{"operation":"document","citation":"PI-89-018","title":"Exxon Gas System, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1989-09-15","effective_on":null,"summary":"PI-89-018 response to Exxon Gas System, Inc. concerning 192.611.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-018.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-018.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-018","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1989/PI89018.pdf","body":"<<<PAGE 1>>>\n\nMr. J. Keith McSorley\nExxon Gas System, Inc.\nP. O. Box 3948\nHouston, Texas 77253-3948\nDear Mr. McSorley:\nThank you for your letter requesting an interpretation of §192.611 as amended (54 FR 24173,\nJune 6, 1989). Your letter indicates that you believe that §192.611(a)(1) should be applicable to\na pipeline where, because of a previous class location change, §192.611(a)(2) had been applied\nand the MAOP reduced. You included as an example data on a pipeline for which the MAOP had\nbeen reduced in 1986 from 833 psig to 675 psig. Current application of §192.611(a((1) as\namended would permit operation of the pipeline at 801 psig, which, although less than the original\nMAOP, is considerably higher than the current MAOP.\nA previous revision to §192.611 was made in 1986 (51 FR 34987, October 1, 1986, Amdt. 192-\n53), clarifying that the three MAOP restrictions in this section are options. Prior to that\nrulemaking, many persons had assumed that the restrictions now designated (a)(1), (2), and (3)\nwere intended to be applied sequentially as circumstances dictated. The most recent revision of\nthis section relies heavily on this interpretation that the restrictions are options.\nIn the Notice of Proposed Rulemaking preceding the 1986 revision (51 FR 1978, June 3, 1986),\nwe stated that, \"RSPA does not believe that the 18-month rule blocks operators who choose one\ncompliance option from later selecting the other.\" This language seems to apply in the situation\nyou have described. The fundamental difference here is that in the intervening time the available\ncompliance options have been changed. This factor, though, should not override the principle\nestablished in the previous rulemaking action, that selection and implementation of one option,\ne.g., lowering pressure, do not preclude later implementation of another option, e.g., retesting.\nThus, OPS believes it reasonable to interpret §192.611 to permit an operator who has previously\nreduced the pressure on a pipeline in response to a class location change to revisit that pipeline\nand raise the operating pressure within the limits now specified in §192.611(a)(1).\nWe hope that this discussion has answered your questions and made clear the appropriate\napplication of §192.611. If you have any further questions, please do not hesitate to contact us.\nDB\nC:\\WP51\\INTERPRT\\192\\611\\89-09-15\n1\n\n<<<PAGE 2>>>\n\nSincerely,\nRichard L. Beam\nDirector\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\611\\89-09-15\n2","truncated":false,"body_characters":2483}