# Kinder Morgan, Inc. — Pipeline Safety Interpretation

**Citation:** PI-07-0103  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-04-11

PI-07-0103 response to Kinder Morgan, Inc. concerning 192.3.

## Document text

<<<PAGE 1>>>

PI-07-0103
April 11, 2007
Mr. Bruce Hancock
Manager, Codes and Standards
Kinder Morgan, Inc.
P.O. Box 281304
Lakewood, CO 80228-8304
Dear Mr. Hancock:
On October 20, 2006 you wrote to the Pipeline and Hazardous Materials Safety
Administration (PHMSA) requesting interpretations of 49 CFR 192.153, 192.503 and 192.505 as
they pertain to temporary pipeline pig launchers and receivers.
In your letter you ask, “When a temporary launcher or receiver is built utilizing standard
pipe and fittings with the intention of running pipeline cleaning and inspection tools in gas
pipelines does that fabrication fall under the jurisdiction of 49 CFR 192.153, Components
fabricated by welding?”
The pipeline safety regulations at § 192.3 define a “pipeline” to mean “all parts of those
physical facilities through which gas moves in transportation, including ... fabricated
assemblies.” As fabricated assemblies through which gas moves in transportation, temporary
pig launchers and receivers are regulated by 49 CFR Part 192, including Subpart D, Design of
Pipeline Components. The temporary pig launchers and receivers you describe, however, would
meet the exceptions in Subpart D, § 192.153(a), if the standard pipe and fittings used to build the
launchers and receivers are joined by circumferential welds and any connections to the launchers
or receivers are branch connections welded to the launcher or receiver in accordance with
§ 192.155, Welded Branch Connections.
You also ask, “When a temporary launcher or receiver is placed in a gas pipeline for the
purpose of running pipeline cleaning or inspection tools is a pressure test required in
conformance with 49 CFR 192.505?”
As stated above, temporary pig launchers and receivers are fabricated assemblies through
which gas moves in transportation, therefore, they must be tested in accordance with 49 CFR
Subpart J, which includes § 192.505. Subpart J also includes general test requirements,
environmental and safety requirements, record keeping requirements, and references to other
sections in 49 CFR 192 that also apply to launchers and receivers. The regulations do allow a
pre-installation strength test for fabricated units and short sections of pipe for which a post
installation test is impractical on pipelines operated at a hoop stress of 30 percent or more of the
specified minimum yield strength (SMYS) [see § 192.505(e)].

<<<PAGE 2>>>

Lastly you ask, “When a temporary launcher or receiver is moved to a new location on the
same or a different gas pipeline is a new pressure test required prior to placing the launcher or
receiver back into temporary service?”
Section 192.503 states that a segment of a pipeline cannot be returned to service after it has
been relocated until it has been tested in accordance with Subpart J and § 192.619 to substantiate
the maximum allowable operating pressure (MAOP). A pipeline includes temporary pig
launchers and receivers as explained above. Accordingly, testing must be performed after a
temporary pig launcher or receiver is relocated and before it is returned to service as required by
§ 192.503 (a). As also stated above, the regulations do allow a pre-installation strength test for
fabricated units and short sections of pipe for which a post installation test is impractical on
pipelines operated at a hoop stress of 30 percent or more of SMYS [see § 192.505(e)].
If I can further assist you with this, or any other regulatory matter, please contact me at
(202) 366-4595.
Sincerely,
Florence L. Hamn
Director, Office of Regulations

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2007/g07-04-11_HANCOCK_192.3_Pipeline-nlmx.pdf>
- Source ID: `phmsa`
- SHA-256: `fe1f124447b6df54664682cfa627893a82ef18b9464afa36a86b8513a6fad57d`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-22T04:25:03.880Z
- Document slug: `phmsa-interpretation-pi-07-0103`

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