{"operation":"document","citation":"PI-71-0120","title":"ACF Industries — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-12-15","effective_on":null,"summary":"PI-71-0120 response to ACF Industries concerning 192.505.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0120.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0120.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-0120","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/g71-11-22_Wilkins_192.505-lmxs.pdf","body":"<<<PAGE 1>>>\n\nPI-71-0120\nDecember 15, 1971\nMr. R. D Wilkins, Manager\nApplications Engineering\nEngineering and Research\nACF Industries\nP.O. Box 2117\nHouston, Texas 77001\nDear Mr. Wilkins:\nThank you for your letter of November 22, 1971, that inquired about the interpretation of 49 CFR §§192.505 (c) and (d).\nYou are correct in your understanding that in the very limited circumstances delineated in §192.505 (d) the\nrequirements for a strength test and for maintaining test pressure for eight hours is not required. Thus, if a component\nother than pipe is the only item being replaced or added to a pipeline, a strength test after installation is not required, if\nthe manufacturer of the component certifies that (1) the component was tested to at least the pressure required for the\npipeline to which the component is being added, or (2) the component was manufactured under a quality control\nsystem that ensures that each item manufactured is at least equal in strength to a prototype and that the prototype was\ntested to at least the pressure required for the pipeline to which it is being added.\nThe reason for this exception is that if the manufacturer meets either of the requirements of §192.505 (d) an equivalent\nlevel of safety to §192.505 (c) is maintained without the burden of the eight hour test.\nWe trust that this will satisfactorily clarify the regulations for you.\nSincerely,\nOriginal signed by:\nJoseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nACF Industries\nP.O. Box 2117\nHouston, Texas 77001\nNovember 22, 1971\nMr. Joseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\nDepartment of Transportation\n400 Sixth St. S.W.\nWashington, D. C. 20590\nDear Mr. Caldwell:\nWe would like to request an interpretation of Paragraph 192.505 of Title 49, Code of Federal Regulations.\nIn Subparagraph (c) of Paragraph 192.505, an eight hour system strength test is required for a pipeline operating\nabove 30% of pipe SMYS.\nIn Subparagraph (d), it is stated that a strength test of this pipeline is not required if a component manufacturer\ncertifies that the valve was tested to at least the pressure required for the pipeline in which this component will\nbe installed.\nFrom the way the Paragraph is phrased, we are able to interpret that the eight hour test duration is not required\nby the wording of Subparagraph (d).\nSince this interpretation is literal, we ask that you verify this interpretation so that we may be also assured of the intent\nof the paragraph.\nVery truly yours,\nR. D. Wilkins\nManager –\nApplications Engineering\nEngineering & Research","truncated":false,"body_characters":2585}