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Interpretation Response #PI-23-0010


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

Interpretation Response Details

Response Publish Date: 10-04-2023
Company Name: B3PE LLC    Individual Name: Mr. Brad Bean
Location state: CO    Country: US

View the Interpretation Document


Response text:

Mr. Brad Bean
Senior Partner and Managing Member
B3PE LLC
419 East Columbia Street
Colorado Springs, Colorado 80907

Dear Mr. Bean:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated March 10, 2023, you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 192 with respect to the § 192.3 definition of "transmission line."

You stated that the paragraph (2) definition of a "transmission line" was revised by the Amendment 192-132 of the August 24, 2022, final rule (87 Fed. Reg. 52267), from "(2) Operates at a hoop stress of 20 percent or more of SMYS; or" to "(2) Has an MAOP of 20 percent or more of SMYS;"

You stated that the maximum allowable operating pressure (MAOP) is a measure of pressure and specified minimum yield strength (SMYS) is a measure of stress, and the new wording of "transmission line" therefore evaluates a pressure value against a stress value while the original wording made it clear that the evaluation criteria was between two stress values. You believe the new wording meant to evaluate an MAOP that would produce a hoop stress of 20 percent or more of SMYS, such that two stress values would be compared in defining a "transmission line" under § 192.3. You suggested if PHMSA meant to indicate the latter (i.e., an MAOP that would produce a hoop stress of 20 percent or more of SMYS) in the new wording of "transmission line" that PHMSA should amend the paragraph (2) definition of “transmission line” to clearly state the intended evaluation criteria. You requested confirmation that the August 24, 2022, final rule regulatory language intended operators to evaluate if the hoop stress produced by the MAOP is equal to or greater than 20 percent of SMYS. The relevant regulatory language is reprinted below.

§ 192.3 Definitions.

Transmission line means a pipeline or connected series of pipelines, other than a gathering line that:
(1) ....
(2) Has an MAOP of 20 percent or more of SMYS;

Response: The August 24, 2022, final rule regulatory language intended operators to evaluate if the hoop stress produced by the MAOP is equal to or greater than 20 percent of SMYS; therefore, a pipeline with an MAOP that produces a hoop stress of 20 percent or more of SMYS would be a transmission line under paragraph (2) of 49 CFR § 192.3.

PHMSA will consider clarifying the § 192.3 regulatory definition of "transmission line" in a future rulemaking.

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

Section Subject
§ 192.3 Definitions