{"operation":"document","citation":"PI-81-0109","title":"Pipeline Safety Interpretation PI-81-0109","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1981-07-10","effective_on":null,"summary":"PI-81-0109 concerning 195.106.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-0109.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-0109.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-0109","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1981/g81-07-10_Speckmann_195.106-DBx.pdf","body":"<<<PAGE 1>>>\n\nPI-81-0109\nJuly 10, 1981\nMr. R. E. Speckmann, Manager\nRegulations and Maintenance Standards\nShell Pipe Line Corporation\nP.O. Box 2648\nHouston, Texas 77001\nDear Mr. Speckmann:\nThis is in response to your letter dated March 17, 1981, and Mr. R. D. Fischer’s letter dated May 11, 1981,\nconcerning the use of 48-inch and 42-inch pipe which was noted as grade B on the supplier's Certificate of\nAnalyses and Tests, but which was shown on the same certificate to have yield strengths of 51,500 psi and\n56,500 psi respectively, and chemical compositions consistent with higher grades of pipe. You have used the\npipe in a pump suction and discharge piping with design stresses equal to the indicated yield strengths on the\nsupposition that the pipe is not, in fact, grade B. Your letter requests our concurrence with the use of the pipe\nin this manner.\nThe Certificate of Analyses and Tests raises doubt whether the pipe is grade B or a higher grade of pipe. You\nbelieve, however, that the hydrostatic test stresses the pipe to such a level to demonstrate that since the pipe\ndid not reach its yield strength, it must therefore be the higher strength pipe having those physical\ncharacteristics listed on the Certificate of Analyses and Tests. We agree with this conclusion based on the data\nfurnished in your letters. As further support for this conclusion, we suggest you conduct the API 5LX tests on\nrepresentative unused pipe and have this added information available when the Materials Transportation\nBureau enforcement personnel examine the records.\nSincerely,\nSIGNED\nMelvin A. Judah\nActing Associate Director\nfor Pipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nShell Pipe Line Corporation\nP.O. Box 2648\nHouston, Texas 77001\nMay 11, 1981\nMr. Melvin A. Judah, Acting\nAssociate Director for Pipeline Safety Regulations\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. Judah:\nFurther to our letter of March 17, 1981 concerning pipe installed at the initial pump station on the LOCAP\npipeline, and in response to your Mr. Frank Robinson's telephone inquiry, we submit the following\nsupplementary information.\nInitial (Phase I) Operation: Discharge Pressure - 800 psi\nSuction Pressure - 150-400 psi\nFuture (Phase II) Design: Discharge Pressure (max.) - 1150 psi\nSuction Pressure (max.) - 720 psi\nStation Valves: Suction - 300#\nPump - 600#\nDischarge - 600#\nSubsequent to the hydrostatic pressure test at 1950 psi (actual test pressures were minimum = 1990 psi,\nmaximum = 2020 psi), the station piping was measured circumferentially at 3-foot intervals. The results which\nconfirmed no evidence of yield, were as follows:\nPipe Circumference (feet)\nMeasurements Average Maximum Minimum Nominal\n48\" Grade B 20 12.58 12.58 12.57 12.57\n48\" X-52 9 12.60 12.62 12.58 12.57\n42\" Grade B 10 11.00 11.01 11.00 11.00\n*42\" Grade B (surplus) 8 11.02 11.03 11.01 11.00\n*This surplus \"Grade B\" pipe had not been subjected to the hydrostatic pressure test.\nPlease advise if any additional information is desired.\nVery truly yours,\nR. D. Fischer, Acting Manager\nRegulations & Maintenance Standards\n\n<<<PAGE 3>>>\n\nShell Pipe Line Corporation\nP.O. Box 2648\nHouston, Texas 77001\nMarch 17, 1981\nMr. Melvin A. Judah, Acting\nAssociate Director for Pipeline\nSafety Regulation\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. Judah:\nShell Pipe Line Corporation is constructing LOCAP Pipeline, a 48-inch diameter crude oil pipeline from the\nLousiana Offshore Oil Port (LOOP) terminal at Clovelly, Louisiana to LOCAP's terminus at St. James, Louisiana,\nThe initial pump station on the LOCAP pipeline is located at LOOP's Clovelly terminal in Section 32, T18S, R22E,\nLaFourche Parish, Louisiana. The design for the discharge piping at this pump station, developed in\nconformance with 49 CFR 195.106, specified API 5LX-46 pipe with a \"specified minimum yeild strength\" of\n46,000 psi, and pipe was ordered to this specification in 42-inch and 48-inch dimaters. Subsequent to receipt\nof this pipe, a Certificate of Analysis and Tests covering the furnished pipe was received from the supplier.\nAlthough the physical and chemical properties of the pipe met or exceeded specifications for API 5LX-46 pipe,\nthe certificate indicated \"Specification and Graded API 5L Grade B\". A copy of this certificate, dated February\n25, 1980, is attached hereto.\nUpon receiving the certificate and noting the inconsistancy, the supplier was advised that as the indicated\nspecification on the certificate did not fully conform with the purchase order, the pipe was not acceptable,\nand the order was cancelled and replaced with another supplier and subsequently received. (In order to\nexpedite delivery, it was agreed that 48-inch X-52 pipe could be substituted for X-46).\nPrior to the return of the rejected pipe to the supplier, the piping installation contractor inadvertantly picked\nup approximately 120 feet of that pipe together with the API 5LX pipe, and some 112'-5\" of the rejected pipe\nwas installed in the station manifold piping, as indicated on the attached drawing ES-77-99. This was not\ndiscovered until a material inventory for closing out the project revealed a variance in the pipe tally compared\nto the ordered quantity.\nThe entire discharge manifold was hydrostatically tested to 1950 psi (based on 90% of the SMYS of 48-inch X-\n52 pipe) for 24 hours in conformance with 49 CFR 195.302. A copy of the hydrostatic test report, with pressure\nand temperature charts, is attached.\nIn summary of the above:\n1. The pipe design specification was to be API 5LX-46.\n2. The pipe was ordered to this specification.\n3. The 112'-5\" of pipe inadvertantly installed conformed in every physical and chemical respect with\nspecifications for API 5LX-46 pipe.\n4. The specification as written on the supplier's certificate was API 5L-Grade B.\n5. The installed pipe was hydrostatically tested to 1950 psi.\nWe submit that replacement of the subject pipe, at an estimated cost in excess of $200,000, would provide no\nincrease in public safety, and would not be in keeping with Presidential guidelines to reduce unnecesary costs\nto the public.\nIn consideration of the actual properties and hydrostatic testing of the installed pipe in question, there would\nbe no reduction in public safety, nor would it be inconsistent with pipeline safety, to stipulate the subject pipe\n\n<<<PAGE 4>>>\n\nas qualified in meeting the specifications of API 5LX-46, for the purpose of determining internal design\npressure under the provisions of 49 CFR 195.106. Your concurrence with this proposed stipulation is\nrequested.\nVery truly yours,\nR. E. Speckmann, Manager\nRegulations and Maintenance\nStandards","truncated":false,"body_characters":6746}