{"operation":"document","citation":"PI-96-009","title":"Maryland Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1996-06-12","effective_on":null,"summary":"PI-96-009 response to Maryland Public Service Commission concerning 192.557.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-009.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-009.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-009","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1996/PI96009.pdf","body":"<<<PAGE 1>>>\n\nMr. H. Russell Frisby, Jr.\nChairman\nMaryland Public Service Commission\nWilliam Donald Schaefer Tower\n6 St. Paul Street\nBaltimore MD 21202-6086\nDear Mr. Frisby:\nWe have considered your letter of May 6, 1996, notifying us the Commission will grant the\nBaltimore Gas and Electric Company (BGE) a waiver from compliance with 49 CFR 192.557(c)\nand 192.619(a)(3). The waiver will apply to certain gas pipeline systems constructed before 1970\nthat operate at less than 30 percent of specified minimum yield strength. BGE requested the\nwaiver to authorize prior upratings of these systems that were based on pressure tests done at the\ntime of construction instead of at the time of uprating.\nOur review of this matter indicates that a waiver is unnecessary. The regulations in 49 CFR Part\n192 do not require that upratings of these systems be based on pressure tests done concurrently\nwith uprating.\nBGE said it was requesting the waiver because of a March 11, 1974, letter we sent the Tennessee\nPublic Service Commission. That letter says a strength test must be performed in uprating to a\npressure permitted by § 192.619(a)(2)(ii). This statement was intended to indicate that because\n§ 192.619(a)(2)(ii) requires a pressure test as a basis of maximum allowable operating pressure\n(MAOP), any system uprating to a pressure permitted by § 192.619(a)(2)(ii) must be based on a\npressure test.\n\n<<<PAGE 2>>>\n\n2\nApparently, the statement has been misconstrued to mean the test must be performed concurrently\nwith uprating. But there is no doubt that § 192.619(a)(2)(ii) permits operators to rely on previous\ntest pressures in calculating MAOP. And there is nothing in the regulations that alters this policy\nwhen MAOP is determined by uprating.\nSincerely,\nRichard B. Felder\nAssociate Administrator for\nPipeline Safety\ncc: Alex Dankanich\nAssistant Chief Engineer\nGas Pipeline Safety","truncated":false,"body_characters":1884}