§195.406 Maximum Operating Pressure, Guidance

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§195.406 Maximum Operating Pressure, Guidance

 Enforcement Guidance O&M Part 195
 Revision Date 09-28-2011
 Code Section §195.406
 Section Title Maximum Operating Pressure
ExistingCodeLanguage (a) Except for surge pressures and other variations from normal operations, no operator may operate a pipeline at a pressure that exceeds any of the following:

(1) The internal design pressure of the pipe determined in accordance with §195.106. However, for steel pipe in pipelines being converted under §195.5, if one or more factors of the design formula (§195.106) are unknown, one of the following pressures is to be used as design pressure:

(i) Eighty percent of the first test pressure that produces yield under section N5.0 of Appendix N of ASME B31.8, reduced by the appropriate factors in §§195.106(a) and (e); or

(ii) If the pipe is 323.8 mm (12: in) or less outside diameter and is not tested to yield under this paragraph, 1379 kPa (200 psig).

(2) The design pressure of any other component of the pipeline.

(3) Eighty percent of the test pressure for any part of the pipeline which has been pressure tested under Subpart E of this part.

(4) Eighty percent of the factory test pressure or of the prototype test pressure for any individually installed component which is excepted from testing under §195.305.

(5) For pipelines under §§195.302(b)(1) and (b)(2)(i), that have not been pressure tested under Subpart E of this part, 80 percent of the test pressure or highest operating pressure to which the pipeline was subjected for 4 or more continuous hours that can be demonstrated by recording charts or logs made at the time the test or operations were conducted.

(b) No operator may permit the pressure in a pipeline during surges or other variations from normal operations to exceed 110 percent of the operating pressure limit established under paragraph (a) of this section. Each operator must provide adequate controls and protective equipment to control the pressure within this limit.

 Origin of Code Original Code Document, 35 FR 17183, 11-07-70
 Last Amendment  Amdt. 195-65, 63 FR 59475, 11-04-1998.
Interpretation:  PI-91-008  Date:  03-25-1991The operator of a regulated pipeline may not own the device on a refiner’s grounds that is necessary to control pressure is responsible for compliance with Part 195 standards governing that device, because the operator is using or relying on the device to operate its pipeline according to §195.406(b).
 Advisory Bulletin/Alert Notice Summaries Advisory Bulletin ADB-11-01, Establishing Maximum Allowable Operating Pressure or Maximum Operating Pressure Using Record Evidence, and Integrity Management Risk Identification, Assessment, Prevention, and MitigationPHMSA is issuing an Advisory Bulletin to remind operators of gas and hazardous liquid pipeline facilities of their responsibilities, under Federal integrity management (IM) regulations, to perform detailed threat and risk analyses that integrate accurate data and information from their entire pipeline system, especially when calculating Maximum Allowable Operating Pressure (MAOP) or Maximum Operating Pressure (MOP), and to utilize these risk analyses in the identification of appropriate assessment methods, and preventive and mitigative measures.
 Guidance Information
  1. The operator must have written procedures for establishing maximum operating pressure.
  2. To determine if any of the requirements of Part 195 apply to a pipeline or a piping facility, refer to §195.1 and related interpretations and amendments. If pipelines are found to be “excepted” under §195.1(b), Part 195 regulations do not apply.
  3. For criteria that apply to converted pipelines, refer to §195.5.
  4. To determine the MOP, a pressure must be calculated under each of the applicable criteria in §195.406(a).  MOP is the lowest of these pressures.
  5. §195.406(b) expressly allows operators to exceed MOP by 10% in other than normal situations. For example, a temporary pressure boost in an attempt by the operator to dislodge a stuck pig in a pipeline would not violate §195.406(b), as long as the resultant pressure does not exceed 110% of MOP.
  6. Surge pressures that occur for brief periods during start-up and shutdown which exceed the MOP, but not above 110% of MOP, may be considered as being normal operating conditions.  Continuing operations above MOP is not allowed.
  7. It is not a violation for operators to set discharge control pressure as high as MOP.
  8. MOP of a pipeline segment must take into consideration both pump station discharge and pressure gradient profile along the entire segment.
  9. The design pressure of components is not prescribed in specific terms as it is for pipe under §195.106. Although sound design principles may require that a manufacturer’s pressure rating and applicable factors in consensus standards be considered in determining the design pressure of a component, a pipeline operator is free under Part 195 to use equally sound principles to derive an independent design pressure.
  10. Administrative change control procedures are considered a part of the pressure control system. (§195.406(b))
  11. The operator must establish the MOP of a low-stress pipeline according to this section before transportation begins or before July 3, 2009, if the pipeline exists on July 3, 2008. (See §195.11(b)(5)).
  12. Final Order Guidance:

a. Kinder Morgan Energy Partners, LP [4-2006-5023] (Aug. 31, 2010):  Inherent in the requirement imposed under 49 C.F.R. § 195.406(b)—i.e., to provide adequate controls and protective equipment to ensure that the pressure in a pipeline during surges or other variations from normal operations does not exceed 110 percent of the established maximum operating pressure—is an obligation on the part of the operator to use reasonable means to determine what controls and protective equipment are adequate for a particular pipeline system and to document the basis for that determination.  CO/CP

b. Enterprise Products Operating, LLC [4-2007-5015] (Dec. 2, 2009):   An operator must consider the potential for pressure surges in making a determination under 49 C.F.R. § 195.406(b) about the adequacy of the controls and protective equipment for a particular pipeline system.  CO/CP

c. Dixie Pipeline Company [2-2004-5009] (Oct. 21, 2004):  The pressure of a pipeline may not exceed the maximum operating pressure (MOP) as established under 49 C.F.R. § 195.406(a) during normal operations.  The pressure of a pipeline may not exceed 110 percent of MOP during surges or other variations from normal operations under 49 C.F.R. § 195.406(b).  CP

 Examples of aProbable Violation
  1. Lack of procedures is a violation of 195.402.
  2. Lack of records is a violation of 195.404.
  3. Operator has/is operating a pipeline above the MOP that is prescribed under §195.406(a), except for surge pressures or other variations from normal operations. This may include failure of the operator to provide adequate test pressure or highest operating pressure records, if §195.406(a)(5) applies.
  4. Operator did not have any equipment to protect the MOP.  This includes foreign lines that interconnect with their lines.
  5. The pipeline pressure exceeded 110% of MOP under surge pressures or other variations from normal operations.
  6. Operator’s pressure control and protective equipment is not adequate to control the pipeline segment’s pressure within 110% of MOP as prescribed in §195.406(b).
  7. Set points of relief devices set incorrectly.
  8. Operator has not established MOP in accordance with this section or does not have adequate documentation to demonstrate compliance with this section.
  9. Pressure control equipment did not operate properly.
  10. Repairs are not suitable for the established MOP.
 Examples of Evidence
  1. Documentation of facility MOP determination.
  2. Facility specifications, records, nameplates.
  3. Engineering drawings and records.
  4. Component design and test data.
  5. Elevation profiles.
  6. Test records or operating pressure logs that establish MOP.
  7. Operating pressure records (electronic and/or paper, SCADA).
  8. Operating schematics.
  9. Pressure control/relief equipment maintenance procedures; equipment inspection and test records.
  10. Operator’s surge analyses, pipeline response model (under abnormal or transient conditions).
  11. Documented comments from the operator.
  12. Accident investigation report.
  13. Abnormal or emergency operation reports.
  14. Unscheduled equipment shutdown records.
  15. Manufacturer’s component installation recommended procedures.
  16. Lack of procedures or records.

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