{"operation":"document","citation":"PI-76-017","title":"Herbert Schroeder, Jr. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-04-13","effective_on":null,"summary":"PI-76-017 concerning 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76017.pdf","body":"<<<PAGE 1>>>\n\nApril 13, 1976\nMr. Byrd L. Minter, Manager\nSealants Department\nFord, Bacon & Davis\nP.O. Box 1762\nMonroe, Louisiana 71201\nDear Mr. Minter:\nThis refers to your letter of March 26, 1976, in which you ask whether Section 192.619(c) or\nSection 192.621(a) governs the maximum allowable operating pressure of a steel distribution\npipeline with an inlet pressure of 170 psig.\nFor a steel or plastic high-pressure distribution pipeline the maximum allowable operating\npressure is governed by Section 192.619, subject to the applicable limitation of Section 192.621.\nUnder these requirements, a person may not operate a pipeline at a pressure permitted by Section\n192.619(c) if that pressure would exceed the applicable limitation of Section 192.621.\nIf we may be of further assistance, please let us know.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\192\\619\\76-04-13\n1\n\n<<<PAGE 2>>>\n\nMarch 26, 1976\nDOT Pipeline Safety Policy\nOffice of Safety Affairs\n400 7th Street SW\nWashington, DC 20590\nGentlemen:\nI need clarification regarding the maximum allowable operating pressure of a natural gas\ndistribution feeder line. The line is welded ERW and does not have any service lines connected to\nit. Elements of the system have been installed over the past thirty years. Elements were tested at\nvarying pressures between 100 psig and 275 psig. Two elements of the system have a different\nhistory, prior to July 1, 1970, of maximum operating pressure prior to their being connected and\nbecoming a continuous system.\nOne element of the system has a history of maximum operating pressure of less than 100 psig.\nAnother element of the system has a history of maximum operating pressure of approximately 150\npsig. Recently an element with a history of operating pressure of approximately 300 psig and test\npressure of 500 psig has become part of the system. The maximum inlet pressure to the system is\nnow approximately 170 psig.\nThe basic question is which section of the rule applies to this type of line (system), paragraph\n192.619 or 192.621. As I understand:\nIf 192.619 applies, then paragraph (c) governs the MAOP even though certain elements of\nthe system were only tested at a lower design pressure in accordance with (a)(2)(ii).\nIf paragraph 192.621 applies, and a design pressure in accordance with paragraph (a)(1) is\nless than the history of the maximum safe operating pressure, then paragraph (a)(1)\napplies.\nYour clarification of the interpretation of these two paragraphs would be appreciated as this is a\ntypical question that comes up many times during discussions of MAOP's of gas distribution\nfeeder lines operating in the less than 200 psig range.\nSincerely,\nByrd L. Minter, Manager\nSealants Department\ndal\\192\\619\\76-04-13\n2","truncated":false,"body_characters":2774}