{"operation":"document","citation":"PI-12-0002","title":"McAfee & Taft — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-10-17","effective_on":null,"summary":"PI-12-0002 response to McAfee & Taft.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-12-0002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-12-0002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-12-0002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-04/McAfee-and-Taft-PI-12-0002-10-18-2012-Part195.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nOCT 1 7 2012\nMr. Chris A. Paul, Esq.\nAttorney at Law\nMcAfee & Taft\n1717 S. Boulder, Suite 900\nTulsa, OK 74119\nDear Mr. Paul:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nDecember 8, 2011, you requested an interpretation concerning the requirements in 49 CFR\nPart 195 for pressure testing a segment of pipeline that has been replaced prior to putting that\nsegment in service. Specifically, you asked whether post-installation pressure testing was\nrequired for a pipe replacement project involving multiple joints of pre-tested pipe. You also\nasked whether PHMSA could provide any relevant enforcement guidance documents on this\nlSSUC.\nPressure testing a pipeline segment before placing it in service is a core requirement of the\nFederal pipeline safety regulations. Part 195. Subpart E governs the pressure testing of pipeline\nused in hazardous liquid service. 49 CFR 195.302(a) states:\n(a) except as otherwise provided in this section and in § 195.305(b), no operator\nmay operate a pipeline unless it has been pressure tested under this subpart\n\\Vithout leakage. In addition, no operator may return to service a segment of\npipeline that has been replaced, relocated. or othenvisc changed until it has been\npressure tested under this subpart without leakage.\nThe term \"pipeline\" is defined in§ 195.2 as:\n\"Pipeline or pipeline system means all parts of a pipeline facility through which a\nhazardous liquid or carbon dioxide moves in transportation. including. but not\nlimited to. line pipe, valves and other appurtenances connected to line pipe.\npumping units, fabricated assemblies associated with pumping units, metering and\ndelivery stations and fabricated assemblies therein, and breakout tanks.''\nThe term \"pipe\" is further defined in§ 195.2 as:\n\"Pipe or line pipe means a tube, usually cylindrical, through which a hazardous\nliquid or carbon dioxide flows from one point to another.''\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written claritications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the claritication. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nUnder these definitions, the term pipe means that section of pipe through which a hazardous\nliquiq will flow from point-to-point and therefore must be pressure tested from point-to-point.\nNo distinction is made as to the length of pipe or the number ofweldedjoints within the replaced\npipe segment. Similarly, under§ 195.308, a pipe tie-in segment being il).stalled must be pressure\ntested either with or without the tie-in welds (which themselves require non-destructive testing).\nNote that the welds connecting several pipe lengths in a section to be tied-in are not tie-in welds.\nIn general, while PHMSA has not required post-installation pressure testing when a single joint\nof pre-tested pipe is replaced, operators are subject to the pressure testing requirement anytime\nmore than one pipe joint is being replaced.\nRegarding your request for enforcement guidance documents, all available PHMSA enforcement\nguidance materials are posted on the PHMSA website for public viewing at:\nhttp://www.phmsa.dot.gov/foia/e-reading-room. Once you visit the website, please click on-\n'~III. Staff Manuals and Instructions\" to view the enforcement guidance materials. While\nPHMSA does not have an enforcement guidance document for 49 CFR Part 195, Subpart E-\nPressure Testing, we have enclosed an enforcement guidance document dealing with the pressure\ntesting requirement for natural gas pipeline replacement projects under Part 192. While this\nenforcement guidance is not applicable to hazardous liquid pipelines, it is illustrative ofthe\nmanner in which PHMSA applies the pressure testing requirement to pipe replacement projects.\nIn relevant part, it states that \"the entire replaced segment must be tested ... except the tie-in\njoints\" (and notes that the several pipe lengths are not tie-in joints).\nFinally, if you have a scenario where you can demonstrate that conducting a post-installation\npressure test on a replacement segment is impracticable, you may contact the PHMSA regional\noffice covering the area and submit a proposed alternative in writing for its consideration such as\na proposal to perform an appropriate strength test on the segment prior to installation (which\nPHMSA may elect to witness).\nI hope that this information is helpful to you. If I can be of further assistance, please contact me\nat 202-366-4046.\nSincerely,\n~--// ohii A. Gale\nDirector, Office of Standards\nand Rulemaking\nEnclosure\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nEnforcement Guidance\nO&M Part 192\nRevision Date 09-28-20 I I\nCode Section § 192.719\nSection Title Transmission Lines - Testing of Repairs\nExisting Code Language (a) Testing of replacement pipe. If a segment of transmission li ne is repaired\nby cutting out the damaged portion of the pipe as a cylinder, the replacement\npipe must be tested to the pressure required for a new line installed in the same\nlocati on. This test may be made on the pipe be fore it is installed.\n(b) Testing of repairs made by welding. Each repair made by welding in\naccordance with ~~ 191\n. 71.3. 191. 7_1} . and !92.7_1] must be exam ined in\naccordance 'vvith § 192.241.\nOrigin of\nCode\nOri ginal Code Document. 35 FR 13248. 08-1 9-1 970\nLast\nAmendment\nArndt. 192-54. 5 I FR 41635. I I- I 8-1986.\nInterpretation Interpretation: PJ-94-024 Date: 06-07-J 994\nSummaries\nQuestion #2: \"Our second question relates to the hydrostatic testing of\nreplacement pipe und e r ~ I 92. 719(a). In a repai r situation where several joints\nof pipe are welded together. does the welded piece have to be hydrostati cally\ntested as a unit? Each joint is pre-tested and the welds arc I 00% non-\ndestructi vely tested.\"\nAnswer #2: Section I 92. 719(a) is intended fo r testi ng of repairs of\ntransmission pipelines. where the pipe is required to be tested as a new\nline. The test requirements in Subpart .I are applicable to a new segment of\npipeline. or the return to service of a segment or pipeline that has been\nrelocated or replaced.\nIn accordance with § l92.503(a) in Subpart J. the entire replaced segment must\nbe tested in accordance with Subpart .J and § 192.6 19. except the ti e-in joints\nthat are excepted under § 192.503(d). It should be noted that the joints\nconnecting the several pipe lengths are not tie-i n joints. However. if. in\nThe Pipclmc and llaznrdtlll$ Mmcrials Safcl~ i\\dminislralion. Ollicc or 1'1pduu.: Sal<:!~ prm ide' \\\\flllcn clarilicalulll' oriiH: Rcg.ulallons\n(49 CFR Pan> 190-199) in 1 hc limn or illlcrprctalion lcucr~ . rhc'c lcllcrs rclkcl I he agcnc~ 's curn:nl applicalinnor I he n.:gulalions It> I he\nspccilic ltlCIS presented hy the persou requesti ng lhc clarilicminn lnlcrprclillinns do nol create lcgall y-cnlilrccahlc righls or obligations and\narc provided 1 n help lhc puol1c umkrSiand hn\" In ~:n mpl ~ \"llh 1hc r\\:gulalunlS\n\n<<<PAGE 4>>>\n\naccordance with§ 192.505(e). it is not practical to conduct a post installation\ntest, a pre-installation strength test must be conducted on each pipe length or\nthe segmen\" t by maintaining the pressure at or above the test pressure for at\nleast 4 hours.\nInterpretation: PI-ZZ-037 Date: 04-15-1988\nYour letter asks whether mechanical couplers fall under ~§ 192.7 11 - 192.719\nof the Federal Gas Pipeline safety Standards ( 49 CFR Part 192). and whether\nthe Department of Transportati on (DOT) must approve your company\"s\nproduct before it may be used in gas pipelines.\nSections 192.7 11 - 192.7 19 apply to the fi eld repair of transm ission\nlines. Any mechanical coupler of acceptable design and strength may be used\nwhen the use of a weld less joining device is appropriate under §§ 192.7 1 1-\n192.7 19. The acceptabil ity of couplcrs is governed by various secti ons in\nsubparts B. D and r of Part 192.\nPrior DOT approval is not required for the use of any type of gas pipeline\n. faci li ty. including mechanical couplers. Operators are free to select and use\nmateri als that they determine. either on their own or with the aid of\nmanufacturers· representations. are acceptable under DOT standards. The\ncorrectness of these determinations is subject to review by DOT and State\nagency enforcement personnel during periodic inspecti on visits.\nAdvisory\nBulletin/ Alert\nNotice\nSummaries\nOther\nReference\nMaterial\n& Source\nGPTC Guide Material is avai lable.\nThe Pipclin~ and llazardous Malcrials Satcly Adminislralion. Otlice of l'irclin..: Sate!) provides wrin..:n clariticarions oflhe Regula! ions\n(49 CFR Parts 1 90- 1 99) inlhc form of inlcrprclalion lcncrs. These lcllcrs rdkcl !he a g~ n cy 's currcnl applicalion ur !he regula! ions 10 !he\nspecitic racls presen!cd by !he person requesling !he dariticmion. lr H~rprclilllliii S do no! cr..:ale l..:gall v·..:n l(lrccahk riglus or ohligalions and\narc rrovidcd 10 help !he public underswnd IHl\\\\ Ill comp l ~ wilh !he regui<Hillll;.\n\n<<<PAGE 5>>>\n\nGuidance Information I. The operator must have written procedures for the testing of repairs.\n2. Appropriate UT examination of the repair area should be performed to\ninsure the integrity of the planned repair.\n3. A pipe segment that is replaced must be pressure tested after installation\nunless it is not practicaL in which case each length of pipe or each segment\nmust be pressure tested.\n4. Special attention should be applied to the potential for stresses associated\nwith out-of-roundness. high-low. al ignment. and ch:;mges in pipe wall or\ngrade.\n5. Records documenting pretest of pipe for emergency use must include an\naudit trail to each specific joint of pipe instal led in the pipeline.\nExamples of a Probable Violation I. The lack of procedures is a violation of~ 192.605.\n2. The lack of records is a violation of § 192.603.\n3. The operator did not fo llow written procedures for testing of repairs.\n4. Test records for installed pipe cannot be traced back to the original test\ndocumentation.\n5. NOT records are not available concerning inspection of welds made on\nrepair fitti ngs and devices.\nExamples of Evidence 1. Records regarding the repairs made to the pipeline.\n2. Statements from supervisory personnel regard ing any missing or\nincomplete records.\n3. Metall urgical reports.\n4. Incident reports.\n5. The lack of procedures or records.\nThe Pipeline and Hazardous Materials Safety 1\\dlllinistration. Ol1ke of Pi pel in~ Safety provides wrill~n clarifications of the Rcgulatic111s\n(49 CFR Parts 190- 1 99) in the form of interpretation letters. These lcucrs reflect the agency's current ~pplication of the regu lations to the\nspecific facts presented oy the person req uesting the cl arification Interpretations do not create lcgall~-cnli>rceahlc rights or ohligations and\narc pnwided to hdp the public understand ho11 to cnmph 11 ith the regulations.\n\n<<<PAGE 6>>>\n\nMcAFEE& TAFT\nA PRCJ!ESSIONAL CCJI<PORr\\TIO~\n1717 S. BOULDER • SUITE 900\nTULSA, OK 74119\n1918) 587-0000 • FAX (918) 599-9317\nwww.mcafeetaft.com\nCHRIS A. PAUL\nATTORNEY AT LAW\nWRITER DIRECT\n(918) 57 4-303 7\nFAX(918)574-3137\nChris.Paul@mcafeetaft.com\nDecember 8, 2011\nDEC 16 2011\nOffice of Pipeline Safety (DPS-1 0)\nPipeline Hazardous Materials Safety Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nEast Building, Second Floor (PH)\nWashington, DC 20590\nRE: Interpretation/Clarification\nDear Sir or Madam:\nRegarding petroleum pipelines in various Pipeline and Hazardous Materials\nSafety Administration (PHMSA) regions, I understand that there are varipus\ninterpretations as to the maximum number of joints or length of pre-pressure\ntested pipe that can be used for a pipeline replacement project before post- ..\ninstallation pressure testing is required for the new pipe (that was already pre~\ntested).\nThe normal process is that pre-tested replacement pipe is kept at pipeline\nfacilities to be available in the event replacement of pipe is nece$sary. This pre-\ntested replacement pipe is being inserted into an existing pipeline that has\npreviously been pressure tested per 49 CFR §195, Subpart E- Pressure Testing.\nAll new welds associated with the pipe replacement are1 00% Non-Destructive\nTested per §195.228 Welds and Welding Inspection: Standards of Acceptability.\n§195.302 (a) General Requirements states: \"Except as otherwise provided in this\nsection and in §195.305(b), no operator may operate a pipeline unless it has\nbeen pressure tested under this subpart without leakage. In addition, no\noperator may return to service a segment of pipeline that has been replaced,\nrelocated, or otherwise changed until it has been pressure tested under this\nsubpart without leakage.\"\nI understand that various ·Office of Pipeline Regional.staff have indicated that this\nissue is addressed in a PHMSA standard \"Enforcement Guidance~ document.\nHowever, a copy of this has not (to my knowledge) been made available to\npipeline operators. In addition it appears that there .are apparently various\n9250872_1\nOKLAHOMA CITY TULSA\n\n<<<PAGE 7>>>\n\nDecember 8, 2011\nPage 2\nregional interpretations of how many joints or feet of pre-tested pipe can be\nreplaced before post-pressure testing is required of the entire segment. For\nexample:\n• Central Region - between 3 and 5 joints can be replaced without\npost-pressure testing (this obviously creates an ambiguity).\n• Western Region -only 1 joint can be replaced without post-\npressure testing.\n• Southwest Region - 3 joints can be replaced without post-pressure\ntesting.\nI am requesting the following:\n1. Clarification as to requirements related to the foregoing.\n2. If the nature of the requirements as set forth generally above are being\nused, what is the reasoning and where in the regulations is the\nrequirement for post-pressure testing the entire new section if tested pipe\n(regardless of length) is being inserted into the segment?\n3. If there is a requirement for maximum number of joints or feet of tested\npipe installed, what is allowed in joints or total feet?\n4. If there is an Enforcement Guidance document or manual, or other\nguidance or interpretations, please provide same. If necessary, please\nconsider this fourth request a request under the Freedom of Information\nAct, 5 U.S.C. § 552.\nIf you or your staff has questions, feel free to contact me at (918)-57 4-3037.\nVery truly yours,\nChris A. Paul\nCAP:sd","truncated":false,"body_characters":15239}