{"operation":"document","citation":"PI-74-0120","title":"Pioneer Natural Gas Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-03-11","effective_on":null,"summary":"PI-74-0120 response to Pioneer Natural Gas Company concerning 192.517.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0120.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0120.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0120","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-05-30_Smith_192.517-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0120\nMarch 11, 1974\nMc. Scott C, Smith, Jr.\nPioneer Natural Gas Company\nP.O. Box 511\nAmarillo, TX 79105\nDear Mr. Smiths\nIn your letter of January 31, 1974, you ask specific questions on safety requirements of 49 CFR Part 192, as\nthey apply to lines acquired by gift or other transfer of ownership. Answers to these questions, which are set\nforth below are based, in part, on whether the line involved is a new or existing pipeline. New pipelines are\nthose readied for service after March 12, 1971. Existing pipelines are those in service before March 13, 1971.\nThis distinction is necessary because existing pipelines are not subject to the requirements in Part 192 for\ndesign, installation, construction, initial inspection, and initial testing, except that any replacement or\nrelocation of an existing pipeline after November 12, 1970, must be performed in accordance with\nrequirements in Part 192.\nThe questions and answers follow:\nQuestion 1. \"Is the operator (our Company in this case) in violation of D.O.T. Part 192, if he receives or buys\na new plastic pipeline from a customer when he does not know what sort of pressure tests were installed (sic)\non the pipeline when it was installed, does not know the exact location of the pipeline, and-knows that no\nwire that will enable locating the pipeline was ever installed during the construction, and then the operator\nproceeds to operate the pipeline as his own?\"\nAnswer.An operator who acquires a new plastic pipeline or a relocated or replaced one must comply with the\nrequirements of Subpart J either by knowing what pressure test was made on the line after installation or by\nconduct a proper test.\nTo comply with part 192, an operator who acquires an existing plastic pipeline other than one relocated or\nreplaced after November 12, 1970, need not know what pressure test was made after installation of the line.\nHowever, since the line's MAOP cannot be determined under §192.619(a)(2)(i) without this information, the\noperator must establish an MAOP by testing the line, unless the exception in §192.619(c) applies.\nPart 192 does not require an operator to know the \"exact\" location of its pipelines. However, §192.321(e)\nrequires that new plastic transmission lines and mains have wires or other means for use in locating the\npipeline. Also, an operator must know the general location of pipelines it operates to meet related\nrequirements in Part 192.\nQuestion 2.\"Likewise, is the operator in violation if he receives a new steel pipeline from a customer that:\ninstalled the pipeline without testing welders in accordance with D.O.T. requirements, has no record of any\npressure or strength tests of the pipeline, did not coat all of the pipeline, and did not install adequate cathodic\nprotection.\"\nAnswer. An operator who acquires a new welded steel pipeline is responsible for compliance of that\npipeline with the welding requirements in Subpart E. The use of unqualified welders by the previous owner in\nconstructing the line is a violation of Subpart E requirements which, in the absence of appropriate waiver, may\nbe charged to any subsequent owner or operator of the line. The welding requirements do not apply to an\nexisting welded steel pipeline, except one which is relocated or replaced after November 12, 1970.\n\n<<<PAGE 2>>>\n\nAn operator who acquires a new steel pipeline or one relocated or replaced after November 12, 1970, must\nobtain or establish the test record required by §192.517, if applicable to the line acquired. Irrespective of this\nrecordkeeping requirement, in the case of a new steel pipeline or a relocated or replaced one, to comply with\nSubpart J an operator must know what pressure test was made after installation or conduct a proper test. In\nthe case of an existing steel pipeline operated at 100 psig or more, other than one relocated or replaced, to\nestablish an MAOP under §192.619(a)(2)(ii), an operator must know what test was made after installation or\nconduct a proper test, unless the exception in §192.619(c) applies. Where such an existing line is operated at\nless than 100 psig, an MAOP may be established under §192.619(a) in the absence of a post installation test.\nAn operator who acquires a new or existing steel pipeline must comply with the requirements for corrosion\ncontrol in Subpart I respecting that pipeline, regardless of the condition of the pipeline when ownership is\ntransferred. If necessary, appropriate inspections should be made to determine the extent of compliance at\nthe time of transfer.\nIt is important to note that the natural Gas Pipeline Safety Act of 1968 places the obligation of compliance\nwith the Federal gas pipeline safety standards on each person who transports gas or who owns or operates\npipeline facilities. This obligation may not be excused by blaming previous owners or operators for any failure\nin compliance.\nI trust this satisfactorily responds to your inquiry.\nSincerely,\nSIGNED\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 3>>>\n\nPIONEER\nNATURAL GAS COMPANY\nPOST OFFICE BOX 511\nAMARILLO, TEXAS 79105\nJanuary 31, 1974\nDirector, Gas Utilities Division\nD. 0. T., Office of Pipeline Safety\n400 7th Street, Southwest\nWashington, D. C. 20590\nDear Sir:\nIn years past Pioneer Natural Gas Company had a policy of taking over customers' pipelines, particularly in\nrural areas where the customers had installed various sizes of plastic lines to irrigation wells. We did much of\nthis by a bill of sale accompanied by easements to cover the lines but subsequently found the pipelines to be\ninferior, causing us to replace 1,000 miles or more of these lines, mostly 2\" in size.\nThough we ceased this practice of taking over customers lines some time back, we still have requests from\npeople who wish to install their own line and give it to us. The question I wish to make of D. 0. T. is two-fold:\n1. Is the operator (our Company in this case) in violation of D. 0. T., Part 192, if he receives or buys a new\nplastic pipeline from a customer when he does not know what sort of pressure tests were installed on\nthe pipeline when it was installed, does not know the exact location of the pipeline, and knows that no\nwire that will enable locating the pipeline was ever installed during the construction, and then the\noperator proceeds to operate the pipeline as his own?\n2. Likewise, is the operator in violation if he receives a new steel pipeline from a customer that: installed\nthe pipeline without testing welders in accordance with D. 0. T. requirements, has no record of any\npressure or strength tests of the pipeline, did not coat all of the pipeline, and did not install adequate\ncathodic protection.\nIf you have a question concerning this, please do not hesitate to call collect at (806) 376-4841, Ext. 311. I look\nforward to receiving your reply.\nVery truly yours,\nScott C. Smith, Jr.\nDivision Engineer","truncated":false,"body_characters":6886}