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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-22-0013

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: BGC Engineering Inc.

Individual Name: Mr. Mark Zellman

Location State: CO Country: US

View the Interpretation Document

Response text:

Mr. Mark Zellman
BGC Engineering Inc.
600 12th Street
Suite 300
Golden, CO 80401

Dear Mr. Zellman:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated July 1, 2022, you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 192 with respect to the § 192.917 requirements for operators identifying outside force damage to pipelines in high consequence areas.

You stated the 2004 edition of ASME B31.8S is incorporated by reference and approved for § 192.917 regarding protocols for addressing seismicity. Item "d" in ASME B31.8S, Section A9.2 states that "profile of ground acceleration near fault zones (greater than 0.2 g acceleration)" is a minimal data set that should be collected for each pipeline segment. However, no recommendation for a return period (e.g., 2475, 975, 475, etc.), spectral period (e.g., PGA, 0.1, etc.), or site class (760 m/s [B/C], 537 m/s [C), etc.) is provided. You asked which return period, spectral period, and site class are recommended by PHMSA.

PHMSA incorporated by reference the 2004 edition of ASME B31.8S standard and, as you stated in your request, the standard under Section A9.2(d) specifies, at a minimum, to collect several minimal data sets including, "(d) profile of ground acceleration near fault zones (greater than 0.2 g acceleration)." In addition, a review of the 2018 revision of the 2016 version of the ASME B31.8S shows the data collection requirement is the same as the 2004 edition for addressing seismicity.

The Federal pipeline safety regulations in § 192.935(a) state that "an operator must take additional measures beyond those already required by Part 192 to prevent a pipeline failure and to mitigate the consequences of a pipeline failure in a high consequence area." In addition, § 192.917(b) states “…At a minimum, an operator must gather and evaluate the set of data specified in Appendix A to ASME/ANSI B31.8S...." Therefore, the pipeline operator's procedures as well as the data composition collected and used for the assessment must be based upon pipeline operational, terrain, and environmental factors including treating seismicity as a time-independent threat per § 192.917(a).

Any considerations used in the operator's pipeline procedures for "return period, spectral period, and site class" must be based upon the operator's procedures to maintain pipeline safety through the implementation of assessment, mitigation, and reassessment procedures for the seismicity threat. As a minimum, an operator's procedures must meet the requirements in §§ 192.917, 192.935(a), (b)(2) and (c), 192.937, and 192.939.

If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.


John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.917 How does an operator identify potential threats to pipeline integrity and use the threat identification in its integrity program?