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Interpretation Response #PI-23-0009

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

Interpretation Response Details

Response Publish Date:

Company Name: CH-IV International

Individual Name: Mr. Lex De Groot

Location State: TX Country: US

View the Interpretation Document

Response text:

Mr. Lex De Groot
Civil Engineer
CH-IV International
11700 Katy Freeway
Suite 1350
Houston, TX 77079

Dear Mr. De Groot:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated March 27, 2023, you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 193 with respect to the applicability of §§ 193.2013 and 193.2067 to wind forces design for an LNG facility.

You stated that the requirement to follow ASCE/SEI 7-05, "Minimum Design Loads for Buildings and Other Structures" 2005 edition (including supplement No. 1 and Errata), (ASCE/SEI 7-05 or ASCE 7-05) only applies to shop fabricated containers of LNG or other hazardous fluids with a capacity of not more than 70,000 gallons. You asked whether the § 193.2067(b)(2) wind forces requirement can be determined by applying the edition of ASCE/SEI 7 incorporated by reference in the State Building Code enforced at the time of the design and construction of such facilities. You stated this is supported by the January 5, 2015, amendment to § 193.2067(b)(1) that removes the "-05" edition from this requirement, allowing that a current edition of ASCE/SEI 7 could also be followed for § 193.2067(b).

Under § 193.2067(b)(1), ASCE 7-05 is the incorporated by reference standard. No other standard may be used for § 193.2067(b)(1). Section 193.2013(d)(1) specifically incorporates the 2005 edition of ASCE/SEI 7-05, and the 2015 final rule your letter references did not change or update the incorporated by reference standard.

As to the remaining question in your inquiry, under § 193.2067(b)(2), there is no standard incorporated by reference. Rather, the wind forces at a location of the specific facility must be based on the wind speeds established in either §§ 193.2067(b)(2)(i) or (b)(2)(ii).

However, you may use the edition of ASCE/SEI 7 required by the State's building code enforced at the time of the design and construction of such facilities to assist in determining the wind forces, only if the wind forces are calculated based on the wind speeds equal to or greater than those determined under §§ 193.2067(b)(2)(i) or (b)(2)(ii). Please note that PHMSA reviews structural calculations on a case-by-case basis to verify proper application of load equations and factors.

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

Sincerely,

John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections