{"operation":"document","citation":"PI-76-013","title":"Brown & Root, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-03-26","effective_on":null,"summary":"PI-76-013 response to Brown & Root, Inc. concerning 195.1, 195.208.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-013.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-013.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-013","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76013.pdf","body":"<<<PAGE 1>>>\n\nMarch 26, 1976\nMr. Hines D. Lively\nManager, Piping Design\nBrown & Root, Inc.\nP.O. Box 3\nHouston, TX 77001\nDear Mr. Lively:\nThis is in response to your letter of January 21, 1976,\nrequesting information concerning the jurisdiction of the Federal\nstandards for the Transportation of Liquids by Pipeline, Part 195\nof Title 49 of the Code of Federal Regulations (Part 195), and\nthe ANSI B31.4, Code for Pressure Piping, Liquid Petroleum\nTransportation Piping Systems.\nUnder the Transportation of Explosives Act, 18 U.S.C. 831-835,\nthe Department of Transportation (DOT) has jurisdiction over\ncommon, contract, and private carriers engaged in interstate or\nforeign commerce who transport liquid hazardous materials by\npipeline. Safety regulations issued under 18 U.S.C. 834\ngoverning the design, construction, operation, and maintenance of\ninterstate liquid pipelines are published in Part 195.\nThe ANSI B31.4 code is an industry standard developed under the\ndirection of the American National Standards Committee B31\norganized under the procedures of the American National Standards\nInstitute, Inc., and is under the administrative sponsorship of\nthe American Society of Mechanical Engineers. ANSI B31.4 is\nenforceable as a Federal standard only for the specific\nparagraphs referenced in Part 195.\nThe following is our response to your specific questions:\nQuestion 1: Does a pipeline as shown in SK-1-20-76 fall under\nthe jurisdiction of DOT or only ANSI B31.4? Please answer\nseparately for sections A, B, and C as shown on sketch.\nSections A, B, and C would be subject to the regulations in 49\nCFR Part 195 only if they are used in the transportation of\nliquid hazardous materials by pipeline in interstate or foreign\ncommerce.\nThe electrical transmission line indicated in the lower part of\nSketch SK-1-20-76 is not a part of the pipeline and is not\nconsidered when the question of pipeline jurisdiction is\ndetermined.\ndal\\195\\208\\76-03-26\n1\n\n<<<PAGE 2>>>\n\n2\nQuestion 2: When DOT does apply does section 421 apply (which is\nnot even referred to by Title 49) or does section 195.208 apply?\nSection 421, Design of Pipe Supporting Elements, in ANSI B31.4\nhas not been referenced in Part 195 and is not applicable;\nhowever, Section 195.208, Welding of supports and braces, in Part\n195 is applicable.\nQuestion 3: If 195.208 applies, is nonintegral support\npreferred?\nThe regulations in Part 195 are for the most part performance\nstandards. Where a specific method is neither required nor\nexcluded then the operator has the responsibility of selecting a\nmethod of compliance that will conform with the appropriate\nstandards.\nQuestions 4: If not, can \"excess thickness\" be considered\nsufficient reinforcement is lieu of a \"cylindrical member\ncontinuously welded around the pipe.\"\nThis question is moot as the answers to questions 2 and 3\nindicate that Section 195.208 is applicable.\nANSI B31.4 is not a Federal standard unless it is specifically\nreferenced in Part 195. The Office of Pipeline Safety Operation\nconsiders it a useful guide, providing procedures that may be\nhelpful in complying with the performance requirements of the\nFederal standards. Any questions you might have relative to ANSI\nB31.4 should be directed to:\nSecretary\nAmerican National Standards Committee B31\nThe American Society of Mechanical Engineers\nUnited Engineering Center\n345 East 47th Street\nNew York, New York 10017\nWe appreciate your interest in pipeline safety. If you have any\nfurther questions, do not hesitate to call or write.\nSincerely,\ndal\\195\\208\\76-03-26\n2\n\n<<<PAGE 3>>>\n\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\nJanuary 21, 1976\nMr. Cezar [sic] DeLeon, Director\nOffice of Pipeline Safety\n2100 2nd St. Southwest\nWashington, D.C. 20590\nDear Mr. DeLeon:\nThe following questions were posed in a telephone conversation\nbetween Messrs. Hines Lively, Tom Cairns, and Frank Fulton of\nyour office on January 15, 1976. He requested we direct our\nquestions in writing to your office.\nItems needing further clarification:\n1. Scope of D.O.T. Jurisdiction (See sketch SK-1-20-76)\nDo facilities that are entirely ow ned by company \"X\"\nfall under DOT jurisdiction because other separate\nfacilities owned by same company affect interstate\ncommerce? If not, would they fall under B31.4?\n2. Regarding Title 49 Paragraphs 195.110 and 195.208:\nParagraph 195.110 refers t o Section 419 of USAS B31.4\n1966. We assume the 1974 version is valid at this\ntime. The reference is for expansion and flexibility\nprovisions, not design of pipe supporting elements.\nThe latter is found in section 421 which states \"(a)\nSupports shall be designed to support the pipe without\nimposing excessive local stresses in the pipe and\nwithout imposing excessive axial or lateral friction\nforces that might prevent the desired freedom of\nmovement.\"\nThe preceding does not eliminate directly welded sho es\n(see types A, B & C Sketch SK-1-19-76) especially if\nthey are free to move in both directions as shown in\ntype A and do not create excessive stresses. Therefore\nit probably would be wise to differentiate between\ndal\\195\\208\\76-03-26\n3\n\n<<<PAGE 4>>>\n\nsimple supports (downward restraint in minus y\ndirection), guides (restrained in one horizontal\ndirection x or z), or anchors (restrained in all\ndirection x, y, and z). One might deduce that the\nabove requirements are met in the case of simple\nsupports that the later reference to \"welding supports\nto a separate cylindrical member, continuous welded to\nJanuary 21, 1976\nPage 2\n3. pipe\" are aimed at guides and anchors. Section 421.1\n(c) also indicates a definite preference for\nnonintegral supports such as Type D SK-1-19-76.\nThe only reference to the encircling cylinder is\nproposed in the case of the line operating near its\nstress limit. This is not likely with modern design\nmethods and factors of safety.\nTherefore we conclude that if Section 195.110 does\nintend to include section 421 of B31.4 (which is the\nonly mention of the cylinder reinforcement) it must be\nsecond choice to the nonintegral attachment, and then\nonly necessary in the case of anchors and possibly\nguides. \"421.1 (c) All attachments to the pipe shall\nbe designed to minimize the added stresses in the pipe\nwall because of the attachment.\" 421.1 (c) suggests\nthat local stresses due to uneven application of weld\nheat may be the source of some objection to direct\nwelding of the pipe to the shoe. Since this would\ndepend somewhat upon the welding procedure and condi-\ntions and is therefore quantitatively unpredictable, it\nmay be a valid objection in the case of operating \"near\nthe stress limit\" but we fail to see how it applies to\nthe 100 psi range.\nWe feel the 100 psi must assume the pipe wall thickness\nis no greater than that which would be required under\nSection 402.3.2, .3, .4, and Section 404 B31.4 1974.\nSince without reference to wall thickness the pressure\nalone could not cause overstressing. In any case it\nstill would not eliminate the clamp type nonintegral\nsupport as shown in SK-1-19-76 type D.\nB31.4 recognizes the existence of \"excess wall\nthickness\" (see 404.3.1 (i)) in the calculations for\ndal\\195\\208\\76-03-26\n4\n\n<<<PAGE 5>>>\n\nbranch conns. This consists of any metal in excess of\nthat required for internal pressure, corrosion, mill\ntolerance, external loads, etc. due to the application\nof safety factors greater than required by the code\nand/or by selecting the nearest higher commercially\navailable pipe schedule. This would be equivalent to a\n\"cylindrical member which completely encircles the\npipe\" but would be much superior as reinforcement since\nit is integral to the pipe rather than merely\ncontinuously welded at the ends.\nJanuary 21, 1976\nPage 3\nOur question is: would the existence of such \"excess\nthickness\" constitute compliance with 421.1 if it meets\nthe conditions of 421.1(a).\nThe following is a summarization of the questions discussed in\nthe preceding paragraphs.\n1. Does a pipeline as shown in SK-1-20-76 fall under the\njurisdiction of DOT or only ANSI B31.4? Please answer\nseparately for sections A, B, and C as shown on sketch.\n2. When DOT does apply does section 421 apply (which is\nnot even referred to by Title 49) or does section\n195.208 apply?\n3. If 195.208, applies, is nonintegral support preferred?\n4. If not, can \"excess thickness\" be considered sufficient\nreinforcement in lieu of a \"cylindrical member\ncontinuously welded around pipe.\"\nNOTE: If answers are not true of anchors guides and\nsimple supports, please differentiate.\nWe would appreciate a reply at your earliest convenience.\nVery truly yours,\nHines D. Lively\nManager, Piping Design\ndal\\195\\208\\76-03-26\n5\n\n<<<PAGE 6>>>\n\nAttachments (2)\nSK-1-19-76\nSK-1-20-76\ndal\\195\\208\\76-03-26\n6","truncated":false,"body_characters":8709}