{"operation":"document","citation":"PI-80-017","title":"Venart Industries Limited — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1980-09-26","effective_on":null,"summary":"PI-80-017 response to Venart Industries Limited concerning 192.111.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1980/PI80017.pdf","body":"<<<PAGE 1>>>\n\nSeptember 26, 1980\nMr. J. K. Campbell, P.E.\nVenart Industries Limited\n215 - 52nd Street\nDelta, British Columbia, Canada V4M 2Y3\nDear Mr. Campbell:\nThis refers to your letter dated August 11, 1980, in which you requested an interpretation of 49\nCFR Part 192, Subpart C--Part Design, as it relates to compressor station main piping.\nQuestion: You ask whether strict compliance with 49 CFR is mandatory or not.\nResponse: All pipelines subject to the Natural Gas Pipeline Safety Act (NGPSA) must comply\nwith the prescribed requirements of 49 CFR Part 192, \"Transportation of Natural and Other Gas\nby Pipeline,\" (copy enclosed). These requirements are considered as minimums that must be met.\nUnder section 11(a) of the NGPSA, operators of pipelines found not in compliance with 49 CFR\nPart 192 are subject to a civil penalty not to exceed $1,000 for each violation for each day the\nviolation persists up to a maximum of $200,000 for any related series of violations.\nQuestion: You ask if we agree with your interpretation of the maximum stress levels allowable\nunder 49 CFR Part 192.\nResponse: No. It appears that you have not considered the performance requirements contained\nin §192.103, General, which states: \"Pipe must be designed with sufficient wall thickness, or\nmust be installed with adequate protection, to withstand anticipated external pressures and loads\nthat will be imposed on the pipe after installation.\" The purpose of this performance requirements\nif to take care of those stresses which are not relieved after construction and proof testing that\nbecome additive to operating stresses. Some of the stresses which are of concern specifically with\ncompressor station deign are those caused during blowdowns and repressurization of discharge\nlines, by effects of soil settlement, by major temperature changes, by mechanical and sonic\nvibration, and pulsation.\nWe wish to emphasize that the design factor (F) contained in §192.111 is required to be used only\nin determining the pressure containment abilities of the pipe. However, a person responsible for\ndesigning a pipeline, including compressor station piping, must use appropriate design factors\nand/or provide protection against the accumulative effects of all relevant stresses. Part 192 does\nnot specify the design factors to be used in considering stresses other than those produced by\ninternal pressure although the design factor (F) contained in §192.111 would be considered\nappropriate.\ndal\\192\\111\\80-09-26\n1\n\n<<<PAGE 2>>>\n\nThank you for your very helpful analysis and discussion of MOHR circle diagrams explaining the\ncomplexity involved in analyzing combined stresses in compressor station piping.\nSincerely,\nMelvin A. Judah\nActing Associate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nEnclosure\ndal\\192\\111\\80-09-26\n2","truncated":false,"body_characters":2837}