{"operation":"document","citation":"PI-86-005","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1986-08-04","effective_on":null,"summary":"PI-86-005 response to Memo: Internal concerning 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-86-005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-86-005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-86-005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1986/PI86005.pdf","body":"<<<PAGE 1>>>\n\nROUTE SLIP\nAugust 4, 1986\nIvan, Can you explain what they mean in this\nresponse? Ed\n****************\nYes, If during the period 7/65 - 7/70, the pressure at C.S.\n\"A\" = P1 and at downstream C.S. \"B\" pressure = P2, the MAOP of the line from \"A\" to \"B\" is\nnot P1. The MAOP will vary with the actual pressure imposed at any point at the time the line\nwas operated at the subject pressures.\nIvan\n10-13-87\nFrom:\nFrank Fulton\ndall192\\619186-08-04\n\n<<<PAGE 2>>>\n\nClarification of Questions and Answers to Ivan Huntoon's Interpretation Request - 192.619(c)\n(Questions by Ivan - Answers by Frank Fulton and Buck Furrow)\nQ. Is it the intent of the regulations that the pressure gradient be ignored in determining the\nMAOP and that the MAOP for the entire line from A to B be established at 850 psi?\nA. No, the intent of .619(c) is to allow old safe operations to continue, but not be exceeded.\nThus, pressure gradient would have to be continued. The MAOP of an element inside the\nsegment could not exceed its old operating level.\nQ. Are we to consider the \"segment of pipeline\" to be that length from A to B; and since it was\noperated at 850 psi at A, the entire segment is qualified for 850 psi?\nA. In the final rule \"segment\" replaced \"section\" or \"portion\", but it has no definite beginning or\nend. If A and B mark a segment the MAOP of the segment under .619(c) would vary according\nto past operation and not be uniform as it would under .619(a).\nQ. Is the MAOP established at 850 psi because of the probability that at some time during the\nfive year period the line was packed to 850 psi from A to B?\nA. No\nQ. Is it necessary for the pressure at B to have been 850 psi to qualify the entire line for an\nMAOP of 850 psi?\nA. Yes\nQ. As an inspector, must I verify that the entire line from A to B was subjected to 850 psi\nsometime during that five year period?\nA. Yes\nQ. Is it adequate to assume that it was because the line was frequently operated at a discharge\npressure of 850 psi at A?\nA. No\ndal\\192\\619\\86-08-04\n2\n\n<<<PAGE 3>>>\n\nQ. Do the regulations require that the operator have records to substantiate the pressures used to\nestablish the MAOP per 192.619(c)?\nThe regulations do not require \"records\", however, enforcement personnel have to apply\njudgment as to what they will accept to substantiate the operator claim. A violation would have\nto be clearly obvious in order to be enforceable.\nRecords (i.e., pressure recording charts, compressor station records, flow calculations from a\nsubstantiated point, dispatcher records, etc.), sworn statements by the operator, etc., would be\nmeans that the operator could use to establish the highest pressure for the 5 year period.\ndal\\192\\619\\86-08-04\n3\n\n<<<PAGE 4>>>\n\nROUTE SLIP\nAugust 4, 1986\nTo: Ivan Huntoon\nCan you explain what they mean in this response?\nEd\n-----------------------------------------------------------------\nYes! If during the period 7/65 - 7/70, the pressure at C.S.\n\"A\" = P1 & at downstream C.S.\"B\" pressure = P2, the MAOP of the line from \"A\" to \"B\" is not\nP1. The MAOP will vary with the actual pressure imposed on at any point at the time the line was\noperated at the subject pressures.\nFrom: Frank\ndal\\192\\619\\86-08-04\n4\n\n<<<PAGE 5>>>\n\nDate: April 12, 1985\nSubj: Intent of 192.619(c)\nFrom: Ivan A. Huntoon, Staff Engineer, DMT-14\nTo: Frank Fulton, Chief, Pipeline Safety Enforcement, DMT-13\nDuring our telephone conversation on April 5, 1985, I questioned the intent of the\n\"grandfather clause\", 192.619(c). As I am not certain that I satisfactorily stated the\nsituation, it is stated in this memo, as are the questions which arose.\nI would like to have our position clarified in regard to this matter. Please call if you have\nany questions.\nThe \"grandfather clause\", 192.619(c), states that an operator may operate a segment of\npipeline found to be in satisfactory condition, considering its operating and maintenance\nhistory, at the highest actual operating pressure to which the segment was subjected\nduring the five years preceding July 1, 1970...subject to the requirements of 192.611.\nMy concern lies with the intent of the regulations as related to consideration of pressure\ngradient in the pipeline. Possibly it revolves around \"segment of pipeline\". Consider the\nfollowing example.\nI have a gas transmission line. The maximum allowable operating pressure (MAOP)\nbetween compressor stations A and B is established by 192.619(c) to be 850 psi. By the\nother criteria of 192.619, the MAOP would be 650 psi. The 850 psi MAOP is established\non the basis of one day's operation in April of 1970 (or any other day during the five years\npreceding July 1, 1970) when the discharge pressure at A, the upstream station, is 850 psi\nat some time during that day. The suction pressure at station B corresponding to the 850\npsi at A is 450 psi. Consider the line section to be entirely in a Class 1 location from A to\nB.\nIs it the intent of the regulations that the pressure gradient be ignored in determining the\nMAOP and that the MAOP for the entire line from A to B be established at 850 psi?\nNo, the intent of .619(c) is to allow old safe operations to continue but not be exceeded.\nThus pressure gradient would have to be continued. The MAOP of an element inside the\nsegment could not exceed its old operating level.\ndal\\192\\619\\86-08-04\n5\n\n<<<PAGE 6>>>\n\nIn the final rule \"segment\" replaced \"section\" or \"portion\" but it has no definite\nbeginning or end. If A and B mark a segment, the MAOP of the segment under. 619(c)\nwould vary according to past operation and not be uniform as it would under. 619(a).\nAre we to consider the \"segment of pipeline\" to be that length from A to B; and since it\nwas operated at 850 psi at A, the entire segment is qualified for 850 psi?\nIs the MAOP established at 850 psi because of the probability that at some time during the\nfive year period the line was packed to 850 psi from A to B? NO\nIs it necessary for the pressure at B to have been 850 psi to qualify the entire line form an\nMAOP of 850 psi? YES\n{As an inspector, must I verify that the entire line from A to B was subjected to 850 psi\nsometime during that five year period,› YES {or is it adequate to assume that it was\nbecause the line was frequently operated at a discharge pressure of 850 psi at A?} NO\nDo the regulations require that the operator have records to substantiate the pressures\nused to establish the MAOP per 192.619(c)?\nThe regulations do not require \"records\", however, enforcement personnel have to apply\njudgement as to what they will accept to substantiate the operator claim. A violation\nwould have to be clearly obvious in order to be enforceable.\nRecords*, sworn statements by the operator, etc., would be means that the operator can\nuse to establish the highest press. for the 5 year period.\n*Press. recording charts\ncompressor sta. press. records\nflow calculations from a substantiated point\ndispatcher records\netc.\ndal\\192\\619 86-08-04","truncated":false,"body_characters":6940}