{"operation":"document","citation":"PI-70-010","title":"United Gas Pipe Line Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1970-02-12","effective_on":null,"summary":"PI-70-010 response to United Gas Pipe Line Company concerning 192.13, 192.63, 192.65, 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-70-010","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1970/PI70010.pdf","body":"<<<PAGE 1>>>\n\nDecember 2, 1970\nMr. W. P. Heineman\nUnited Gas Pipe Line Company\nP. O. Box 1407\nShreveport, Louisiana 71102\nDear Mr. Heineman:\nThis is in reply to your three letters of October 12, 1970, requesting interpretations of various\nsections of 49 CFR, Part 192.\nIn answer to your question concerning requirements for two-phase systems, the statement made in\nHouston that the most severe regulation (either gas or liquid) be complied within two-phase\nsystems is still correct.\nYou state that most two-phase systems are designed to transport primarily natural gas. An\nexamination of the \"Gas Engineers Handbook,\" 1966 edition, page 8/11 on two-phase flow\nindicated that such systems range from gas bubbling in a solid stream of liquid to a fog of liquid in\na gas stream. Therefore, to state that all two-phase systems follow either the gas or liquid\nregulation would not be wise.\nYou state that the B31.8 should be followed in the future as it has been the Code used in the past\nfor two-phase flow. In the case of stress levels in other than Class 1 locations, the gas regulations\nwould be more severe than the liquid, but in most instances the regulations would be similar for\ntransmission type or trunkline type pipelines. Therefore, you should have no problem in the\nfollowing the most severe regulation, at least at present, with the knowledge we have on two-\nphase pipelines.\nIn answer to your question regarding transportation of pipe, a change in the language of Section\n192.65 is under consideration to apply only to pipe transported after the effective date of the\nregulations. We recognize that there is a problem with respect to application of our regulation to\nthe original transportation of existing stocks of pipe. Therefore, we suggest that you furnish all\navailable information as to the transportation procedures used before RP5L1 was issued and the\nprecise nature and magnitude of the problem.\nWith regard to your letter on the qualification of steel pipe presently in inventory, our recent\namendment to Section 192.55 and Appendix B should have alleviated much, if not all of the\nproblem. If you still find that you have a large inventory that does not qualify under a listed\nspecification or Section 192.55(d), you may wish to petition for a waiver. Should you elect to\nfollow this course of action, I suggest that your petition contain the following information:\ndal\\192.1-a\\13\\70-12-02\n1\n\n<<<PAGE 2>>>\n\n1. The magnitude of the problem in terms of quantity of pipe and its value.\n2. The reasons why qualification of the pipe under Section 192.55(a)(2) is not\nappropriate.\n3. The basis upon which the waiver could be found not inconsistent with pipeline\nsafety.\n4. A indication as to whether other companies might also be adversely affected (if the\nproblem is widespread, an amendment might be more appropriate).\n5. Suggested language for an amendment that would alleviate the problem while\nassuring an equivalent level of safety.\nIf we can be of further assistance, please do not hesitate to ask.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector, Acting\nOffice of Pipeline Safety\ndal\\192.1-a\\13\\70-12-02\n2","truncated":false,"body_characters":3130}