{"operation":"document","citation":"PI-71-084","title":"Citizens Gas & Coke Utility — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-11-23","effective_on":null,"summary":"PI-71-084 response to Citizens Gas & Coke Utility concerning 192.509, 192.511, 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-084.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-084.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-084","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/PI71084.pdf","body":"<<<PAGE 1>>>\n\nNovember 23, 1971\nMr. D. J. Hendrickson\nDirector, Pipeline Safety Division\nIndiana Public Service Commission\n901 State Office Building\nIndianapolis, Indiana 46204\nDear Mr. Hendrickson:\nWe have now had an opportunity to have your letter of September 30, 1971, reviewed in detail by\nour Technical Division.\nWith regard to the two cases you mentioned you are correct in your statement relative to Section\n192.511(c) that in effect our regulations do not specify a test pressure above the desired operating\npressure for service lines operating in the range of 90 psig to 20 percent of SMYS. However, you\nmust refer to the requirement that is specified in Section 192.619(a)(2)(ii), as amended on\nNovember 10, 1970, copy enclosed. This specifies that in order to operate a pipeline at 100 psig\nor more, it must be tested according to the limits shown in the table incorporated in the\nregulations.\nThe test pressure for new lines to operate over 100 psig will always exceed the maximum\nallowable operating pressure according to the provisions of Section 192.619(a)(2)(ii). The only\nsituation where a test pressure of a new pipeline is less than the permitted operating pressure is\nfor a line that will operate between 90 and 100 psig. This variation was included based on strong\ncomments received during rule-making and on recommendation of the TPSSC. These claimed\nthat there was too much existing equipment designed for 100 psig. Since this is a leak test and\nnot a strength test, it was concluded that this would not derogate safety. The same reasoning\napplies to the test requirements in Section 192.509 for pipelines to operate at or below 100 psig.\nThere is a slight discrepancy existing in the regulations in that Section 192.509 states \"at or below\n100 p.s.i.g.\" while Section 192.619 (a)(2)(ii) states \"100 p.s.i.g. or more.\" This will be corrected\nin our next miscellaneous amendments to the regulations.\nDB/dal/192.509\n71-11-23\n1\n\n<<<PAGE 2>>>\n\nWe trust that this will answer your question. If you have any further questions, please feel free to\ncontact us.\nSincerely,\n/signed/\nJoseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\nDB/dal/192.509\n71-11-23\n2","truncated":false,"body_characters":2183}