BGC Engineering Inc. — Pipeline Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration August 11, 2022 1200 New Jersey Avenue, SE Washington, DC 20590 Mr. Mark Zellman BGC Engineering Inc. 600 12th Street Suite 300 Golden, CO 80401 Dear Mr. Zellman: In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated July 1, 2022, you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 192 with respect to the § 192.917 requirements for operators identifying outside force damage to pipelines in high consequence areas. You stated the 2004 edition of ASME B31.8S is incorporated by reference and approved for § 192.917 regarding protocols for addressing seismicity. Item “d” in ASME B31.8S, Section A9.2 states that “profile of ground acceleration near fault zones (greater than 0.2 g acceleration)” is a minimal data set that should be collected for each pipeline segment. However, no recommendation for a return period (e.g., 2475, 975, 475, etc.), spectral period (e.g., PGA, 0.1, etc.), or site class (760 m/s [B/C], 537 m/s [C), etc.) is provided. You asked which return period, spectral period, and site class are recommended by PHMSA. PHMSA incorporated by reference the 2004 edition of ASME B31.8S standard and, as you stated in your request, the standard under Section A9.2(d) specifies, at a minimum, to collect several minimal data sets including, “(d) profile of ground acceleration near fault zones (greater than 0.2 g acceleration).” In addition, a review of the 2018 revision of the 2016 version of the ASME B31.8S shows the data collection requirement is the same as the 2004 edition for addressing seismicity. The Federal pipeline safety regulations in § 192.935(a) state that “an operator must take additional measures beyond those already required by Part 192 to prevent a pipeline failure and to mitigate the consequences of a pipeline failure in a high consequence area.” In addition, § 192.917(b) states “…At a minimum, an operator must gather and evaluate the set of data specified in Appendix A to ASME/ANSI B31.8S…. ” Therefore, the pipeline operator’s procedures as well as the data composition collected and used for the assessment must be based upon pipeline operational, terrain, and environmental factors including treating seismicity as a time-independent threat per § 192.917(a). 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 are not generally applicable, do not create legally-enforceable rights or obligations, and are provided to help the specific requestor understand how to comply with the regulations.#

Page 22 Any considerations used in the operator’s pipeline procedures for “return period, spectral period, and site class” must be based upon the operator’s procedures to maintain pipeline safety through the implementation of assessment, mitigation, and reassessment procedures for the seismicity threat. As a minimum, an operator’s procedures must meet the requirements in §§ 192.917, 192.935(a), (b)(2) and (c), 192.937, and 192.939. If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523. Sincerely, John A. Gale 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 are not generally applicable, do not create legally-enforceable rights or obligations, and are provided to help the specific requestor understand how to comply with the regulations.#

Page 3BGC ENGINEERING INC. AN APPLIED EARTH SCIENCES COMPANY 600 12th Street Suite 300 Golden, Colorado 80401 July 1, 2022 Mr. John A. Gale Director, Office of Standards and Rulemaking Office of Pipeline Safety (PHP-30) Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue, S.E. Washington, D.C. 20590-0001 Dear Mr. Gale, Re: Formal interpretation request Text within 49 CFR part 192.917 references ASME B31.8S regarding protocols for addressing seismicity. Item “d” in ASME B31.8S, Section A9.2 states that “profile of ground acceleration near fault zones (greater than 0.2 g acceleration)” is a minimal data set that should be collected for each pipeline segment. However, no recommendation for a return period (e.g. 2475, 975, 475, etc.), spectral period (e.g. PGA, 0.1, etc.), or site class (760 m/s [B/C], 537 m/s [C), etc.) is provided. Which return period, spectral period, and site class is recommend by the Pipeline and Hazardous Materials Safety Administration? BGC ENGINEERING INC. per: Mark Zellman#