{"operation":"document","citation":"PI-92-0106","title":"Rain Hill Group — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1992-08-05","effective_on":null,"summary":"PI-92-0106 response to Rain Hill Group concerning 192.53, 192.55, 195.112, 195.8.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-0106.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-0106.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-0106","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1992/g92_08_05_THOMAN_195.8_lmx.pdf","body":"<<<PAGE 1>>>\n\nPI-92-0106\nAugust 5, 1992\nMs. Wenke B. Thoman\nRain Hill Group\n27 East 61st Street\nNew York, NY 10021\nDear Ms. Thoman:\nI received your letter dated June 23, 1992, in which you indicate that you represent a client\ninterest in marketing bimetallic centrifugally cast pipe for use in accordance with the Federal\nRegulations applicable to the operation of oil and gas pipelines, particularly in applications\nwhere severely corrosive oil or gas is to be transported. I thank you and your client for your\ninterest in assuring that pipe materials intended to be marketed by your client comply with the\npipeline safety regulations.\nNew steel pipe for gas transportation is qualified for use under 49 CFR Part 192 if it was\nmanufactured in accordance with a specification listed in section I of Appendix B of Part 192\n(See 49 CFR § 192.55). The ASTM specifications listed in the manufacturer's brochure enclosed\nin your letter are not among those listed in Appendix B. Nonetheless, non-steel metallic\nmaterials meeting other specifications are not prohibited from being used in gas pipelines if these\nmaterials meet § 192.53 requirements. This section requires that all pipe and components be\nsuitable for those applications in which they are used.\nThe regulations for hazardous liquid pipelines, 49 CFR Part 195, require that new or used pipe\ninstalled in a pipeline must meet the performance requirements of § 195.112. There are no other\nmaterial specifications in Part 195, such as the nickel based alloys listed in the pipe brochure\nenclosed with your letter. However, under\n§ 195.8, an operator may use a material other than steel, if the Department determines the use\nwould not be unduly hazardous.\nThe Office of Pipeline Safety (OPS) recognizes that corrosion resistant alloys, suitable for\nservice in severely corrosive situations, are manufactured in pipe form to specifications that are\nnot listed in Part 192, and that such pipe technically is not steel under Part 195. In evaluating\nmaterials other than steel to be used in hazardous liquid pipelines, as required by § 195.8, RSPA\nrecognizes that corrosion resistant alloy materials commonly are superior to steel with respect to\ntheir suitability for service in specific severely corrosive situations and are the appropriate\nalternative to steels. The criteria OPS applies under § 195.8 regarding the use of pipe made from\na non-steel corrosion resistant alloy, such as a nickel based alloy are:\n- The corrosion resistant alloy materials for pipe must otherwise conform with § 195.112,\nas appropriate.\n\n<<<PAGE 2>>>\n\n- The pipe must be manufactured in conformance with a published specification and\ndocumented quality assurance program.\n- The procedure for joining lengths of pipe must be qualified for both the pipe material\nand the intended service.\n- It is the responsibility of the pipeline operator to demonstrate that the corrosion resistant\nalloy pipe and joining procedures are acceptable for the intended service.\nThe following responds to your questions which I have paraphrased below:\n1. Q. Where is the process started too obtain approval for pipe manufactured to a\nspecification not listed in Part 192?\nA. No approval is required for pipe to be used in gas service that is not manufactured to a\nspecification not listed in Part 192. In accordance with § 192.53, a pipeline operator is\nresponsible to select materials for severely corrosive conditions that are suitable for the\nintended service.\n2. Q. Under Parts 192 and 195, which standards are applicable to corrosion resistant\nbimetallic pipe?\nA. There are no standards listed in Part 192 or Part 195 that specifically apply to\ncorrosion resistant bimetallic pipe. However, a pipeline made of such pipe would have to\nmeet all requirements that apply generally to pipelines or pipeline facilities without regard\nto pipe material.\n3. Q. When does the Department of Transportation (DOT) get involved with the approval\nprocess?\nA. The OPS does not get involved in the process of selecting or approving material\nsuitable for a gas pipeline. With regard to the use of such material in a hazardous liquid\npipeline, a notice of intended use of such material must be made to this office in\naccordance with § 195.8. Our evaluation of the use of such material would be made\nusing the criteria set forth above.\nI note that of the ASTM Specifications listed in Section 3 of the pipe brochure enclosed with\nyour letter, none of the specifications referenced are for bimetallic pipe. ASTM A872 is for\ncorrosion resistant centrifugally cast pipe. Specifications A351, A743, and A744 are for\ncorrosion resistant castings. Specifications B423 and B444 are for corrosion resistant wrought\nseamless pipe. Specification B662 is not for pipe or corrosion resistant alloys in any form.\nRather than B662, the brochure probably intended to reference Specification B622, which is for\ncorrosion resistant wrought seamless pipe.\n\n<<<PAGE 3>>>\n\nI thank you for your inquiry. If you have further questions, please contact G. Joseph Wolf of my\nstaff at (202) 366-4560.\nSincerely,\nCesar De Leon\nDirector, Regulatory Programs\nOffice of Pipeline Safety\n\n<<<PAGE 4>>>\n\nRain Hill Group INC.\nTELEFAX COMMUNICATION SHEET\nPlease deliver the attached to: Mr. Joseph Wolf. Dept, of Transportation\nTOTAL PAGES INCLUDING THIS PAGE: 6 FROM: Wenke B. Thoman\nTransmitted by: WBT on: June 23. 1992\nDear Mr. Wolf,\nAttached is a descriptive brochure of the Bimetallic Pipe our client would like to offer to U.S.\npipeline operators for offshore applications.\nThis pipe has particular appeal in sourgas fields and other applications if severely corrosive oil and gas\nis to be carried.\nMy quick reading of the Federal Regulations suggests that pipelines must meet certain standards and\nthat this be law. The standard requirements incorporated by reference in Appendix A and B are set\nby various private self regulated industry bodies such as API, ASTM etc.\nOur questions are where do we start the \"approval\" process and which standards are applicable in\nBimetallic Pipe and when does DOT get involved with the approval process?\nI thank very much for your assistance and suggestions.\nYours truly,\nWenke B. Thoman\nIf you do not receive legible copies of all pages, please call:\n(212) 752-2722, and ask for Ilka\nTelefax number: ( 202 ) 366 4566\nCompany: ________________________________________________________________________________\n27 EAST 61ST STREET, NEW YORK, NY 10021\nTEL: (212) 752-2722 FAX: (212) 752-3288/3156","truncated":false,"body_characters":6497}