{"operation":"document","citation":"PI-77-0108","title":"Pipeline Safety Interpretation PI-77-0108","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-12-12","effective_on":null,"summary":"PI-77-0108 concerning 192.555.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-0108.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-0108.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-0108","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/g77-12-12_Kent_192.555-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-77-0108\nDecember 12, 1977\nMr. Charles H. Kent\nSupervising Engineer\nPanhandle Eastern Pipe Line Company\nP.O. Box 1348\nKansas City, Missouri 64141\nDear Mr. Kent:\nWe apologize for the unusual delay in responding to your inquiry about the appropriateness of applying\nsection 192.555 instead of section 192.557 when lateral transmission lines are up rated to stress levels below\n30 percent of SMYS.\nAs your letter clearly points out, many of the requirements of section 192.557 for up rating pipelines to\nstress levels below 30 percent of SMYS are more stringent than the ones for pipelines being up rated to high\nstress levels. We believe this distinction was made because most of the lower stress level pipelines are in\ndistribution systems where there is a greater risk to public safety. However, since the requirements\nthemselves do not distinguish between distribution and transmission lines, there may be some unnecessary\nprocedural restrictions placed on up rating lateral transmission lines to low stress levels.\nIn the future, as part of our regulatory reform policy, we will be reviewing the up rating requirements to see\nwhat changes may be necessary. Meanwhile, if you feel that the existing requirements are creating a\nhardship in a particular situation, you may file a petition for a waiver as provided in section 3(e) of the\nNatural gas Pipeline Safety Act of 1968 (49 USC 1672 (e)).\nSincerely,\nSIGNED\nCesar DeLeon\nActing Director\nOffice of Pipeline Safety Operations\n\n<<<PAGE 2>>>\n\nPanhandle eastern Pipe Line Company\nP.O. Box 1348\nKansas City, Missouri 64141\nMay 13, 1977\nMr. Cesar DeLeon, Acting Director\nOffice of Pipeline Safety Operations\nMaterials Transportation\nBureau Department of Transportation\n2100 Second Street, S.W.\nWashington, D.C. 20591\nRe: Federal Pipeline Safety Regulations Sections 192.555 and 192.557 Up rating Pipelines.\nDear Mr. DeLeon:\nThe wording of Section 192.557, up rating of lines that operate at less than 30 percent of SMYS,\nindicates that the requirements are mainly applicable to distribution mains; however, there are a great many\nsmall diameter transmission lines supplying distribution systems which operate at pressures up to 700 or 800\npsig and still have hoop stresses less than 30 percent of SMYS. It seems that the requirements of 192.555 would\ndie much more applicable and reasonable when up rating these lateral lines.\nParagraph 192.555(c) allows an operator to use a previous test or high operating pressure as the\ntest pressure on which to apply the factors of 192.619 in determining the pressure to which a line can be up\nrated. Is this same procedure available for lines operating below 30 percent SMYS.\nParagraph 192.555(d)(1) allows an operator to test in accordance with Subpart J to establish an up\nrated MAOP. Is this procedure available for lines operating below 30 percent SMYS?\nIf a line is tested in accordance with Subpart J and a new MAOP established, is it necessary to\nincrease the operating pressure in increments when the line is put back in service? This is not required when a\nline operating above 30 percent SMYS is up rated in accordance with 192.555(d)(1).\nYour consideration of these questions will be appreciated.\nYours truly,\nChas. H. Kent, Supervising Engineer","truncated":false,"body_characters":3260}