Can I use normal operating pressure in my potential impact circle calculations if that pressure is significantly below MAOP?
No. The rule requires that MAOP be used in calculating potential impact circles (PIC) to identify HCAs. Pipelines can operate up to their MAOP, and integrity must be assured for such operation. Operators whose MAOP is significantly higher than their operating pressure could choose to derate their pipeline to reduce the calculated size of PICs. In such a case, subsequent increases in MAOP would be subject to the requirements of Subpart K for uprating and would require that PICs be re-calculated.
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