Interpretation Response #PI-10-0022 ([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.
Location State: NY Country: US
View the Interpretation Document
Response text:
May 24, 2011
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 September 27, 2010, you stated that the technical note you provided to PHMSA in support of your initial March 22, 2010, interpretation request concerning the exposure of polyethylene (PE) pipe to ultraviolet light did not specify a reference to the 1999 version of the American Society for Testing of Materials (ASTM) D-2513. You provided supplementary information from the manufacturer to show that the technical note does refer to the 1999 version of ASTM D-2513 and you expressed the view that there is no measureable change in pipe performance properties after over four years of outdoor exposure. Therefore, you believe storage of Driscopipe 8100 series pipe for up to four years of outdoor exposure would comply with the 49 CFR Part 192 requirements.
After examining your latest information, we still believe that you have not demonstrated that this specific PE pipe meets the ASTM D-2513-99 requirements after stored outdoors unprotected for over two 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.
We acknowledge that Technical Note PP839-TN contains three graphs of manufacturer"s test data on pages 2 and 3. In order to use PE pipe that has been stored outdoors and unprotected for over two years from date of manufacture, however, you must go beyond providing general test data from the manufacturer. You must test the actual pipe that you have been storing for all of ASTM D-2513-99 requirements and provide the full results of this testing to PHMSA. In the absence of test results from testing of the actual pipe that you have stored, the use of your PE pipe that has been stored outdoors unprotected in excess of the two-year limit would 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, Division of
Standards and Rulemaking