{"operation":"document","citation":"PI-94-033","title":"Public Utilities Commission of Ohio — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1994-10-18","effective_on":null,"summary":"PI-94-033 response to Public Utilities Commission of Ohio concerning 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-033.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-033.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-033","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94033.pdf","body":"<<<PAGE 1>>>\n\nOctober 18, 1994\nMr. Edward M. Steele\nChief, Gas Pipeline Safety Section\nThe Public Utilities Commission of Ohio\n180 E. Broad Street\nColumbus, Ohio 43266-0573\nDear Mr. Steele:\nI am responding to your letter of May 11, 1994, concerning the maximum allowable operating\npressure (MAOP) of a distribution system. The operator established an MAOP of 5 psig, based\non a maximum safe pressure under § 192.621(a)(5). However, as shown on an MAOP\nworksheet, the system was operated at 10 psig on a peak day during 1970. The operator now\nalleges the MAOP was mistakenly set at 5 psig and should have been 10 psig. You ask if the\noperator may increase the MAOP to 10 psig without uprating under Subpart K of Part 192.\nWhen we addressed this issue in our letter to you dated May 2, 1994, we said the operator must\nuprate the system under Subpart K. We still believe that is a correct application of the\nregulations. System MAOP is governed by the lowest value determined under § 192.619 and\n§ 192.621. The worksheet shows that 5 psig was the lowest value. Thus, 5 psig was\nunmistakenly [sic] the correct MAOP, and any increase in MAOP must meet Subpart K.\nHowever, inasmuch as the system has been operated at 10 psig every winter since 1970, the\noperator may wish to seek a waiver of Subpart K based on this history of operation.\nSincerely,\nCesar De Leon\nDirector for Pipeline Safety\nRegulatory Programs\ndal/192.619\n94-10-18","truncated":false,"body_characters":1426}