{"operation":"document","citation":"PI-77-0100","title":"Pipeline Safety Interpretation PI-77-0100","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-01-07","effective_on":null,"summary":"PI-77-0100 concerning 192.11.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-0100.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-0100.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-0100","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/g77-01-07_Ashler_192.11-lmx.pdf","body":"<<<PAGE 1>>>\n\nPI-77-0100\nJanuary 7, 1977\nMr. Philip F. Ashler\nState Treasurer\nState Fire Marshal\nTallahassee, Florida 32304\nYour letter of October 4, 1976, to Webster B. Todd, Jr., Chairman, National Transportation Safety Board, indicated that\nthe Bureau of LP Gas does not consider LP gas containers jurisdictional under 49 CFR Part 192.\nA recent interpretation of the term “system” in connection with the regulation of petroleum gas systems under 49 CFR\n192.11, published in the October issue of the OPSO Advisory Bulletin (copy enclosed), includes tanks storing petroleum\ngas in liquid form as being part of a petroleum gas system regulated by 49 CFR 192.11\nWe trust this interpretation clarifies any misunderstanding of the scope of jurisdiction of Part 192 over LP gas\ncontainers. Mr. Todd is also being advised of the interpretation.\nSincerely,\nSIGNED\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\n\n<<<PAGE 2>>>\n\nPhilip F. Ashler\nTreasurer of Florida\nTallahassee 32304\nOctober 4, 1976\nMr. Webster B. Todd, Jr.\nChairman\nNational Transportation Safety Board\nWashington, D.C. 20594\nMy dear Mr. Todd:\nYour letter of September 21, 1976, regarding the matter of LP gas containers connected to OPS jurisdictional systems\nhas been reviewed by Mr. Earl Kicliter, LP Gas Bureau Chief. Mr. Mater does recall a conversation with Mr. Charles\nBatten of the Office of Pipeline Safety regarding such matter; however, Mr. Kicliter does not recall having stated the LP\ngas containers were jurisdictional by the provisions of Title 49, Part 192, and in fact, Mr. Kicliter pointed out that the\nfederal regulations do not address the subject of LP gas storage containers except by reference to NFPA Pamphlet 56.\nMr. Kicliter reminds me the Bureau of LP Gas has, since its inception in 1957, had the jurisdictional responsibility for a\ngas containers and the NITA Pamphlet 5$ is the adopted code for this area of LP gas container safety.\nThis office does not consider the LP gas containers jurisdictional under Title 49, Part 192, and / hope this will help clarify\nany misunderstand.\nWith kindest personal regards.\nSincerely,\nPhilip P. Ashler\nState Treasurer\nState Fire Marshal\n\n<<<PAGE 3>>>\n\nAdvisory Bulletin No. 76-10 October 1976\nRelates to 49 CFR, Part 195, Subpart D\nNOTICES UPDATE DEVELOPMENTS ON TRANS-ALASKA WELD PETITIONS AND ANNOUNCE PUBLIC HEARING...On October\n6, 1976, the Office of Pipeline Safety Operations (OPSO) issued Notice 4-in Docket No. 76-12W (41 Fed. Reg. 44207,\nOctober 7, 1976), advising that additional technical information had been placed in the Docket which included a\npreliminary report on the National Bureau of Standards (NBS) analysis and assessment of (i) fracture mechanics as that\nanalytical technique may be applicable for determining the effect of defects in girth welds on the structural integrity of\nthe Trans-Alaska pipeline system and the alternative maximum allowable weld defect sizes proposed by Alyeska Pipeline\nService Company, (ii) weld defect and arc burns sizes submitted by Alyeska in support of its petition for exemptions from\ncertain welding requirements of 49 CFR Part 195 for individual welds in the main line pipe of the Trans-Alaska pipeline\nsystem, and (iii) methodologies for measuring the depth of those defects and arc burns. The Notice also advised that\nthe Docket has been reopened to receive additional written comments until the close of business on October 28, 1976,\nand that the Deputy Secretary of Transportation will conduct a public hearing on this matter commencing at 8:30 a.m.,\nThursday, October 28, 1976, in the third floor auditorium of Federal Building 10A at 800 Independence Avenue, S.W.,\nWashington, D.C.\nThe informal hearing on October 28 will be for the purpose of receiving the views of interested persons as to (1)\nwhether a fracture mechanics analysis can properly serve as an alternative to the standards set forth in Subpart D of 49\nCFR Part 195 for determining the integrity of girth welds in the main line of the Trans-Alaska crude oil pipeline system\nand (2) if so, whether the docketed technical information provides a valid basis for applying a fracture mechanics\nanalysis to the particular girth welds for which Alyeska seeks waivers of the 49 CFR standard. Public participants will be\npermitted a maximum of 15 minutes for each presentation. Written copies of presentations are requested but not\nrequired. Persons desiring to make presentations at the hearing should write to or telephone the Docket Clerk (Ms.\nPeggy Hammond), Office of Pipeline Safety Operations (Alyeska Docket No. 76-12W), 2100 Second Street, S.W.,\nWashington, D.C. 20590 (telephone 202-426-0135) to be received not later than noon, Tuesday, October 26, 1976,\ngiving the following information: (1) Name; (2) Address; (3) Phone number during normal working hours; (4) Capacity in\nwhich presentation will be made (e.g., private citizen, public interest group, or public official); (5) Position--pro or con on\neach of the two issues stated above; and (6) Time (maximum 15 minutes) desired for presentation.\nOn October 21, 1976, Notice 5 in Docket No. 76-12W was published in the Federal Register announcing the receipt and\ninclusion in the Docket of the final report on the NBS analysis and assessment.\nTAYLOR TO HEAD DOT ONSITE ALASKA MONITORING TEAM...Marshall W. Taylor, II, Chief of the Office of Pipeline Safety\nOperations' Central Regional Office, will head the Department's onsite monitoring team along the Trans-Alaska pipeline.\nDeputy Secretary of Transportation John W. Barnum announced recently. The team was sent to Alaska in July to\nmonitor all aspects of the construction of the pipeline for the remainder of the 1976 construction season to assure that\nthe pipeline is constructed in accordance with DOT regulations.\nThe five-member monitoring team is composed of two U.S. Coast Guard radiographic specialists and three DOT OPSO\ncompliance inspectors. A third U.S. Coast Guard radiographic specialist will be assigned if necessary to provide\nadditional capability to evaluate the adequacy of the radiographic records of the pipeline girth welds made in the field\nduring the 1975 construction season. The team is also charged with the task of assessing the adequacy of the Alyeska\nPipeline Service Company's remedial program to repair all welds that have been identified as having defects in excess of\nthe DOT standards.\nMTB DIRECTOR ADDRESSES GAS ASSOCIATION ANNUAL MEETING…On October 11, 1976, James T. Curtis, Jr., Director,\nMaterials Transportation Bureau (MTB), discussed current Federal pipeline safety activities and their relationship to\nfuture gas industry goals before the annual meeting of the American Gas Association in Los Angeles, California. The\nBureau Director summarized the first year of development of the MTB and activities of OPSO. Also discussed were the\nrecent amendments to the Federal gas pipeline safety standards; regulatory activities relating to importation of liquefied\nnatural gas; Arctic gas pipeline technology and specialized safety regulations; offshore pipeline safety amendments to\n\n<<<PAGE 4>>>\n\nthe regulations; DOT and State sponsored gas pipeline safety training courses and seminars; and some thoughts about\nprobable future MTB and OPSO programs.\nRelates to 49 CFR, §192.455\nMTB PROPOSES TO AMEND GAS PIPELINE SAFETY STANDARDS RELATING TO CORROSION CONTROL FOR SMALL METAL\nFITTINGS IN PLASTIC PIPELINES...On September 22, 1976, the OPSO Acting Director issued Notice 76-1, Docket No.\nOPSO-37, in which the MTB proposes to amend the external corrosion control requirements of 49 CFR Section 192.455\nwith regard to alloy metallic fittings that are part of plastic pipelines. Under the existing .Section 192.455, any metallic\nfitting which is part of a plastic pipeline must be coated and cathodically protected in accordance with applicable\nrequirements unless the operator of the pipeline can demonstrate by certain tests, investigation, or experience in the\narea of application that a corrosive environment does not exist, or for a temporary installation of five years or less, that\ncorrosion of the fitting will not be detrimental to public safety. However, when an installation intended to last more\nthan five years is made without cathodic protection, the operator is required to make electrical tests within six months\nafter the installation to adequately evaluate the fitting and apply cathodic protection if a corrosive condition is found.\nThereafter, Section 192.465 requires that if a metallic fitting in a plastic pipeline is not protected under Section 192.455,\nit must be reevaluated every three years by electrical tests or other allowable methods and cathodically protected\nwhere active corrosion is found.\nIn a petition for rulemaking (Docket No. Pet. 74-15), the fitting supplier argues that the application of cathodic\nprotection to short fittings with metallic parts made of Type 316 stainless steel is not necessary for safety when the\nfittings are in an otherwise all plastic pipeline and provided data in support of - its position. In light of technical\ninformation made available, MTB is proposing that Section 192.455 be amended to allow the installation of small,\nelectrically isolated alloy fittings in plastic pipelines without coating and cathodic protection if (1) an operator can show\nby tests, investigation, or experience in the area of application, that corrosion control is provided by alloyage, and (2) the\nfitting is designed to prevent leakage caused by localized corrosion pitting.\nInterested persons are invited to participate in this rulemaking action by submitting such written data, views, or\narguments as they may desire. Communications should identify the regulatory docket and notice numbers and be\nsubmitted in triplicate to the Director, Office of Pipeline Safety Operations, Department of Transportation, 2100 Second\nStreet, S.W., Washington, D.C. 20590. All communications received by November 1, 1976, will be considered before\nfinal action is taken on the notice. Late filed comments will be considered so far as practicable. All comments will be\navailable for examination by interested persons at the Office of Pipeline Safety Operations before and after the closing\ndate for comments. Reprints of the notice (41 Fed. Reg. 42221, September 27, 1976) have been sent to those on the\nappropriate OPSO mailing lists.\nRelates to 49 CFR, §192.313 and §195.212\nMTB PROPOSES TO AMEND GAS AND LIQUID PIPELINE SAFETY STANDARDS CONCERNING BENDING PIPE HAVING\nLONGITUDINAL SEAMS...On October 18, 1976, the OPSO Acting Director issued Notice 76-2, Docket No. OPSO-38, in\nwhich the MTB proposes to amend Section 192.313(a)(4) of the Federal gas pipeline safety standards and Section\n195.212(b)(3) of the Federal liquid pipeline safety standards to except bends made with an internal bending mandrel\nfrom the requirement that for field bends of steel pipe containing a longitudinal weld, the weld must be as near as\npracticable to the neutral axis of the bend. The notice is based, in part, on a petition dated October 18, 1975, by the\nAlyeska Pipeline Service Company (Pet. 76-11W) requesting that the pipe bending requirement of 49 CFR 195.212(e)\n(now §195.212(b)(3)) be repealed and, in the interim, that Alyeska be granted a waiver from compliance with the\nrequirement with respect to the Trans-Alaska crude oil pipeline.\nInterested persons are invited to participate in this rulemaking action by submitting such written data, views, or\narguments as they may desire. Communications should identify the regulatory docket and notice numbers and be\nsubmitted in triplicate to the Director, Office of Pipeline Safety Operations, Department of Transportation, 2100 Second\nStreet, S.W., Washington, D.C. 20590. All communications received by November 8, 1976, will be considered before\nfinal action is taken on the notice. Late filed comments will be considered so far as practicable. Reprints of the notice\n\n<<<PAGE 5>>>\n\n(41 Fed. Reg. 46463, October 21, 1976) are being sent to those on the appropriate OPSO mailing lists.\nRelates to 49 CFR, §195.218\nRIVER CROSSING WAIVER GRANTED TO TRANS-ALASKA PIPELINE...On September 1, 1976, the MTB granted a waiver to\nAlyeska from compliance with the to welding requirement of 49 CFR 195.218 with respect to girth weld No. 49344T at\nthe completed Jim River Crossing No. 2 on the Trans-Alaska crude oil pipeline. The girth weld serves to tie in two\nsections of 48-inch concrete coated pipe in the 620-foot crossing. Section 195.218 requires that longitudinal weld seams\non adjacent lengths of pipe must be offset. However, at weld No. 49344T, the seams on adjacent pipe lengths are\nabutting, not \"offset\" as required. MTB reviewed the information and arguments submitted by Alyeska in connection\nwith its petition and found that the requested waiver is not inconsistent with pipeline safety and is in the public interest.\nThe reasons cited for this decision are quality of girth weld; ductility of the pipe and girth weld metals which would\nprovide for localized yielding where high residual stresses may exist; mechanical properties of the girth weld and pipe\nmetals minimize the likelihood of any concentration of residual stresses existing at the intersection of welds and\nsurrounding heat-affected zone; longitudinal seams are ground flush with the inside pipe circumference at the joint\nmitigating the likelihood of any concentration of residual stresses caused by excess metal at the intersection of welds;\nand replacing weld No. 49344T to comply with Section 195.218 could reduce the pipeline's integrity because of the\ndifficulties in cutting out a segment of the concrete coated crossing and rotating and realigning it in the river crossing.\nAccordingly, effective September 1, 1976, Alyeska was granted a waiver from compliance with 49 CFR 195.218 with\nrespect to weld No. 49344T at the Jim River Crossing No. 2 on the Trans-Alaska crude oil pipeline (41 Fed. Reg. 38202,\nSeptember 9, 1976).\nIOWA COMMISSION SEEKS UTILITY REGULATION ENGINEER...The Iowa State Commerce Commission has an immediate\nopening for a Utility Regulation Engineer III in its gas safety and service program. Minimum requirements for the\nposition are a B.S. degree in engineering; four years experience in the area of gas utility regulation with a State or\n.Federal regulatory agency; and possession of a certificate of registration as a Professional Engineer issued by the State\nof Iowa, or equivalent. Salary range is $17,524 to $24,648. Resumes and inquiries should be directed to Dean A. Briley,\nExecutive Secretary, Iowa State Commerce Commission, 300 - 4th Street, Des Moines, Iowa 50319, telephone (515) 281-\n5256.\nUTILITY LOCATION AND COORDINATION WORKSHOPS SCHEDULED FOR NEW YORK AND FLORIDA...The American Public\nWorks Association (APWA) announces that its next series of Utility Location and Coordination Council (ULCC) workshops\nare scheduled to be held in New York City on November 16 and 17, 1976, at the Sheraton Inn, LaGuardia Airport, and on\nNovember 18 and 19, 1976, in Orlando, Florida, at the Sheraton Olympic Villas. Topics for the workshops include need\nfor coordination, the national ULCC program, how to form a new committee, standardized field markings, standardized\ndamage reports, developing utility location standards, computer assisted mapping and records, permit and record\nsystems, one-call excavation notification systems, and related topics. Fees for the workshops for APWA members (and\nothers qualifying) are $85; nonmembers, $100. For further information and registration, contact C. Richard Kuykendall,\nAmerican Public Works Association, 1313 East 60th Street, Chicago, Illinois 60637, telephone (312) 947-2523.\nSOUTHERN STATE AGENCY PIPELINE SAFETY LEADERS MEET...Gas pipeline safety\nliaison representatives from State agencies in OPSO's Southern Region held their second annual 2-day meeting in\nAtlanta, Georgia, on October 5-7, 1976. Representatives of all eight States in the Southern OPSO Region attended the\nFederal/State coordination sessions. Safety regulatory topics discussed in the meeting included LNG facilities, corrosion\ncontrol, the Federal grant program, streamlining of Federal report forms, and an update on Federal regulations and\ntechnical studies. The new Southern Regional Chairman is Lamar Cockrell of the Florida Public Service Commission, and\nthe Vice-chairman is James Stites of the South Carolina Public Service Commission. The 1977 Southern Region\nFederal/State meeting is tentatively scheduled for October in the Tampa, Florida, area.\nNTSB REPORTS ON MICHIGAN-WISCONSIN COMPRESSOR STATION FIRE...On June 23, 1976, the National Transportation\nSafety Board (NTSB) issued two safety recommendation letters on its investigation of a natural gas incident which\noccurred near Cedardale, Oklahoma, on January 7, 1976. As work was nearing completion on the addition of\ncompressor facilities, employees at the Michigan-Wisconsin Pipe Line Company's Cedardale, Oklahoma, compressor\n\n<<<PAGE 6>>>\n\nstation were directed to open a valve on a shut-in 12-inch gas-gathering pipeline in an attempt to increase the flow into\nthe main line. Natural gas and natural gas liquids at 700-psig pressure passed through the valve, out through the end of\nan open 12-inch pipe, and into a ditch, where seven men were working near an open flame heater. The natural gas\nliquids saturated their clothing, and the flame from the heater set them on fire. \"Five men were killed and two men\nwere burned seriously as a result of this accident.\nThe NTSB recommended that Michigan-Wisconsin Pipe Line Company, operator of the system, initiate immediate action\nto conduct periodic training programs on the importance of following written procedures covering such situations;\nexamine procedures for valve and piping changes to assure that each critical action is checked appropriately; and\nprohibit such changes, except in emergencies, while construction is conducted nearby. The NTSB also recommended\nthat the Interstate Natural Gas Association of America stress the importance of following such written procedures to\ntheir member companies.\nSingle copies of the letter reports (Safety Recommendations P-76-27 through 29 and P-76-26) may be obtained by\ndirecting a request to Publications Branch, BGM-222, National Transportation Safety Board, Washington, D.C. 20594,\ntelephone (202) 426-8169.\nRelates to 49 CFR, §192.11\nINTERPRETATION OF REGULATIONS\nQuestion: Under Section 192.11, what constitutes a petroleum gas system?\nOPSO Interpretation:...\"For the purpose of Section 192.11(a), a 'system' normally consists of a tank storing petroleum\ngas in liquid form and the appurtenant pipelines and other facilities used by the operator of the system to deliver gas to\none or more customers.”\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\nThe Secretary of Transportation has determined that publication of this periodical is necessary in the transaction of the\npublic business required by law of this Department. Use of funds for printing this periodical has been approved by the\nDirector of the Office of Management and Budget through November 30, 1976.","truncated":false,"body_characters":19179}