Interpretation Response #PI-10-0003 ([Central Hudson Gas & Electric Corp.] [Mr. David W. Merte, P.E.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Central Hudson Gas & Electric Corp.
Individual Name: Mr. David W. Merte, P.E.
Country: US
View the Interpretation Document
Response text:
Sep. 17, 2010
Mr. David W. Merte, P.E.
Central Hudson Gas & Electric Corp.
284 South Avenue
Poughkeepsie, NY 12601
Dear Mr. Merte:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated March 22, 2010, you requested an interpretation as to whether Central Hudson Gas & Electric Corporation can utilize plastic pipe that is exposed to ultraviolet light for up to four years. You stated that plastic pipe manufactured by Perfonnance Pipe testing predicts that Driscopipe 8100 series pipe has an outdoor unprotected exposure of at least four years (manufacturer's technical note included).
You stated that you have discussed outdoor storage of this pipe with the New York State Department of Public Service - Gas Safety Division Staff (GSD) and that the GSD staffhas indicated that PHMSA does not allow outdoor unprotected storage of plastic pipe for more than two years and has suggested that you request a PHMSA interpretation of this issue.
We agree with the GSD staff that plastic pipes should not be exposed to ultraviolet light for more than the plastic pipe manufacturer's recommended maximum period of exposure or a maximum of two years, whichever is less, unless the pipes meet the American Society for Testing of Materials (ASTM) D-2513-99 requirements. The ASTM D-2513-99 is incorporated by reference into 49 CFR Part 192. In this case, two years is less than the manufacturer's recommendation of four years. Section A1.5.7 of ASTM D-2513-99 states:
Outdoor Storage Stability-PE pipe stored outdoors and unprotected for at least two years from date of manufacture shall meet all the requirements of this specification. PE pipe stored outdoors for over two years from date of manufacture is suitable for use if it meets the requirements of this specification.
The technical note you provided (Technical Note PP 839-TN) states, "ASTM D2513 allows outdoor storage times in excess of two years where the manufacturer has shown that the pipe perfonnance properties are not affected by the extended outdoor storage time." This statement does not appear to refer to the 1999 version of ASTM D-2513 requirements and, therefore, the contents of the Technical Note do not fully qualify PE pipes to meet the requirements of ASTM D-2513-99 when the pipes are stored outdoors unprotected for more than two years. Based on the infonnation you provided, PE pipes that are stored outdoors unprotected in excess of the two year limit do not comply with the 49 CFR Part 192 requirements.
I hope that this information is helpful to you. If I can be of further assistance, please contact me at 202-366-4046.
Sincerely,
John A. Gale
Director, Office of Regulations
Regulation Sections
| Section | Subject |
|---|---|
| 192.321 | Installation of plastic pipe |