MAOP and 192.619(c), Grandfather clause

In the past couple of years there has been a lot of discussion about 192.619(c), better known as the grandfather clause, and what may happen to this paragraph relating to MAOP.  There are rumblings, rumors, suggestions, recommendations and general comments about deleting or modifying this paragraph.

Why would anyone want this to happen?  Well, this section of 192.619 Maximum allowable operating pressure, if applicable to an operator’s system, could allow MAOP to be established without a pressure test, and above a design pressure calculated under Subparts C and D.

The discussion about this is long and intense, as removing this paragraph, and requiring pressure testing (or some alternate method of validation) could be time consuming and costly.  Looking back over past questions and answers about the regulations the interpretation below from 1973 addressed this 5-year window.  Consider the ramifications to this distribution systems (in reality, any pipeline system) if the grandfather clause was revoked and testing was required.

From 1973, WinDOT brings you the following:

192.1, 1973 5

June 19, 1973

Mr. Larry E. Waldrop
Utilities Engineer
Alabama Public Service Commission
P. O. Box 991
Montgomery, Alabama  36102

Dear Mr. Waldrop:

This is in reply to the two questions asked in your letter of June 1, 1973.

Question:  “…under 192.619 and 192.621.  If a gas system is an all steel system and designed and tested for a 100 lb. system and has only operated at 30 lbs. for the last ten years, what is his M.A.O.P.?”
Answer:  This system is governed by §192.619(c) which, in effect, allows the pipeline to operate at the highest actual operating pressure to which it was subjected during the 5 years preceding July 1, 1970.  In the given case, the system operated only at 30 lbs. in that 5-year period.  The M.A.O.P. is, therefore, 30 lbs.

Question:  “…where a school is master metered and distributes the gas through its own piping to different buildings and they are ultimate consumers, would they be under gas pipeline safety regulations?”
Answer:  One of the characteristics of a master meter system that makes it subject to the regulations is a transfer of the gas from the operator to other persons who are the ultimate consumers of the gas.  In the situation described, however, the school taking delivery on gas through the “master” meter is not reselling or distributing any of the gas to any other person.  Where the gas is being used entirely by school employees for school purposes on school property, the gas system is not subject to the federal gas pipeline safety regulations.

If you have further questions in this regard, please contact us.

Sincerely,

/signed/

Joseph C. Caldwell
Director
Office of Pipeline Safety

******************************************************
STATE OF ALABAMA
ALABAMA PUBLIC SERVICE COMMISSION
P. O. BOX 991
MONTGOMERY, ALABAMA — 36102

June 1, 1973

Mr. Joseph C. Caldwell
Director
Office of Pipeline Safety
Department of Transportation
Washington, D.C. 20590

Dear Mr. Caldwell:

I would like your definition and opinion to this question which is covered under 192.619 and 192.621. If a gas system is an all steel system and designed and tested for a 100 lbs. system and has only operated at 30 lbs. for the last ten years, what is his M.A.O.P.?

Under the new service line definition 192.3 the question is where a school is master metered and distributes the gas through its own piping to different buildings and they are the ultimate consumers would they be under gas pipeline safety regulations?
Your prompt attention and reply to these questions will be greatly appreciated.

Yours very truly,

Larry E. Waldrop
Utilities Engineer

All this and more including historical interpretations in WinDOT, The Pipeline Safety Encyclopedia.

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