{"operation":"document","citation":"PI-74-0125","title":"Florida Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-07-18","effective_on":null,"summary":"PI-74-0125 response to Florida Public Service Commission concerning 192.63.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0125.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0125.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0125","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-07-18_Batten_192.63-lmx.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0125\nJuly 18, 1974\nMr. Charles H. Batten\nDirector, Safety Department\nFlorida Public Service Commission\n700 South Adams Street\nTallahassee, FL 32304\nDear Mr. Batten:\nPursuant to my conversation with a member of your staff, I am enclosing a subsequent interpretation to the\ninterpretation which was included in our Advisory Bulletin no 74-5. I hope this interpretation will clarify and answer the\nspecific comments contained in your letter of June 7, 1974.\nIf you need further clarification in this matter, please let us know.\nSincerely,\nSIGNED\nCesar DeLeon\nDeputy Director\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nMarch 18\nMr. Stephen C. Stinson\nMiddle Tennessee Natural Gas\nUtility District\nP.O. Box 231\nSmithville, Tat 37166\nDear Mr. Stinson:\nThank you for your letter to Mr. Frank Fulton of February 12, 1974. In response to the questions you ask, we offer the\nfollowing:\nQuestion: In section 192.63 you say each piece of pipe must be marked. What happens when this is covered by coating?\nAnswer: The intent of the regulation is that the product, pipe, fitting, etc., must be clearly identified from point of\nmanufacture to installation. Where pipe is coated before installation, covering the parking, the coated pipe must be\nremarked unless some other means of identification permitted by section 192.63 is used.\nQuestion: If the specifications of the pipe are listed on the bill of lading and the original purchase order, is a blanket\nidentification sufficient?\nAnswer: A blanket identification where permitted under section 192.63 is sufficient only if the items involved are clearly\nidentified from point of manufacture to installation, as when all items so identified are used at a single installation.\nWhere individual items covered by a blanket identification are used separately, each item must be marked exclusive of\nthe blanket identification.\nQuestion: How have people maintained marking that was put on the coating? As you know, ultra violet light attacks PVC\nand ink on it. Do you require identification to be maintained on coal tar? If so, how do you identify field coated pipe?\nAnswer: For coated pipe in short term storage or protected storage, a marking on the coating or coating wrapper will\nnormally remain legible until installation. For coated pipe in long term storage, marking is usually maintained by painting\nthe pipe inside each end. Also, some operators paint a color code on pipe. It is an operator's responsibility to use\nmarkings that will identify material until it is installed. Section 192.63 does not require that markings be maintained\nafter installation, but materials used in any segment of pipeline must be identifiable for the life of the facility to ensure\nproper operation and maintenance. This is accomplished by maintaining appropriate records.\nWe hope that this sufficiently answers your questions. If we may assist further, please let us know.\nSincerely,\nOriginal signed by:\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 3>>>\n\nFlorida Public Service Commission\n700 South Adams Street\nTallahassee 32304\nJune 7, 1974\nMr. J. C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\n400 Seventh Street, SW\nWashington, D. C. 20590\nRe: Advisory Bulletin 74-5\nDear Mr. Caldwell:\nUpon reading the interpretation contained in the referenced \"Advisory Bulletin\", I have studied in detail Section 192.63\nand have the following comments:\n1. It can be seen how the interpretation was developed by reading the words contained in Section 192.63,\nbut one would have to ignore the intent when this regulation was developed.\n2. It can also be seen how the interpretation could have been made to require marking only as prescribed\nwithin the applicable standard by reading the same words and this interpretation would be backed up\nby the intent as well as existing practice. This way individual lengths under certain sizes would not\nrequire marking except by bundle.\n3. Our experience shows that we are just now getting through to the coating mills that pipe delivered to\nsystems in this State must be marked according to the specification under which the pipe was manu-\nfactured. We have been informed that with the shortage of steel that they do not need to sell pipe in\nthis State if we insist upon marking. In other words, they will sell to companies in states that are not\nenforcing the regulations.\n4. For us to enforce this new interpretation, we will have to install something other than steel pipe or the\nuser will have to mark the pipe when he breaks a bundle of small diameter pipe and order pipe only in\nfull bundles. This does not cause any insurmountable problem if the company can get steel pipe; but the\nmajority of companies use only one specification pipe, thus this added marking serves no useful\npurpose. Your interpretation leaves no latitude for this type operation and thus is overly restrictive.\nEnforcement of the marking requirement in some of the states places systems in an untenable position already, but this\nnew interpretation makes for an overly restrictive requirement and for those systems which purchase under one\nspecification, this added requirement accrues no benefit.\nWe ask that your office reconsider the interpretation so as to make marking required only as set forth in the\nspecification of manufacture or at least provide flexibility for systems which purchase only under one specification.\nSincerely yours,\nCharles H. Batten Director\nSafety Department\n\n<<<PAGE 4>>>\n\nOPS Advisory Bulletin No. 74-5 May, 1974 page4\nOIL & GAS JOURNAL, February 4, 1974, “Canada, U.S. Pipeliner Set Sights on Big arctic Projects,” Jim\nWest, Mid-Continent Editor; February 11, 1974, “Exxon Completes 32-Line River Crossing,” Robert C.\nEwing, Pipeline Editor; February 25, 1974, “In-House Testing Program for Gas Lines pays off,” Staff\nReport; “Watch for AC-Induced Interference on Lines,” Gharles G. Siegrfied, Ebasco Services, Inc.\nPIPELINE & GAS JOURNAL, Handbook Issue, March 15, 1974, “Minimum Federal Safety Standards for\nLiquid Pipelines,” “Minimum Federal Safety Standards for Gas Lines,” “Leak Reporting Requirements for\nGas Lines,” Reprints of OPS Regulations.\nPIPE LINE NEWS, March 1974, “Multiple Output Rectifiers for Pipelines,” Tom P. Wilkinson, Good-All\nElectric, Inc.; “Pipe Line News Annual Corrosion Symposium,” Oliver Klinger, Jr., Editor.\nPIPELINE AND UNDERGROUND UTILITIES CONSTRUCTION, March 1974, “Big Three Automatic Welders\nTested on Oklahoma Line,” William R. Quarles, Editor.\nGAS INDUSTRIES—Natural Gas Edition, March 1974, “New Life for Old Service Mains,” George F.\nSteinmetz, Jr., Baltimore Gas and Electric Company.\nMATERIALS PERFORMANCE, March 1974, “Corrosion Control in Idle Pipelines,” J.P. Fraser, Shell\nDevelopment Company; “On IR Drops, “ J.B. Lankes, Virginia Electric & Power Company.\nENERGY PIPELINES AND SYSTEMS (nee Gas Magazine), March 1974, “Industry Usage of Plastic Pipe\nContinues to Grow, “ Ken Kridner, Editor.\nAMERICAN GAS ASSOCIATION MONTHLY, March 1974, “Gas Pilot Lights—Extinguishing Top Burner Pilot\nLights Would Create a Safety Hazard.”\nINTERPRETATIONS OF REGULATIONS\nRelates Question: does the intent of Section 192.63 require marking of individual lengths of pipe removed\nto 49 CR2, from a bundle and installed separately?\n§.192.63\nOPS Interpretation: . . . ”Under L092.63, pipe must be clearly identified from point of manufacture to\ninstallation. In the case of bundle marked pipe, this requirement is satisfied where the bundle is used at\na single installation. However, if lengths of pipe are taken Out of the bundle and used at separate\ninstallations, each length removed must he marked exclusive ct the bundle marking to comply with the\nrequirement.\"\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nThe Secretary of Transportation has determined that publication of this periodical is necessary in the\ntransaction of the public business required by law of this Department. Use of funds for printing this\nperiodical has been approved by the Director of the Office of Management and Budget through\nNovember 30, 1976","truncated":false,"body_characters":8092}