{"operation":"document","citation":"PI-90-022","title":"OXY USA Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1990-06-05","effective_on":null,"summary":"PI-90-022 response to OXY USA Inc. concerning 195.5.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-90-022.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-90-022.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-90-022","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1990/PI90022.pdf","body":"<<<PAGE 1>>>\n\nJune 5, 1990\nMr. Kevin C. Bodenhamer\nArea Manager\nOXY USA Inc.\nBox 1225\nHutchinson, KS 67504\nDear Mr. Bodenhamer:\nWe have reviewed your petition (P-90-2W) requesting a waiver from compliance with the testing\nrequirements of 192.14(a)(4) and 195.5(a)(4) for a 6-inch steel pipeline carrying natural gas liquids that\nwas constructed and hydrostatically tested in 1966. The petition states that OXY desires to covert [sic]\nthe line to dual service for operation under both Part 192 and Part 195.\nYou stated that in view of the original testing and subsequent service, no additional risks will be imposed\nby not testing the pipeline. You also stated that testing the pipeline upon each frequent change in service\nwould impose an undue hardship that could cost $500,000 a year.\nWe must decline to grant the waiver for the following reasons: First, when a hazardous liquid pipeline is\nconverted to gas service under 192.14, the operator lacks proof that the line complies with the current\nPart 192 material, design, and construction standards. To offset the risks inherent in lack of compliance\nwith these gas pipeline safety standards, the conversion rule (192.14) requires that the line be strength\ntested as part of the conversion process to confirm its maximum allowable operating pressure. We\nestablished this test requirement with the knowledge that many pipelines to be converted under 192.14\nwould have been tested initially soon after construction. However, such testing was considered\ninadequate to qualify a pipeline for gas service because of the time elapsed since the initial test. There\ndoes not appear to be any reason, therefore, to treat OXY's pipeline any differently regarding the need for\ntesting than other hazardous liquid pipelines that are converted to gas service under 192.14.\nThe second reason is that the conversion rules under 192.14 and 195.5 do not require testing each time a\nchange in service occurs in a pipeline qualified for dual service. The conversion rules prescribe\nqualifications for initial operation in gas service of an existing pipeline not previously subject to part 192\nand for initial operation in hazardous liquid service of an existing pipeline not previously subject to Part\n195. Under Parts 192 and 195, once a pipeline qualifies for operation in gas or hazardous liquid service,\nit remains qualified for operation in that service regardless of the type of service in which it may be used\nsubsequently. For example, if a pipeline that is qualified under Part 195 for hazardous liquid service, such\nas OXY's pipeline in the present case, is converted to gas service, it does not have to be requalified under\nPart 195 before being returned to hazardous liquid service. Any component installed in an existing\npipeline after it is qualified for use in gas or hazardous liquid service must, of course, meet all applicable\nmaterial, design, construction, and testing requirements in effect when the component is installed.\nSincerely,\nGeorge W. Tenley, Jr.\nDirector\nOffice of Pipeline Safety","truncated":false,"body_characters":3045}