{"operation":"document","citation":"PI-85-002","title":"Missouri Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1985-03-20","effective_on":null,"summary":"PI-85-002 response to Missouri Public Service Commission concerning 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-85-002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-85-002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-85-002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1985/PI85002.pdf","body":"<<<PAGE 1>>>\n\nMarch 20, 1985\nMr. Dale W. Johansen\nAssistant Manager\nMissouri Public Service Commission\nP.O. Box 360\nJefferson City, Missouri 65102\nDear Mr. Johansen:\nIn response to your letter of February 22, 1985, and subsequent discussions on the Missouri PSC\nenforcement problems concerning 49 CFR Part 192, paragraph 192.619 and related regulations, I\noffer the following comments:\nThe facts:\nm The steel distribution pipeline systems were designed for 40 psi.\nm The systems were tested and qualified for 40 psi at time of installation.\nm Installation and testing was prior to July 1, 1965.\nm The system relief valves are sized and set to relieve for 40 psi MAOP.\nm The systems operated at no higher than 10 psi for the 5 years prior to July 1, 1970.\nThe Operating limitations of concern that are imposed by Part 192 on the gas systems\nare:\nm 192.619(a)(3) limits the MAOP of the system to 10 psi. This is also the MAOP\npermitted by 192.621.\nm 192.621(a)(5) & (b) requires that the relief valves that will prevent the MAOP\nfrom being exceeded, be designed in accordance with 192.195.\nThe problem:\nIn order to have sufficient relief capacity at an MAOP of 10 psi, the operator\nwould incur the expense and effort of replacing the relief valves.\nor\ndal\\192\\619\\85-03-20\n1\n\n<<<PAGE 2>>>\n\nThe operator would incur the expense and effort of upgrading the system per\n192.553 and 192.557 to an MAOP of 40 psi.\nMy staff and I have reviewed the regulations and interpretations relating to the situations\ndescribed and advise that, based on the facts and conditions previously stated, the operator has\nthree options for action he can take:\n1. Waiver - The operator could submit to the Missouri Public Service Commission a\nrequest for waiver from 192.619 to permit the MAOP to be established at 40 psi\nwithout performing certain requirements specified in Subpart K - Uprating or to\npermit the existing relief devices to continue in use. In either case, the operator\nwould have to demonstrate why the existing regulation(s) is (are) inappropriate\nand how the level of safety intended by the regulation(s) will be maintained. If the\nMissouri Public Service Commission would approve such a waiver request, the\napproval would be contingent upon MTB's concurrence. This option should not\nbe considered by the Missouri PSC where a compliance case has been initiated.\n2. Upgrade the Existing Pipeline Systems - The operator could upgrade the existing\npiping systems per the requirements of 192.553 and 192.557. These upgrading\nrequirements do provide a sound and practical means to upgrade the MAOP of\npipelines that have been operated and maintained in accordance with good\nprocedures such as you indicated the operator claims to have performed.\n3. Replace Overpressure Protective Devices - The operator could replace the existing\noverpressure protective devices with devices that would be capable of protecting\nthe 10 psi MAOP within the limits specified by 49 CFR Part 192, i.e, 192.621(b),\n192.195, 192.199, and 192.201.\nI have enclosed for your information and future guidance, several interpretations relating to the\nregulations involved in this determination. These interpretations should reinforce and clarify your\nunderstanding of the regulations as discussed in your letter and are consistent with our national\npolicy.\nI would also like to emphasize that 192.557 provides the operator with a practical means of\nestablishing a higher MAOP for pipelines believed to be in an otherwise safe operating condition.\nThe regulations also protect the public by requiring the operator to take steps to assure that safe\ncondition. The requirements are little more than what a prudent operator would do prior to\nraising the pressure on any pipeline that had been operated at a lower pressure for several years.\nIf you desire any further clarification, please contact Ed Ondak, Frank Fulton, or myself. Thank\nyou for your participation in this pipeline safety program.\ndal\\192\\619\\85-03-20\n2\n\n<<<PAGE 3>>>\n\nSincerely,\nRobert L. Paullin\nAssociate Director for Operations\nand Enforcement\nMaterials Transportation Bureau\nEnclosures\ndal\\192\\619\\85-03-20\n3","truncated":false,"body_characters":4133}