{"operation":"document","citation":"PI-71-057","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-06-04","effective_on":null,"summary":"PI-71-057 response to Memo: Internal concerning 192.611, 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-057.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-057.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-057","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/PI71057.pdf","body":"<<<PAGE 1>>>\n\nSUBJECT: Interpretation of section 192.619(c)\nFROM: TGC-20\nTO: TSA-32\nYou have asked for an opinion on the effect the \"grandfather\" clause in\n§192.619(c) vis-a-vis the requirements in §§192.607 and 192.611 that an MAOP\nof a pipeline which is not commensurate with its present class location must be\nconfirmed or revised in accordance with §192.611.\nWhen Part 192 was issued, the preamble indicated the primary purpose of the\n\"grandfather\" clause was to avoid reductions of the existing MAOP's because the\npipeline was only tested to 50 p.s.i.g. above MAOP or because the pipeline was\noperated at pressures above the design stress levels permitted under §192.619(a).\nHowever, the right conferred by this \"grandfather\" clause are somewhat\ncircumscribed by the phrase \"subject to the requirements of §192.611\".\nSection 192.611 was derived from provision in the ANSI B31.8 Code (850.42)\nwhich was specifically limited to pipelines in Class 2, 3, or 4 locations. Although\nthis limitation was not included in section 192.611, we note that the provisions of\nthat section can only be meaningfully applied to pipelines in Class 2, 3, or 4\nlocations. Nowhere in this section is there a reference to a pipeline in a Class 1\nlocation.\nTherefore, it is our opinion that pipelines in Class 2, 3 and 4 locations must have\ntheir operating pressures confirmed or revised in accordance with section 192.611.\nHowever, pipelines in Class 1 locations operated at pressures which are not\ncommensurate with that class location, based on the design stress levels of section\n192.619(a)(1), may continue to operate at their previous MAOP under the\n\"grandfather\" clause of section 192.619(c). In answer to your specific questions --\nthe first pipeline could continue operations at the stress level of 75% of SMYS;\npressure in the second or third pipeline would have to be confirmed or revised in\naccordance with section 192.611.\nWilliam D. Broderick\nDB\nC:\\WP51\\INTERPRT\\192\\619\\71-06-04.N\n1","truncated":false,"body_characters":1977}