{"operation":"document","citation":"PI-79-0101","title":"Pipeline Safety Interpretation PI-79-0101","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1979-02-23","effective_on":null,"summary":"PI-79-0101 concerning 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-0101.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-0101.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-0101","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1979/g79-02-23_Hersey_192.619-msfX.pdf","body":"<<<PAGE 1>>>\n\nPI-79-0101\nArizona Corporation Commission\n2222 West Encanto Blvd.\nPhoenix, Arizona 85009\nFebruary 23, 1979\nMr. Howard Hersey\nArizona Public Service Company\nP.O. Box 21666\nPhoenix, AZ 85036\nDear Mr. Hersey:\nIn regards to my interpretation regarding over pressure protection requirements and grandfathering,\nclarification has been received from DOT, Washington. My interpretation has been substantialized. Please see\nthe enclosed copy of the letter from Cesar DeLeon dated February 14, 1979.\nAs a result of this clarification, please review all pressure regulating stations in Arizona Public Service's\nsystems and make the corrections necessary to comply with over pressure protection requirements as soon as\npossible.\nPlease acknowledge receipt of this letter and inform this commission of your proposed program\nschedule for accomplishment of the review mentioned above and correction of deficiencies found resulting\nfrom review and this clarification.\nSincerely,\nARIZONA CORPORATION COMMISSION\nH. R. Garabrant, P.E.\nUtilities Safety Engineer\nUtilities Division\n\n<<<PAGE 2>>>\n\nArizona Corporation Commission\n2222 West Encanto Blvd.\nPhoenix, Arizona 85009\nFebruary 23, 1979\nTO: All Gas Operators - State of Arizona\nFROM: H.R. Garabrant, P.E.\nSUBJECT: Over pressure protection\nAs you are all aware, this commission has been enforcing the over pressure protection requirements when\nrequired, regardless of age of the installation, i.e. grandfathering of 192.195 is not applicable as parts\n192.619(b) and 192.621(b) are not grandfathered and part 192.195 is incorporated by reference in 192.619(b)\nand 192.621(b).\nOne company disagreed with our enforcement policy and it was necessary to obtain clarification from\nWashington to substantiate this position.\nSubstantiation of the interpretation has been received and a copy of the letter stating the facts is enclosed, as\nit may be of interest to you.\nSincerely,\nARIZONA CORPORATION COMMISSION\nH. R. Garabrant, P.E.\nGas Utilities Safety Engineer\nUtilities Division\n\n<<<PAGE 3>>>\n\nDepartment of Transportation\nResearch and Special Programs Administration\nWashington, D.C. 20590\nFebruary 14, 1979\nH. R. Garabrant, P.E.\nGas Utilities Safety Engineer\nUtilities Division\nArizona Corporation Commission\n2222 West Encanto Boulevard\nPhoenix, Arizona 85009\nDear Mr. Garabrant:\nThis responds to your letter of October 20, 1978, regarding the applicability of sections 192.619(b) and\n192.621(b).\nYour letter notes that sections 192.619(b) and 192.621(b) are operation requirements which are not\n\"grandfathered\" and are continuing regulations that are applicable to all pipelines. Your letter mentions that\nboth of these sections reference section 192.195 which states, in part, that \" . . . must have pressure relieving\nor pressure limiting devices that meet the requirements of sections 192.199 and 192.201.\" As you noted,\nsections 192.195, 192.199, and 192.201 are design requirements which only apply to pipelines readied for\nservice after March 12, 1971, or replaced, relocated, or otherwise changed after November 12, 1970. You\ninquire if you are correct in interpreting that all district regulators including those readied for service before\nMarch 12, 1971, must meet the requirements of section 192.621(b).\nBecause section 192.195 is incorporated by reference in sections 192.619(b) and 192.621(b), which are\noperating requirements, the provisions of section 192.195 apply to those pipelines readied for service before\nMarch 21, 1971, if section 192.619(b) or section 192.621(b) applies to the pipelines concerned.\nWe trust that this adequately responds to your inquiry.\nSincerely,\nCesar De Leon\nAssociate Director for Pipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 4>>>\n\nUNITED STATES GOVERNMENT\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nMemorandum\nDATE: December 19, 1978\nSubject: Request for Interpretation\nFrom: Chief, Western Regional Office\nTo: Associate Director, Office of Operations and Enforcement\nAttached is a copy of Mr. Garabrant's letter to you requesting an interpretation.\nThis is the letter we discussed that was sent by you to OPSR for interpretation and was misplaced.\nPlease resubmit to OPSR for immediate action as Mr. Garabrant is anxious to receive the interpretation. Thank\nyou.\nJack Overly\n\n<<<PAGE 5>>>\n\nArizona Corporation Commission\n2222 WEST ENCANTO BLVD.\nPHOENIX. ARIZONA SSOOS\nOctober 20, 1978\nMr. Robert L. Paullin\nAssociate Director for\nOperations and Enforcement\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. Paullin:\nIn the past one area of enforcement that I have given a rather high priority to in this state and one that all\ncompanies have been making corrections to comply with has been 192.621(b).\n\"No person may operate a segment of pipeline to which paragraph (a)(5) of this section applies, unless over\npressure protection devices are installed on the segment in a manner that will prevent the maximum\nallowable operating pressure from being exceeded in accordance with section 192.195.\"\nParagraph (a)(5) states. \"The pressure determined by the operator to be the maximum safe pressure after\nconsidering the history of the segment, particularly known corrosion and the actual operating pressures.\"\nThe above statements are basically repeated in paragraph 192.619 (b).\nYou will note that section #192.621 and 192.619 are in the regulations under sub-part L.\n- operations.\nInterpretations are that this sub-part and sections are applicable to all pipelines regardless of age i.e. not\ngrandfathered (see attached chart).\nPart 192.619 (b) and 192.621 (b) both refer to 192.195.\nPart of the requirements of 192.195 include, \"-----must have pressure relieving or pressure limiting devices\nthat meet the requirements of sections 192.199 and 192.201.\"\nI will not repeat 192.199 here but in paragraph (g) of 192.199 there is a clause \"be designed and installed to\nprevent any single incident such as an explosion in a vault or damage by a vehicle from affecting the operation\nof both the over pressure protective device and the district regulator. \"\n192.201 (b) reads \"When more than one pressure regulating or compressor station feeds into a pipeline, relief\nvalves or other protective devices must be installed at each station to insure that the complete failure of the\nlargest capacity regulator or compressor or any single run of lesser capacity regulators or compressors in that\nstation will not impose pressure on any part of the pipeline or distribution system in excess of those for which\nit was designated or against which it was protected, whichever is lower.\"\nYou will note that sections 192.195 192.199 and 192.201 are in sub-part D - This section is grandfathered and\nit might be possible to interpret that old regulator stations need not be up dated to include over pressure\nprotective devices at each station.\nMy interpretation has been and I still consider it a defficiency if each district regulator station does not have\nan over pressure protective device and that a device must be added. This is based on the paragraph 192.621\n(b), and is the more stringent condition due to \"no person may operate-----.”\n\n<<<PAGE 6>>>\n\nOne major company is faced with a fairly major effort to correct a considerable number of stations. They have\nstated that they believe that the regulations exceed the authority given by Congress and that there was no\nintent by Congress for an operations requirement to require rebuild or adding to existing facilities as Congress\n\"grandfathered\" design and construction.\nI might mention that most of this company's stations feed into various integrated systems and in most cases\nthere is a relief valve some where in the system. I suggested a while back that they use the waiver procedure\nshowing the calculations to prove (under minimum load conditions) that the MAOP would not be exceeded by\nthe allowable amount if any one of the district regulator stations should fail. Such situations would have to be\nwell documented before I would consider a waiver approval. I doubt that this would solve many of their\nproblems as there is a certain amount of pressure gradient involved and a remote relief valve would have to\nbe set lower than normal to prevent over pressuring lines close to the failing regulator station.\nBefore I bring the situation to the attention of the Arizona Corporation Commissioners for show cause action\npossibly involving fines. I need confirmation from your office that my interpretation is correct and that the\nLegal Department in Washington confirms that the requirements of 192.621 (b) is in compliance with\nCongressional intent.\nI would appreciate a reply as soon as possible on this.\nNOTE: To put things in the proper perspective, I have not been citing companies where the paragraph 192.199\n(g) is in violation as long as 192.201 (b) was in compliance and the equipment installation grandfathered due\nto age. This is what I think the rules and Congress intended.\nI don't see that the requirement of adding a relief valve or monitor regulator is any more out of line than\nadding cathodic protection requirements to older facilities that would otherwise be grandfathered.\nSorry to put you to this trouble but I need a certain amount of backup before I present this to the Commission\nfor action. Hopefully, if your answer confirms my interpretation, the company may accelerate their program in\nthis regard and formal Commission action with the usual public hearings avoided.\nSincerely,\nARIZONA CORPORATION COMMISSION\nH. R. Garabrant, P.E.\nGas Utilities Safety Engineer\nUtilities Division","truncated":false,"body_characters":9640}