pipe class with an LJF less than 1.0, are sufficient to establish a\nLongitudinal Joint Factor of 1.0.\nPer Section 192.113, SDG&E and SoCalGas apply a LJF of 1.0 where the API 5L/5LX pipe manufacturing\nspecification of the installed pipe is known, and the same LJF of 1.0 applies to all possible seam types subject\nto the manufacturing specification, even where pipe-specific records for certain segments do not identify the\nspecific seam type . With respect to Line 1600, supplemental inspection records (both ILI and direct\nexamination) for this line comport with the documented pipe specification for such segments, and validate the\ndetermined LJF for these pipeline segments, particularly confirming the entire pipeline aligns with the API 5L\nspecification. The SDG&E and SoCalGas position aligns with the underlying principles of Subpart O, namely,\nto strengthen the integrity of transmission pipeline systems using integrated data and a holistic approach.\n3\nSDG&E, SoCalGas, the CPUC’s Safety and Enforcement Division, and an independent auditor retained by\nthe California Public Utilities Commission (RCP, Inc.) reviewed the calculation of the MAOP for Line 1600\nand interpreted the established LJF of 1.0 to be consistent with federal regulations.\n2 51 Fed. Reg. 15333.\n3 “Data integration is an important concept in the IM rule. In principle, this is an action that will help assure that\noperators learn about their pipelines the things that data from disparate activities can tell them.” - Excerpt from PHMSA\nGas Transmission Integrity Management FAQ 240, 08/02/2006, www.phmsa.dot.gov.\n2\n\n<<<PAGE 5>>>\n\nBackground\nLine 1600 is a 16-inch diameter natural gas transmission pipeline originally constructed in 1949 with pipe\nmanufactured by A.O. Smith Corporation using the electric flash-welded (EFW) manufacturing method. The\noriginal Line 1600 design based MAOP is 812.5 pounds per square gauge (psig). Per 49 CFR §192.105, this\nMAOP is established based on the 16-inch outside diameter (OD), 0.250-inch wall thickness, 52 ksi grade, a\n1.0 Longitudinal Joint Factor, and a 0.5 class location design factor. The original 1949 work orders identify\nAPI 5L or API 5LX pipe. Historical records indicate each pipe joint was hydrotested at the mill, and a post-\nconstruction pressure test was not conducted. Approximately 46 miles of the original 1949 pipe remain in\nservice today. The long seam type (pipe class) of the 1949 A.O. Smith pipe is known and is not at issue here.\nOver time, there has been work on small sections of Line 1600, and there are 29 Work Orders (including the\noriginal installation). Twelve of these Work Orders specifically reference the exact long seam type of the\ninstalled pipe, while 17 Work Orders do not. The Line 1600 segments for which the historical installation\nrecords do not specifically identify the long seam type were installed between 1961 and 2006. During this\ntime period, and through the present, SDG&E had and has Standard Specifications for Line Pipe that\nrequired API 5L or API 5LX pipe.\n4 Further, the supporting historical work order records specifically\nreference installation of 16-inch pipe meeting API 5L or 5LX.\nFor six of the 17 Work Orders where the exact longitudinal seam type is not expressly set forth in the Work\nOrder, direct examination records affirm the long seam type to be consistent with API 5L/5LX and a 1.0 LJF.\nThese direct examination records, further validated by ILI results, provide an additional layer of confidence\nthat SDG&E’s available historical records establish that pipe meeting the API 5L or 5LX specification, with\nan LJF of 1.0, was installed on Line 1600.\nIn 2018, to address CalPA’s concerns regarding SDG&E and SoCalGas’s calculation of the MAOP for Line\n1600 using an LJF of 1.0, the CPUC directed SDG&E and SoCalGas to facilitate an audit review of Line 1600\nrecords by an independent third party. The audit was completed in October 2019 by RCP, an independent\nthird-party auditor (Auditor) selected and directed by SED5\n. The Auditor focused on the pipeline segment list\nand validated the MAOP using the historical documentation for Line 1600. After reviewing over 865 pages of\nMAOP records, the Auditor concluded the following:6\n4 SDG&E Standard Specifications for Line Pipe July 9, 1956 to present. The January 27, 1964 and December 12, 1964\nStandards are provided as supporting documents.\n5 CPUC Decision 18-06-028, Ordering Paragraph 9, 10, June 21, 2018\n6 Line 1600 MAOP Audit, Final Report, Dated October 17, 2019 completed by RCP, at 9-10 (emphasis added).\n3\n\n<<<PAGE 6>>>\n\n• “The minimum MAOP based on the lowest of the design and pressure calculations for each pipeline\nsegment on Line 1600 is 800 psig which is greater than the current established MAOP.”\n• “All historical documents were consistent and sufficient to confirm the pipe specifications used on the\noriginal installation of the 16-inch pipe for Line 1600. The company utilized the Kiefner Report in\ncombination with a third-party Inspection Report from Moody Engineering to ensure the manufacturing\nprocess of the 16-inch pipe complied with API-5L standards.”\n• “There are records for pipe segments that did not have a seam type listed in the pipe specifications.\nSDG&E performed an internal study on long seam types based on the history of the company’s Pipe Design\nStandards. No Lap Weld or Furnace Butt Weld pipe was used in the construction and replacement\nsections of Line 1600. Therefore, a longitudinal joint factor of 1.0 can be used when there is no\nspecification of seam type on a document.”\nSDG&E and SoCalGas are currently implementing an SED-approved Line 1600 Test and Replace Plan to\nreplace approximately 37 miles of Line 1600 pipe located in high consequence areas and pressure test\napproximately 13 miles of Line 1600 pipe located in non-high consequence areas.\nSupporting Documents\nAttached to this letter are the following documents, which support a Longitudinal Joint Factor of 1.0 for Line\n1600:\n1. L1600 Supporting Documentation and Data File, which (a) summarizes the historical records and,\nwhere applicable, “dig” records establishing the installed pipe was manufactured to API 5L or API\n5LX Pipe Specifications for pipe segments with Work Orders that do not specifically state the long\nseam type; and (b) attaches those historical and “dig” records by each of the 19 Work Orders.\n2. Line 1600 Longitudinal Joint Factors White Paper prepared by SDG&E and SoCalGas that provides\nsupporting background information and rationale for the application of an LJF of 1.0 to the pipe\ninstalled pursuant to the 19 Work Orders that do not provide an explicit longitudinal seam type. RCP\nreferred to this White Paper in their Audit L1600 spreadsheet and in their audit report.\n3. October 17, 2019, Line 1600 MAOP Audit Final Report of RCP, Inc., an independent third-party\nauditor, which also confirms the determination that a Longitudinal Joint Factor of 1.0 applies to all\nsegments of Line 1600.\n4\n\n<<<PAGE 7>>>\n\n4. Line 1600 In-Line Inspection Data, which confirms all Line 1600 longitudinal seams are intact,\ncomports to the existing pipeline specifications and records, and demonstrates there are no\ninconsistencies with regard to longitudinal seams that may suggest the presence of pipe segments\nwith LJF of 0.8 or 0.6. The entirety of Line 1600 has been in-line inspected 2 times between 2012\nand 2016 using multiple ILI tool technologies to evaluate for metal loss, deformation and\nlongitudinal seam conditions, including circumferential magnetic flux leakage tools.7\nRequest for PHMSA Interpretation\nSDG&E and SoCalGas seek PHMSA’s interpretation of the following question based on the\ninformation set forth above:\n• Under Section 192.113, is a Longitudinal Joint Factor of 1.0 properly determined based\nupon historical records showing that installed pipe in a 16-inch steel transmission line\nmet Specification API 5L or 5LX, when such Specification required a pipe class with a\nLongitudinal Joint Factor of 1.0?\nWe thank you for your consideration. Please contact me if you have additional questions or if you would\nlike to discuss these matters at your earliest opportunity.\nSincerely,\nTRAVIS SERA\nDirector – Integrity Management\nSOUTHERN CALIFORNIA GAS COMPANY\n7 It should be noted that circumferential magnetic flux leakage assessment was only successfully completed once in\n2012. The 2016 attempt to complete inspection of Line 1600 with circumferential magnetic flux leakage resulted in a\nstuck tool and only a partial inspection.\n5","truncated":false,"body_characters":17753}