{"operation":"document","citation":"PI-91-012","title":"Greeley Gas Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1991-05-09","effective_on":null,"summary":"PI-91-012 response to Greeley Gas Company concerning 192.285.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-91-012.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-91-012.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-91-012","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1991/PI91012.pdf","body":"<<<PAGE 1>>>\n\nMr. Richard W. Remley\nSenior Vice President\nGreeley Gas Company\n1301 Pennsylvania Street\nDenver, CO 80203-5015\nDear Mr. Remley:\nThis responds to your letter of January 8, 1991, to Cesar DeLeon of this agency asking for our\ninterpretation of 49 CFR 192.285(d). You feel that a State Commission interpretation requiring\nyour company to identify each fusion joint by the person who made it exceeds Federal\nRequirements.\nSection 192.285(d) states that each operator shall establish a method to determine that each\nperson making joints in plastic pipelines is qualified under §192.285. You interpret this rule to\nmean that your company should insure that only qualified joiners are allowed to connect plastic\npipe in your system. Accordingly, you said your company requalifies this practice is sufficient to\nmeet Federal Standards.\nPursuant to §192.285(c), a person must be requalified under a joining procedure if during any 12-\nmonth period (1) that person does not make any joints; or (2) has 3 joints or 3 percent of the\njoints made, whichever is greater, under that procedure that are found unacceptable by testing\nunder §192.513. Your company's practice to requalify all joiners annually appears to be an\nacceptable method that satisfactorily fulfills the requirements of §192.285(d) provided the joiners\nare requalified in every procedure they use. If all joiners are requalified annually, there is no need\nto record who made each joint for the purpose of determining if the threshold of unacceptable\njoints is exceeded in a 12-month period for a particular procedure or determining if a joiner made\nno joints in a 12-month period.\nWe trust that this responds satisfactorily to your request.\nSincerely,\n/signed/\nGeorge W. Tenley, Jr.\nAssociate Administrator\nDB\nC:\\WP51\\INTERPRT\\192\\285\\91-05-09\n1\n\n<<<PAGE 2>>>\n\nSUBJECT: Plastic Pipe\nFROM: Cesar DeLeon\nDirector, Regulatory Programs, DPS-10\nTO: Richard E. Sanders\nManager, Pipeline Safety Division, DMA-607\nThis memo responds to your list of concerns, dated November 16, 1991, about plastic pipe,\nstemming from discussions at TSI seminars, pipeline safety inspections, and pipeline accidents.\n1. 2. 3. Section 1, issue 1, (Present Part 192 Code Sections . .. Where Temperatures Will Not Go\nBelow - 20mF or Above 140mF) and Section 6, (Pressure Testing of Polyethylene\nSystems), of your memo expressed concerns over existing temperature limits for design\nand testing of plastic pipe. As you know, 49 CFR 192.123, Design limitations for plastic\npipe, sets a minimum operating temperature in plastic pipe at -20mF, and 49 CFR\n192.513 limits the temperature of thermoplastic material during pipeline tests to a\nmaximum of 100mF.\nWe agree with your recommendations concerning the need to relax the regulations to\nreflect advancements in technology of polyethylene piping. We are currently developing a\nNotice of Proposed Rulemaking to address these issues.\nSection 1, issue 2, expressed a concern over the need to derate plastic pipe whose\ntemperature exceeds 73mF to be commensurate with the design formula for that\ntemperature. We agree that unless the pipe in you example was qualified for use above 73\nmF, its MAOP could not be set at 60 psig.\nIn Section 2, (Qualification Procedures in §192.283), you expressed concern over\n§192.283(a)(1)(i) which governs the qualification of procedures of joining polyethylene\npipe. This section references ASTM D2513, 1987 edition, which does not identify fiber\nstress amounts for polyethylene pipe when conducting an acceptable quick burst test.\nWe intend to address this issue through staff Participation on the ASTM D2513\ncommittee. Meanwhile, we have issued an interpretation on the issue. (See attached letter\nto Glen Smith.)\nAdditionally, in Section 2, you recommended that an organization. such as PPI, undertake\nresponsibility for receiving and reviewing all joining procedures, and publishing all\nqualified joining procedures. Although we see some potential benefit to such action, we\ndo not think it's necessary for RSPA to take the lead in bringing it about.\nDB\nC:\\WP51\\INTERPRT\\192\\285\\91-05-09\n2\n\n<<<PAGE 3>>>\n\n4. 5. 6. In Section 3, (Maintenance of Equipment Used to Join Plastic Pipe), you identified the\nneed for equipment specifications and maintenance requirements regarding permissible\ntolerances in the operation of equipment used to join plastic pipe.\nWe agree with your concerns about the use of proper equipment, However, we think a\nrequirement to use such equipment is implicit in existing standards under §192.273 and\n§192.283, which govern plastic pipe joining. Equipment that is in obviously poor\ncondition probably would not be able to produce the requisite joints.\nSection 4, (Qualification Of Persons To Join Plastic Pipe), expressed the need clarification\nof 49 CFR 192.285(c). This rule requires persons to be requalified if, during any 12\nmonth period, (1) the person does not make any joints under a given procedure; or (2) 3\njoints or 3 percent of the joints made, whichever is greater, are found unacceptable by\ntesting under §192.513.\nUpon review of this regulation, we find that it does not require am operator to review a\nperson's joining performance based on a running 12-month period. In other words, each\nnew day does not mark the end of another 12-month period requiring another review.\nRather, in cases where a person is qualified or requalified to join plastic pipe, the 12-\nmonth period would begin at the time of the qualifications.\nIn Section 5, (NFPA Standard 58), you indicated that there sometimes arises confusion\nover which requirements take precedence, NFPA 58 or the Part 192 regulations. You\nsaid the NFPA code, referenced in §192.11, permits only butt or socket fusion for\npolyethylene pipe; whereas, the Part 192 regulations, otherwise, permit mechanical\nfittings.\nNFPA 58 expressly prohibits the use of mechanical fittings on certain pipe in petroleum\ngas systems. The use of mechanical fittings on all gas systems is allowed under Subpart F,\n\"Joining of Material Other Than by Welding.\" We are aware that some operators view\nthis as a conflict. Thus, we are presently evaluating the issue as part of our regulatory\nreview process and hope the review will resolve this matter.\nLastly, you indicated that NFPA requires all plastic materials used in LP gas systems to be\nregistered with NFPA. A review of the 1979 edition of NFPA 58, adopted by our\nregulations, and our subsequent conversations with NFPA, regarding interpretation,\nconfirm your assertions. At present, this NFPA requirement cannot be satisfied because\nthere exists no listed authorities for use of polyethylene plastic pipe. Consequently, NFPA\nhas amended the standard to eliminate this requirement from the 1992 edition of NFPA\n58, and we have begun efforts within DOT to reference this latter edition in our\nregulations.\nDB\nC:\\WP51\\INTERPRT\\192\\285\\91-05-09\n3\n\n<<<PAGE 4>>>\n\n7. 8. 9. Section 7, Plastic Casings, raises a concern over the use of plastic casings with steel\ncarrier pipe. The plastic casing would act as a high dielectric materials, thus not\npermitting cathodic protection currents to be driven through the casing to the carrier pipe.\nIf a pipeline does not have an adequate level of cathodic protection because of shielding by\na pipe casing, the operator must remove the casing or modify the cathodic protection\nsystem to provide the required level of protection. We believe this interpretation is clear\nunder the Part 192 corrosion control rules.\nSection 8, Use of Plastic Pipe for Temporary Bypass During Emergencies and\nMaintenance, expressed concerns over existing regulations (§192.321) which prohibit the\nuse of aboveground plastic pipelines. The regulations prohibit the use of aboveground\nplastic pipelines for any reason, including temporary applications needed for quick\nresponses to emergencies and maintenance problems.\nWe agree with your concerns, and we are currently developing a Notice of Proposed\nRulemaking to address this issue.\nSection 9, Material Not Covered Under Present DOT Code or Industry Standards,\nindicated that no industry standards exist for nylon or composite plastic materials. You\nsuggested that standards or procedures be established which would parallel existing\nstandards or procedures for other plastic material.\nAs you know, Subpart B-Materials of Part 192 of the DOT Pipeline Safety Regulations\nprescribes minimum requirements for the selection and qualification of pipes used in\nnatural gas pipelines. It requires that all pipe be manufactured in accordance with a listed\nspecification. For plastic pipe, ASTM D2512 and ASTM D2517 are two such listed\nstandards for manufacture and use of thermoplastic and thermosetting plastic pipe in\nfederally regulated gas pipelines. No other standards are listed for plastic pipe use, and\nneither ASTM D2513 nor ASTM D2517 incorporate nylon or composite plastics into the\nstandards, Thus, nylon or composite plastic pipe may not be used in federally regulated\ngas pipelines. We assume, however, that standards comparable to thermoplastic and\nthermosetting materials will be developed with sufficient economic or industrial demand.\nWe would then consider amending Part 192 to reflect these changes.\nYour continued support for this office is very much appreciated.\nAttachment\nDB\nC:\\WP51\\INTERPRT\\192\\285\\91-05-09\n4\n\n<<<PAGE 5>>>\n\nMr. Glen D. Smith\nChief, Pipeline Safety Utilities Division\nKansas Corporation Commission\n1500 S.W. Arrowhead Rd.\nTopeka, KS 66604-4027\nDear Mr. Smith:\nI am responding to your letter of May 16, 1991 to Mr. George Tenley, regarding the requirements\nof 49 CFR 192.283(a)(1)(i) for testing a procedure used to join polyethylene pipe by fusion.\nThese requirements refer to paragraph 8.7, Minimum Hydrostatic Burst Pressure, of ASTM\nD2513 (1987 edition). You questioned the applicability of paragraph 8.7 to polyethylene because\nparagraph 8.7 does not provide a test pressure for this material or a fiber stress for calculation of\na test pressure.\nAlthough your observations about paragraph 8.7 are correct, ASTM D2513 (1987 edition)\nprovides another means for qualifying polyethylene pipe that is tested under paragraph 8.7.\nParagraph 6.3 of ASTM D2513 (1987 edition) provides:\nFor PE materials, the pipe shall fail as defined in D1599. a ductile manner, when tested in accordance with 8.7.\nSo, if polyethylene pipe specimens with fusion joints are tested under paragraph 8.7, and the\nspecimens fail as defined in ASTM D1599 and in a ductile manner, the fusion joining procedure\nqualities under §192.283(a)(1)(i).\nWe will be amending the ASTM D2513 references in Part 192 to reflect the changes in the 1991a\nedition of ASTM D2513. In the 1991a edition, paragraph 6.7 and Annex A1 include the above\nASTM requirements regarding minimum hydrostatic burst pressure for testing polyethylene pipe\nspecimens. We will amend §192.283(a)(1)(i) to reflect this change in the 1991a edition of ASTM\nD2513.\nIn addition, the pipe shall fail in\nSincerely,\n/signed/\nCesar DeLeon\nDirector, Regulatory Programs\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\285\\91-05-09\n5","truncated":false,"body_characters":11102}