B31 codes vs. 49 CFR 192 1

[davefitz]

Reading the federal code 49 CFR 192 with respect to natural gas pipelines, there does not seem to be a defined legal scope break where 49 CFR 192 does not govern.

I was under the impression that once the service line passes past public property and enters private property and serves one customer, then 49 CFR 192 scope ends and the B31 codes takeover.

Does anyone have experience in the legal interpretation of this scope break? It has a significant impact on requried testing, maintenance , and reporting requirements, not to mention fines for violations.

 

[metengr]

Davefitz;
I work for an IPP, and as such we have various transmission lines and natural gas supply lines that criss-cross our property lines in multiple states.

I would contact the local Jurisdiction for information. We have contacted our Jurisdictions in the past, and they have provided specific guidance.

 

[EGT01]

Davefitz,

If you are the customer, maybe check with your supplier. Seems that they would certainly know where their responsibility to 49 CFR 192 would end.

I happened to check the Office of Pipeline Safety website

http://ops.dot.gov/regsindex.htm

and noticed they have some interpretations that may help but I didn't find them to be easily searched. Just by accident I found this interpretation regarding definition of "Master Meter" that may help but it seems to be filed in the wrong section as under 191.3 but the text in the file references 192.3.

http://ops.dot.gov/document/191/3/96-02-13.pdf

As a side comment, I found it curious that you would say "49 CFR 192 scope ends and the B31 codes takeover". I suppose I always thought of the B31 codes to be related only to design and construction of pipelines versus a more broader scope of 49 CFR 192 which includes not only minimum design and construction requirements but operation and maintenance among others. In fact, it looks like B31.3 specifically states that it is not intended to apply to things like operation and maintenance but I see now that B31.1 does include a nonmandatory appendix of recommended practice for operation and maintenance.

 

[davefitz]

EGT01:
The CFR code has explicit design, testing, maintenance, reporting and fines defined , and seems to be applicable to large interstate pipelines crossing thru public areas and with components ( compressors, PRV stations) remotely removed from any operating personnel. These considerations are quite different than the case of a pipeline within private boundaries that is directly maintaiend by operting personnel that are local to the equipment at all times.

The B31.1 code, for example, does not have fines assessed for violations but also has more conservative design requirements for overpressure protection. This is a more reasonable approach if the equipmetn is on private land and constantly maintained and operated by local equipmetn operators who cannot be expected to meet the scheduled testing and reporting requirements of CFR and certainly do not want to be exposed to fines.

 

[magpieqa]

The new data for DOT, Homeland Defense and OPS needs a common definition for MAOP, MOP and ERF in pipeline pressure calculations for ingegrity analysis.

Mark Harris
Manager;
Quality & Compliance
Magpie Systems

http://www.magpiesystems.com

 

[JohnBreen]

Actually, the CFR has had complete juridiction over Gas Transmission Piping Systems for some time. The CFR even includes a set of rules that was originally copied from B31.8.

ASME has several documents available to assist in the interpretation of the CFR rules.