{"operation":"document","citation":"PI-78-001","title":"Mountain Fuel Supply Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1978-01-04","effective_on":null,"summary":"PI-78-001 response to Mountain Fuel Supply Company concerning 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/PI78001.pdf","body":"<<<PAGE 1>>>\n\nJanuary 4, 1978\nMr. F. F. Bassani\nGas Engineer\nMountain Fuel Supply Company\nP.O. Box 1129\nRock Springs, Wyoming 82901\nDear Mr. Bassani:\nYou have asked our opinion on whether the installation of a\n10-inch branch connection on a 24-inch O.D., 0.281-inch wall, grade X-52 pipe in a Class 1 area,\nusing a hot tap and a split full encirclement saddle for reinforcement, would require a reduction in\nthe pipe's maximum allowable operating pressure (MAOP) of 850 psig. We apologize for the\nunusual delay in responding to your inquiry.\nUnder the applicable regulations governing MAOP in this situation (§192.619(a)(1), §192.13(b),\n§192.105, and §192.111), the pipe's MAOP would be reduced only if installing the 10-inch branch\nconnection \"changes\" the pipe within the meaning of §192.13(b) and, if it does, the hot tap with\nsplit saddle constitutes a \"fabricated assembly\" within the meaning of §192.111(d). We have not\naddressed the second issue because in our opinion installing the branch connection as you have\ndescribed would not \"change\" the existing pipe as intended by §192.13(b). Thus, the installation\nwould not require reassessment of the pipe's design under Subpart C and the MAOP prescribed by\n§192.619(a)-(c) likewise would remain the same.\nAlthough the term \"change\" is not defined in Part 192, since it is used in §192.13(b) in the same\ncontext as \"replace\" and \"relocate,\" a reasonable inference is that \"change\" means a substantial\nalternation of an existing pipeline. Ordinarily, a branch connection made by hot tap with\nreinforcement would not substantially alter the pipe to which it is attached. This view is\nsupported by §192.155 which specifically requires that a branch connection be designed \"to\nensure that the strength of the pipeline system is not reduced.\"\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\192\\619\\78-01-4\n1\n\n<<<PAGE 2>>>\n\nApril 27, 1977\nMr. Cesar DeLeon\nActing Director\nOffice of Pipeline Safety Operations\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. DeLeon:\nWe would like to have an official interpretation on the following question:\nWould the installation of a 10-inch hot tap on a 24-inch O.D., 0.281-inch wall, grade X-52\npipe in a Class I area using a split full encirclement saddle for reinforcement cause us to lower our\nmaximum allowable operating pressure of 850 psig?\nAttached is a copy of an interpretation received from\nMr. J. C. Overly, Chief of the Western Region, Office of Pipeline Safety Operations.\nBy using this method of installation, we would not have to blow any gas to atmosphere,\nand thereby conserve a valuable source of energy.\nAn early reply would be appreciated.\nVery truly yours,\nF. F. Bassani\nGas Engineer\nAttachment\ndal\\192\\619\\78-01-4\n2\n\n<<<PAGE 3>>>\n\nApril 21, 1977\nMr. Roy E. Spann\nMountain Fuel Supply Co.\nP.O. Box 1129\nRock Springs, Wyoming 82901\nDear Mr. Spann:\nI am writing in reply to your question raised at the industry seminar held in Casper, WY on April\n13 and 14 of this year.\nYour question concerned making a 10\" hot tap on a 24\" line in a class 1 location with a M.A.O.P.\nof 850 psig utilizing a full encirclement welded split sleeve as reinforcement.\nI told you at the time you asked the question that I thought that the split sleeve would be\nconsidered reinforcement but that I wanted to verify that. I have since checked with our\nheadquarters office and have received concurrence with my opinion.\nAs such this would not lower the design factor as stated in 192.111(b).\nThis is, as mentioned to you on the phone, the opinion of the Western Regional office. An official\ninterpretation must be requested in writing and directed to OPSO headquarters in Washington,\nD.C.\nI hope I have been of some assistance and if you have any further questions please feel free to\ncontact me. Thank you for your continued interest in gas safety.\nSincerely,\ndal\\192\\619\\78-01-4\n3\n\n<<<PAGE 4>>>\n\nJack C. Overly, Chief\nWestern Region\nOffice of Pipeline Safety Operations\ndal\\192\\619\\78-01-4\n4","truncated":false,"body_characters":4021}