Interpretation Response #PI-77-0100
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
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Location State: FL Country: US
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January 7, 1977
Mr. Philip F. Ashler State Treasurer State Fire Marshal
Tallahassee, Florida 32304
Your letter of October 4, 1976, to Webster B. Todd, Jr., Chairman, National Transportation Safety
Board, indicated that the Bureau of LP Gas does not consider LP gas containers jurisdictional under
49 CFR Part 192.
A recent interpretation of the term “system” in connection with the regulation of petroleum gas
systems under 49 CFR
192.11, published in the October issue of the OPSO Advisory Bulletin (copy enclosed), includes
tanks storing petroleum gas in liquid form as being part of a petroleum gas system regulated by 49
CFR 192.11
We trust this interpretation clarifies any misunderstanding of the scope of jurisdiction of Part
192 over LP gas containers. Mr. Todd is also being advised of the interpretation.
Sincerely, SIGNED
Cesar DeLeon Acting Director Office of Pipeline Safety Operations
Philip F. Ashler Treasurer of Florida Tallahassee 32304
October 4, 1976
Mr. Webster B. Todd, Jr. Chairman
National Transportation Safety Board
Washington, D.C. 20594
My dear Mr. Todd:
Your letter of September 21, 1976, regarding the matter of LP gas containers connected to OPS
jurisdictional systems has been reviewed by Mr. Earl Kicliter, LP Gas Bureau Chief. Mr. Mater does
recall a conversation with Mr. Charles Batten of the Office of Pipeline Safety regarding such
matter; however, Mr. Kicliter does not recall having stated the LP gas containers were
jurisdictional by the provisions of Title 49, Part 192, and in fact, Mr. Kicliter pointed out that
the federal regulations do not address the subject of LP gas storage containers except by reference
to NFPA Pamphlet 56.
Mr. Kicliter reminds me the Bureau of LP Gas has, since its inception in 1957, had the
jurisdictional responsibility for a gas containers and the NITA Pamphlet 5$ is the adopted code for
this area of LP gas container safety.
This office does not consider the LP gas containers jurisdictional under Title 49, Part 192, and /
hope this will help clarify any misunderstand.
With kindest personal regards. Sincerely,
Philip P. Ashler
State Treasurer
State Fire Marshal
Advisory Bulletin No. 76-10
October 1976
Relates to 49 CFR, Part 195, Subpart D
NOTICES UPDATE DEVELOPMENTS ON TRANS-ALASKA WELD PETITIONS AND ANNOUNCE PUBLIC HEARING...On October
6, 1976, the Office of Pipeline Safety Operations (OPSO) issued Notice 4-in Docket No. 76-12W (41
Fed. Reg. 44207,
October 7, 1976), advising that additional technical information had been placed in the Docket
which included a preliminary report on the National Bureau of Standards (NBS) analysis and
assessment of (i) fracture mechanics as that analytical technique may be applicable for determining
the effect of defects in girth welds on the structural integrity of the Trans-Alaska pipeline
system and the alternative maximum allowable weld defect sizes proposed by Alyeska Pipeline Service
Company, (ii) weld defect and arc burns sizes submitted by Alyeska in support of its petition for
exemptions from certain welding requirements of 49 CFR Part 195 for individual welds in the main
line pipe of the Trans-Alaska pipeline system, and (iii) methodologies for measuring the depth of
those defects and arc burns. The Notice also advised that
the Docket has been reopened to receive additional written comments until the close of business on
October 28, 1976, and that the Deputy Secretary of Transportation will conduct a public hearing on
this matter commencing at 8:30 a.m., Thursday, October 28, 1976, in the third floor auditorium of
Federal Building 10A at 800 Independence Avenue, S.W., Washington, D.C.
The informal hearing on October 28 will be for the purpose of receiving the views of interested
persons as to (1)
whether a fracture mechanics analysis can properly serve as an alternative to the standards set
forth in Subpart D of 49
CFR Part 195 for determining the integrity of girth welds in the main line of the Trans-Alaska
crude oil pipeline system and (2) if so, whether the docketed technical information provides a
valid basis for applying a fracture mechanics analysis to the particular girth welds for which
Alyeska seeks waivers of the 49 CFR standard. Public participants will be permitted a maximum of 15
minutes for each presentation. Written copies of presentations are requested but not required.
Persons desiring to make presentations at the hearing should write to or telephone the Docket Clerk
(Ms. Peggy Hammond), Office of Pipeline Safety Operations (Alyeska Docket No. 76-12W), 2100 Second
Street, S.W., Washington, D.C. 20590 (telephone 202-426-0135) to be received not later than noon,
Tuesday, October 26, 1976,
giving the following information: (1) Name; (2) Address; (3) Phone number during normal working
hours; (4) Capacity in which presentation will be made (e.g., private citizen, public interest
group, or public official); (5) Position--pro or con on each of the two issues stated above; and
(6) Time (maximum 15 minutes) desired for presentation.
On October 21, 1976, Notice 5 in Docket No. 76-12W was published in the Federal Register announcing
the receipt and inclusion in the Docket of the final report on the NBS analysis and assessment.
TAYLOR TO HEAD DOT ONSITE ALASKA MONITORING TEAM...Marshall W. Taylor, II, Chief of the Office of
Pipeline Safety Operations' Central Regional Office, will head the Department's onsite monitoring
team along the Trans-Alaska pipeline. Deputy Secretary of Transportation John W. Barnum announced
recently. The team was sent to Alaska in July to monitor all aspects of the construction of the
pipeline for the remainder of the 1976 construction season to assure that the pipeline is
constructed in accordance with DOT regulations.
The five-member monitoring team is composed of two U.S. Coast Guard radiographic specialists and
three DOT OPSO compliance inspectors. A third U.S. Coast Guard radiographic specialist will be
assigned if necessary to provide additional capability to evaluate the adequacy of the radiographic
records of the pipeline girth welds made in the field during the 1975 construction season. The team
is also charged with the task of assessing the adequacy of the Alyeska Pipeline Service Company's
remedial program to repair all welds that have been identified as having defects in excess of the
DOT standards.
MTB DIRECTOR ADDRESSES GAS ASSOCIATION ANNUAL MEETING…On October 11, 1976, James T. Curtis, Jr.,
Director, Materials Transportation Bureau (MTB), discussed current Federal pipeline safety
activities and their relationship to future gas industry goals before the annual meeting of the
American Gas Association in Los Angeles, California. The Bureau Director summarized the first year
of development of the MTB and activities of OPSO. Also discussed were the recent amendments to the
Federal gas pipeline safety standards; regulatory activities relating to importation of liquefied
natural gas; Arctic gas pipeline technology and specialized safety regulations; offshore pipeline
safety amendments to
the regulations; DOT and State sponsored gas pipeline safety training courses and seminars; and
some thoughts about probable future MTB and OPSO programs.
Relates to 49 CFR, §192.455
MTB PROPOSES TO AMEND GAS PIPELINE SAFETY STANDARDS RELATING TO CORROSION CONTROL FOR SMALL METAL
FITTINGS IN PLASTIC PIPELINES...On September 22, 1976, the OPSO Acting Director issued Notice 76-1,
Docket No. OPSO-37, in which the MTB proposes to amend the external corrosion control requirements
of 49 CFR Section 192.455 with regard to alloy metallic fittings that are part of plastic
pipelines. Under the existing .Section 192.455, any metallic fitting which is part of a plastic
pipeline must be coated and cathodically protected in accordance with applicable requirements
unless the operator of the pipeline can demonstrate by certain tests, investigation, or experience
in the area of application that a corrosive environment does not exist, or for a temporary
installation of five years or less, that corrosion of the fitting will not be detrimental to public
safety. However, when an installation intended to last more than five years is made without
cathodic protection, the operator is required to make electrical tests within six months after the
installation to adequately evaluate the fitting and apply cathodic protection if a corrosive
condition is found.
Thereafter, Section 192.465 requires that if a metallic fitting in a plastic pipeline is not
protected under Section 192.455,
it must be reevaluated every three years by electrical tests or other allowable methods and
cathodically protected where active corrosion is found.
In a petition for rulemaking (Docket No. Pet. 74-15), the fitting supplier argues that the
application of cathodic protection to short fittings with metallic parts made of Type 316 stainless
steel is not necessary for safety when the fittings are in an otherwise all plastic pipeline and
provided data in support of - its position. In light of technical information made available, MTB
is proposing that Section 192.455 be amended to allow the installation of small, electrically
isolated alloy fittings in plastic pipelines without coating and cathodic protection if (1) an
operator can show by tests, investigation, or experience in the area of application, that corrosion
control is provided by alloyage, and (2) the fitting is designed to prevent leakage caused by
localized corrosion pitting.
Interested persons are invited to participate in this rulemaking action by submitting such written
data, views, or arguments as they may desire. Communications should identify the regulatory docket
and notice numbers and be submitted in triplicate to the Director, Office of Pipeline Safety
Operations, Department of Transportation, 2100 Second Street, S.W., Washington, D.C. 20590. All
communications received by November 1, 1976, will be considered before final action is taken on the
notice. Late filed comments will be considered so far as practicable. All comments will be
available for examination by interested persons at the Office of Pipeline Safety Operations before
and after the closing date for comments. Reprints of the notice (41 Fed. Reg. 42221, September 27,
1976) have been sent to those on the appropriate OPSO mailing lists.
Relates to 49 CFR, §192.313 and §195.212
MTB PROPOSES TO AMEND GAS AND LIQUID PIPELINE SAFETY STANDARDS CONCERNING BENDING PIPE HAVING
LONGITUDINAL SEAMS...On October 18, 1976, the OPSO Acting Director issued Notice 76-2, Docket No.
OPSO-38, in which the MTB proposes to amend Section 192.313(a)(4) of the Federal gas pipeline
safety standards and Section
195.212(b)(3) of the Federal liquid pipeline safety standards to except bends made with an internal
bending mandrel from the requirement that for field bends of steel pipe containing a longitudinal
weld, the weld must be as near as practicable to the neutral axis of the bend. The notice is
based, in part, on a petition dated October 18, 1975, by the Alyeska Pipeline Service Company (Pet.
76-11W) requesting that the pipe bending requirement of 49 CFR 195.212(e) (now §195.212(b)(3)) be
repealed and, in the interim, that Alyeska be granted a waiver from compliance with the requirement
with respect to the Trans-Alaska crude oil pipeline.
Interested persons are invited to participate in this rulemaking action by submitting such written
data, views, or arguments as they may desire. Communications should identify the regulatory docket
and notice numbers and be submitted in triplicate to the Director, Office of Pipeline Safety
Operations, Department of Transportation, 2100 Second Street, S.W., Washington, D.C. 20590. All
communications received by November 8, 1976, will be considered before final action is taken on the
notice. Late filed comments will be considered so far as practicable. Reprints of the notice
(41 Fed. Reg. 46463, October 21, 1976) are being sent to those on the appropriate OPSO mailing
lists. Relates to 49 CFR, §195.218
RIVER CROSSING WAIVER GRANTED TO TRANS-ALASKA PIPELINE...On September 1, 1976, the MTB granted a
waiver to Alyeska from compliance with the to welding requirement of 49 CFR 195.218 with respect to
girth weld No. 49344T at the completed Jim River Crossing No. 2 on the Trans-Alaska crude oil
pipeline. The girth weld serves to tie in two
sections of 48-inch concrete coated pipe in the 620-foot crossing. Section 195.218 requires that
longitudinal weld seams on adjacent lengths of pipe must be offset. However, at weld No. 49344T,
the seams on adjacent pipe lengths are abutting, not "offset" as required. MTB reviewed the
information and arguments submitted by Alyeska in connection with its petition and found that the
requested waiver is not inconsistent with pipeline safety and is in the public interest. The
reasons cited for this decision are quality of girth weld; ductility of the pipe and girth weld
metals which would provide for localized yielding where high residual stresses may exist;
mechanical properties of the girth weld and pipe metals minimize the likelihood of any
concentration of residual stresses existing at the intersection of welds and surrounding
heat-affected zone; longitudinal seams are ground flush with the inside pipe circumference at the
joint mitigating the likelihood of any concentration of residual stresses caused by excess metal at
the intersection of welds; and replacing weld No. 49344T to comply with Section 195.218 could
reduce the pipeline's integrity because of the difficulties in cutting out a segment of the
concrete coated crossing and rotating and realigning it in the river crossing. Accordingly,
effective September 1, 1976, Alyeska was granted a waiver from compliance with 49 CFR 195.218 with
respect to weld No. 49344T at the Jim River Crossing No. 2 on the Trans-Alaska crude oil pipeline
(41 Fed. Reg. 38202, September 9, 1976).
IOWA COMMISSION SEEKS UTILITY REGULATION ENGINEER...The Iowa State Commerce Commission has an
immediate opening for a Utility Regulation Engineer III in its gas safety and service program.
Minimum requirements for the position are a B.S. degree in engineering; four years experience in
the area of gas utility regulation with a State or
.Federal regulatory agency; and possession of a certificate of registration as a Professional
Engineer issued by the State
of Iowa, or equivalent. Salary range is $17,524 to $24,648. Resumes and inquiries should be
directed to Dean A. Briley, Executive Secretary, Iowa State Commerce Commission, 300 - 4th Street,
Des Moines, Iowa 50319, telephone (515) 281-
5256.
UTILITY LOCATION AND COORDINATION WORKSHOPS SCHEDULED FOR NEW YORK AND FLORIDA...The American
Public Works Association (APWA) announces that its next series of Utility Location and Coordination
Council (ULCC) workshops are scheduled to be held in New York City on November 16 and 17, 1976, at
the Sheraton Inn, LaGuardia Airport, and on November 18 and 19, 1976, in Orlando, Florida, at the
Sheraton Olympic Villas. Topics for the workshops include need for coordination, the national ULCC
program, how to form a new committee, standardized field markings, standardized damage reports,
developing utility location standards, computer assisted mapping and records, permit and record
systems, one-call excavation notification systems, and related topics. Fees for the workshops for
APWA members (and others qualifying) are $85; nonmembers, $100. For further information and
registration, contact C. Richard Kuykendall, American Public Works Association, 1313 East 60th
Street, Chicago, Illinois 60637, telephone (312) 947-2523.
SOUTHERN STATE AGENCY PIPELINE SAFETY LEADERS MEET...Gas pipeline safety
liaison representatives from State agencies in OPSO's Southern Region held their second annual
2-day meeting in Atlanta, Georgia, on October 5-7, 1976. Representatives of all eight States in the
Southern OPSO Region attended the Federal/State coordination sessions. Safety regulatory topics
discussed in the meeting included LNG facilities, corrosion control, the Federal grant program,
streamlining of Federal report forms, and an update on Federal regulations and technical studies.
The new Southern Regional Chairman is Lamar Cockrell of the Florida Public Service Commission, and
the Vice-chairman is James Stites of the South Carolina Public Service Commission. The 1977
Southern Region Federal/State meeting is tentatively scheduled for October in the Tampa, Florida,
area.
NTSB REPORTS ON MICHIGAN-WISCONSIN COMPRESSOR STATION FIRE...On June 23, 1976, the National
Transportation Safety Board (NTSB) issued two safety recommendation letters on its investigation of
a natural gas incident which occurred near Cedardale, Oklahoma, on January 7, 1976. As work was
nearing completion on the addition of compressor facilities, employees at the Michigan-Wisconsin
Pipe Line Company's Cedardale, Oklahoma, compressor
station were directed to open a valve on a shut-in 12-inch gas-gathering pipeline in an attempt to
increase the flow into
the main line. Natural gas and natural gas liquids at 700-psig pressure passed through the valve,
out through the end of an open 12-inch pipe, and into a ditch, where seven men were working near an
open flame heater. The natural gas liquids saturated their clothing, and the flame from the heater
set them on fire. "Five men were killed and two men were burned seriously as a result of this
accident.
The NTSB recommended that Michigan-Wisconsin Pipe Line Company, operator of the system, initiate
immediate action to conduct periodic training programs on the importance of following written
procedures covering such situations; examine procedures for valve and piping changes to assure that
each critical action is checked appropriately; and prohibit such changes, except in emergencies,
while construction is conducted nearby. The NTSB also recommended that the Interstate Natural Gas
Association of America stress the importance of following such written procedures to their member
companies.
Single copies of the letter reports (Safety Recommendations P-76-27 through 29 and P-76-26) may be
obtained by directing a request to Publications Branch, BGM-222, National Transportation Safety
Board, Washington, D.C. 20594, telephone (202) 426-8169.
Relates to 49 CFR, §192.11
INTERPRETATION OF REGULATIONS
Question: Under Section 192.11, what constitutes a petroleum gas system?
OPSO Interpretation:..."For the purpose of Section 192.11(a), a 'system' normally consists of a
tank storing petroleum gas in liquid form and the appurtenant pipelines and other facilities used
by the operator of the system to deliver gas to one or more customers.”
Cesar DeLeon Acting Director Office of Pipeline Safety Operations
The Secretary of Transportation has determined that publication of this periodical is necessary in
the transaction of the public business required by law of this Department. Use of funds for
printing this periodical has been approved by the
Director of the Office of Management and Budget through November 30, 1976.
Regulation Sections
| Section | Subject |
|---|---|
| 192.11 | Petroleum gas systems |