{"operation":"document","citation":"PI-94-006","title":"Alyeska Pipeline Service Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1994-02-04","effective_on":null,"summary":"PI-94-006 response to Alyeska Pipeline Service Company concerning 195.424.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94006.pdf","body":"<<<PAGE 1>>>\n\nFebruary 4, 1994\nMr. John S. Dayton\nSenior Vice President\nOperations and Engineering\nAlyeska Pipeline Service Company\n1835 South Bragaw Street\nAnchorage, Alaska 99512\nDear Mr. Dayton:\nThis responds to your two letters dated December 28, 1993, regarding the Department’ s pipeline\nsafety regulations. The first letter concerns application of the regulations in 49 CFR Part 192 to\nAlyeska’ s fuel gas line, and the second concerns pipe movement under 49 CFR 195.424(a).\nYou asked us to interpret Part 192 to exclude certain portions of Alyeska’ s fuel gas line. By\nletter of August 31, 1993, Edward J. Ondak, Director of the Western Regional Pipeline Safety\nOffice, advised you of the jurisdiction of Part 192 over the fuel gas line. That letter (copy\nenclosed), which represents this agency’ s position on the matter, states that certain piping is\nexcluded from Part 192.\nYou also asked us to interpret § 195.424(a) to exclude small movements of pipe associated with\ncertain operation and maintenance activities, including the restoration of pipe to its original\nposition. Section 195.424(a) states: “ No operator may move any line pipe, unless the pressure in\nthe line section involved is reduced to not more than 50 percent of the maximum operating\npressure.” The plain meaning and history of this rule would not support an interpretation that\nsmall movements are excluded from the rule. However, §195.424(a) does not apply unless an\noperator moves pipe as a necessary step in a maintenance activity. Thus, the rule applies, for\nexample, when pipe is lowered to accommodate a road crossing, and when displaced pipe is\nmoved back into its original position. But the rule does not apply to movement that results from\noperating pressure or temperature fluctuations, because such movement is not part of a\nmaintenance activity. Also, the rule does not apply to movement that is incidental to pipeline\nrepair, such as movement that occurs when temporary pipe support is added or removed, or when\npipe strain is relieved by excavation. Movements such as these are not a necessary part of the\nrepair procedure.\nPlease let me know if I can provide any further information.\nSincerely,\nCesar De Leon\nDirector, Office of Pipeline Safety\nRegulatory Programs\nEnclosure\ndal/195.424\n94-02-04","truncated":false,"body_characters":2291}