{"operation":"document","citation":"PI-97-0102","title":"BP Oil Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1997-10-01","effective_on":null,"summary":"PI-97-0102 response to BP Oil Company concerning 195.404.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-0102.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-0102.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-0102","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1997/g97_10_01_Abraham_195.404.pdf","body":"<<<PAGE 1>>>\n\nPI-97-0102\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh Street, S.W.\nWashington, DC 20590\nOctober 1, 1997\nMr. Larry Abraham\nCompliance Coordinator\nBP Oil Company\n200 Public Square\nCleveland, Ohio 44114-2375\nDear Mr. Abraham:\nThis is in response to your letter dated May 7, 1997, asking if the Research and Special\nPrograms Administration’s Office of Pipeline Safety (OPS) will accept BP's use of the\nSCADA Master system to record pump discharge pressures at each pump/booster station\nto meet the requirements of 49 CFR 195.404(b)(l). In your letter, you state that the scan\ntime for the SCADA system is 40 to 50 seconds in the South East Region and every 20\nseconds in the Mid-West Region. The discharge pressure recorded in both regions is\nbased on an average of one minute of data. These discharge pressures would be stored on\ntape and held for 36 months. The data would also be retrievable via computer in\ngraphical form with two weeks of data viewable at one time. The data would not be\ncollected during times of occasional communications failure.\nOPS considers an appropriate minimum time interval for electronically recorded pressure\ndata as that time interval which is frequent enough to collect the pressures attained during\nnormal and abnormal conditions, such that the recorded data could be assembled to create\na facsimile of the pressures that actually occurred, including the magnitude and time\ninterval of all elevated pressures.\nThis approach requires the operator to review the dynamics of their individual pipeline to\ndetermine what interval would be necessary and to ensure that all elevated pressures are\ncaptured. An inspector could then review the operating dynamics of the pipeline to\ndetermine if the chosen interval is small enough and that the recorded data reasonably\nagrees with actual field data.\nThe use of the SCADA system in lieu of pressure chart recorders would be acceptable as\nan option available to BP, if the SCADA system could be configured to collect and\narchive sufficiently detailed pressure records. The recording of average pressure every\nminute instead of the peak pressure each minute may not preserve the short-term,\n\n<<<PAGE 2>>>\n\nabnormal pressures that occur on BP's pipelines. BP should perform an operations\nanalysis to determine what SCADA configuration parameters would be necessary to\npreserve the pressure history. Such an analysis could also be reviewed during an\ninspection audit to verify the adequacy of the configuration parameters.\nIf we can be of further assistance in this matter, please contact me or L.E. Herrick of my\nstaff at (202) 366-5523.\nSincerely,\nRichard D. Huriaux, P.E.\nDirector for Technology and Regulations\nOffice of Pipeline Safety","truncated":false,"body_characters":2770}