{"operation":"document","citation":"PI-71-0119","title":"Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-11-03","effective_on":null,"summary":"PI-71-0119 response to Public Service Commission concerning 192.505.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0119.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0119.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0119","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/g71-11-03_Hendrickson_192.505-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-71-0119\nNovember 3, 1971\nRequest for Interpretation from D. J. Hendrickson\nIndiana Public Service Commission, September 30, 1971\nChief, Technical Division, TSA--32\nChief Regulations Division, TSA-34\nThe above referenced letter has been reviewed by the Technical Division and I wish to advise as follows:\nMr. Hendrickson is correct in his statement relative to paragraph 192.511(c). Our regulations do not specify a\ntest pressure above the desired operating pressure for service line operating in the range of 90 psig to 20 per\ncent of SMYS. However, Mr. Hendrickson is not recognizing the requirement that is specified in paragraph\n192.619(a) (2) revised. This paragraph specifies that in order to operate a pipeline at 100 psig or more, it must\nbe tested according to the limits shown in the table incorporated in the regulation.\nAccording to Paragraph 192.619(a)(2)(ii) the test pressure for new Lines to operate over 100 psig will always\nexceed the maximum allowable operating pressure. The only situation where a test pressure of a new pipeline\nis less than the permitted operating pressure is for the line that will operate between 90-100 psig. This\nvariation was included based on strong recommendations of industry and TPSSC who claimed there was too\nmuch existing equipment designed for 100 psig output but incapable of achieving much over 90 psig. Also,\nsince this is a leak test not a strength test, it was concluded there was little likelihood of there being any\ndetrimental affect on safety. This same reasoning applies to Mr. Hendrickson's comments on paragraph\n192.509.\nIn reviewing these paragraphs, it has been brought to my attention that there is a slight discrepancy in the\nwording used that is, in paragraph 192.509 we state: \"at or below 100 psig.\" In paragraph 192.619 (a) (2) (ii)\nwe state: \"100 psig or more.\" This should be included in our list of minor corrections to make on the\nregulations.\nSigned\nFrank E. Fulton\n\n<<<PAGE 2>>>\n\nState of Indiana\nPublic Service Commission\n901 State Office Building\nSeptember 30, 1971\nMr. Walter Kurylo\nDirector, States Program\nOffice of Pipeline Safety\nWashington, D.C. 20590\nDear Mr. Kurylo:\nRe: Sections 192.511, 192.509\nHere are two cases where the test pressure may be less than the operating pressure, and technically meet the\nrequirements of the regulations. Should not these be reconsidered?\nParagraph c), Section 192.511, states a service line that is intended to be operated at more than 40 psig must\nbe tested to at least 90 psig, and if operated at a pressure above 20 per cent SMYS must meet the\nrequirements of Section 192.507. Thus, a line that is operated between 90 psig and 20 per cent\nSMYS would be required to be tested to only 90 psig---or the test pressure would be less than the operating\npressure.\nLikewise, in Section 192.509, a line that is to be operated between 90 and 100 psig is required to be tested to\nonly 90 psig.\nVery truly yours,\nD.J. Hendrickson\nDirector, Pipeline Safety Division\n\n<<<PAGE 3>>>\n\nUnited States Government\nDepartment of Transportation\nOffice of The Secretary\nMEMORANDUM\nDATE: November 1, 1971\nSUBJECT: Indiana Public Service Commission ltr 9-30-71\nRe: Sections 192.511 and 192.509\nFROM: Paul Cory\nTO: Frank Fulton\n192.509 Test requirements for pipelines to be operated at or below 100 psig, would indeed permit\noperation of a pipeline up to 100 psig with only a 90 psig test and would be the only situation where the\noperating pressure could be higher than the test pressure but this test is not a strength test anyway but rather\na leak test. In considering the comments on this paragraph and the professed problems with getting 100 psig\nwe reasoned that the chances of a leak showing up at 100 psig that would not show up at 90 psig were nil.\nThe restrictions of 192.619 Maximum allowable operating pressure: steel or plastic pipelines, apply to\nall other pipelines that would be covered under Sections 192.505, 192.507, 192.511 and 192.513, therefore\nthere are no other situations that would permit the operation of a line at a pressure that was in excess of the\ntest pressure .","truncated":false,"body_characters":4109}