{"operation":"document","citation":"PI-76-0102","title":"Pipeline Safety Interpretation PI-76-0102","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-04-02","effective_on":null,"summary":"PI-76-0102 concerning 192.14.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0102.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0102.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0102","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/g76-04-02_HARDIN_192.14%20-%20nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-76-0102\nApril 2, 1976\nMr. E. P. Hardin, President\nMobil Pipe Line Company\nP.O. Box 900\nDallas, Texas 78222\nDear Mr. Hardin:\nThis refers to your letter of November 17, 1975, addressed to our Houston office, concerning a 14-mile section of\npipeline previously used to transport liquid commodities which Mobil now plans to use for the transportation of ethylene\ngas. Your letter outlines several planned changeover procedures and indicates that the section will meet the operation,\nmaintenance, and related recordkeeping requirements of 49 CFR Part 192. (Because the line is described as \"100% under\ncathodic protection,\" we presume that Mobil also intends for it to meet the corrosion control requirements of Part 192.)\nYou ask for our concurrence that the changeover procedures mentioned in your letter will satisfy all requirements of this\nDepartment applicable to converting the section from liquid to gas service.\nThe Department's safety regulations for gas pipeline in 49 CFR Part 192 do not provide specific procedures for\nconverting a pipeline from liquid to gas service. However, Section 192.13(a) provides that \"No person may operate a\nsegment of a pipeline that is readied for service after March 12, 1971, unless that pipeline has been designed, installed,\nconstructed, initially inspected and initially tested in accordance with this part.\" The effect of this regulation is to make\nPart 192 fully applicable to the 14-mile section as soon as it is placed in operation. Just as if it were a new pipeline, the\n14-mile section would have to comply with applicable materials, design, installation, construction, and testing\nrequirements in addition to the corrosion, operation, maintenance, and recordkeeping requirements mentioned above.\nWe regret that we are unable to give the concurrence which you requested because the procedures outlined in your letter\ndo not indicate that Mobil is taking steps to bring the pipeline into compliance with all applicable requirements of Part\n192. The procedures should provide for a complete evaluation of the 14-mile section to determine what actions are\nnecessary to ensure full compliance at the time of operation.\nWe recognize the difficulty in bringing an existing pipeline into compliance with many of the regulations applicable to\nnew pipelines. Therefore, Mobil may wish to file a petition for a waiver from compliance with one or more of the\nregulations. Section 3(e) of the Natural Gas Pipeline Safety Act of 1968 (49 USC 1672(e)) provides that \"Upon\napplication by any person engaged in the transportation of gas or in the operation of pipeline facilities, the Secretary (of\nTransportation) may, after notice and opportunity for hearing and under such terms and conditions and to such extent as\nhe deems appropriate, waive in whole or in part compliance with any standard established under this Act, if he\ndetermines that a waiver of compliance with such standard is not inconsistent with gas pipeline safety.\" A petition should\nstate with respect to each regulation for which a waiver is sought, why the regulation is not appropriate, why the public\ninterest would be served by granting the waiver, and why the waiver would not be inconsistent with gas pipeline safety.\nWe trust that our response is helpful to you.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations","truncated":false,"body_characters":3366}