{"operation":"document","citation":"PI-22-0013","title":"BGC Engineering Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2022-08-11","effective_on":null,"summary":"PI-22-0013 response to BGC Engineering Inc. concerning 192.917.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-22-0013.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-22-0013.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-22-0013","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/76726/bgc-engineering-inc-pi-22-0013-192-08-11-2022-part192917.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration August 11, 2022\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMr. Mark Zellman\nBGC Engineering Inc.\n600 12th Street\nSuite 300\nGolden, CO 80401\nDear Mr. Zellman:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated\nJuly 1, 2022, you requested an interpretation of the Federal pipeline safety regulations in\n49 Code of Federal Regulations (CFR) Part 192 with respect to the § 192.917 requirements for\noperators identifying outside force damage to pipelines in high consequence areas.\nYou stated the 2004 edition of ASME B31.8S is incorporated by reference and approved for\n§ 192.917 regarding protocols for addressing seismicity. Item “d” in ASME B31.8S, Section\nA9.2 states that “profile of ground acceleration near fault zones (greater than 0.2 g acceleration)”\nis a minimal data set that should be collected for each pipeline segment. However, no\nrecommendation for a return period (e.g., 2475, 975, 475, etc.), spectral period (e.g., PGA, 0.1,\netc.), or site class (760 m/s [B/C], 537 m/s [C), etc.) is provided. You asked which return period,\nspectral period, and site class are recommended by PHMSA.\nPHMSA incorporated by reference the 2004 edition of ASME B31.8S standard and, as you\nstated in your request, the standard under Section A9.2(d) specifies, at a minimum, to collect\nseveral minimal data sets including, “(d) profile of ground acceleration near fault zones (greater\nthan 0.2 g acceleration).” In addition, a review of the 2018 revision of the 2016 version of the\nASME B31.8S shows the data collection requirement is the same as the 2004 edition for\naddressing seismicity.\nThe Federal pipeline safety regulations in § 192.935(a) state that “an operator must take\nadditional measures beyond those already required by Part 192 to prevent a pipeline failure and\nto mitigate the consequences of a pipeline failure in a high consequence area.” In addition,\n§ 192.917(b) states “…At a minimum, an operator must gather and evaluate the set of data\nspecified in Appendix A to ASME/ANSI B31.8S….\n” Therefore, the pipeline operator’s\nprocedures as well as the data composition collected and used for the assessment must be based\nupon pipeline operational, terrain, and environmental factors including treating seismicity as a\ntime-independent threat per § 192.917(a).\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\nAny considerations used in the operator’s pipeline procedures for “return period, spectral period,\nand site class” must be based upon the operator’s procedures to maintain pipeline safety through\nthe implementation of assessment, mitigation, and reassessment procedures for the seismicity\nthreat. As a minimum, an operator’s procedures must meet the requirements in §§ 192.917,\n192.935(a), (b)(2) and (c), 192.937, and 192.939.\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\nBGC ENGINEERING INC.\nAN APPLIED EARTH SCIENCES COMPANY\n600 12th Street\nSuite 300\nGolden, Colorado 80401\nJuly 1, 2022\nMr. John A. Gale\nDirector, Office of Standards and Rulemaking\nOffice of Pipeline Safety (PHP-30)\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue, S.E.\nWashington, D.C. 20590-0001\nDear Mr. Gale,\nRe: Formal interpretation request\nText within 49 CFR part 192.917 references ASME B31.8S regarding protocols for addressing\nseismicity. Item “d” in ASME B31.8S, Section A9.2 states that “profile of ground acceleration near\nfault zones (greater than 0.2 g acceleration)” is a minimal data set that should be collected for\neach pipeline segment. However, no recommendation for a return period (e.g. 2475, 975, 475,\netc.), spectral period (e.g. PGA, 0.1, etc.), or site class (760 m/s [B/C], 537 m/s [C), etc.) is\nprovided. Which return period, spectral period, and site class is recommend by the Pipeline and\nHazardous Materials Safety Administration?\nBGC ENGINEERING INC.\nper:\nMark Zellman","truncated":false,"body_characters":5182}