{"operation":"document","citation":"PI-74-0147","title":"Pipeline Safety Interpretation PI-74-0147","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-12-03","effective_on":null,"summary":"PI-74-0147 concerning 195.2.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0147.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0147.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0147","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-12-03_Adams_195.2-wsX.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0147\nDecember 03, 1974\nInterpretations of Section 195.304\nTesting of Components and Section 195.308\nTesting of Tie-ins\nDirector, Office of Pipeline Safety\nChief, Houston Field Office\nThis refers to your office memorandum request for interpretations concerning a possible conflict between\nSection 195.304 and 195.308. You state that some operators are circumventing the requirement of\nhydrostatically testing replacement pipe by using the definition of “component” and a certification from the\npipe mill to the effect that the pipe was hydrostatically tested at the mill.\nThe conflict has arisen because of the fact that various operators are alleging that “pipe” is a component and\nhence within the exemption for hydrostatic testing provided by Section 195.304(b) when it is accompanied by\na certificate from the manufacturer stating that it was hydrostatically tested at the factory. When the\nconditions for the exemption of components under Section 195.304(b) are met, it is alleged that the\nprovisions of Section 195.308 are no longer applicable.\nUnder no circumstance will a normal factory hydrostatic test of the pipe which lasts only a few seconds be\nsufficient to meet the requirement of Section 195.308. The same requirements for pressure and test duration\napplicable to a new pipeline under Section 195.302 are required for any segment of pipe added to a pipeline\nunder Section 195.308. Section 195.308 specifically requires that “pipe associated with tie-ins must be\nhydrostatically tested.” Even though Section 195.304(b) exempts certain pipe, as a component, from the field\ntesting requirement, as a matter of proper language construction, the specific and more stringent safety\nrequirement of Section 195.308 has precedence over the general, less stringent provision in Section\n195.304(b).\nJoseph C. Caldwell\n\n<<<PAGE 2>>>\n\nUnited States Government\nDepartment of Transportation\nOffice of the Secretary\nMemorandum\nDate: November 29, 1974\nSubject: Definition of “pipe” and “components”, section 195.2\nFrom: G.S. Adams\nTo: Director, Office of Pipeline Safety\nAttached is a suggested revision of your proposed memorandum interpreting 49 CFR sections\n195.2, 195.304(b) and 195.308.\nThe existing definition of a \"component\" contained in section 195.302 is subject to being\ninterpreted too broadly by members of the industry and the general public.\nWhile the attached memorandum is intended to clarify our interpretation, the matter should be\nfinally resolved by a revision of the definition provided in section 195.2. A similar ambiguity\nexists with regard to gas pipelines and Part 192, and it should likewise be clarified by the\naddition of a definition of the term \"component\". This would avoid any further confusion over\nthe intended scope of Subparts C (Pipe Design) and Subpart D (Design of Pipeline Components).\nG.S. Adams, TGC-20\n\n<<<PAGE 3>>>\n\nUnited States Government\nDepartment of Transportation\nOffice of the Secretary\nDate: October 1, 1974\nSubject: Interpretations: Liquid Pipelines\nFrom: Staff Engineer\nHouston Field Office\nTo: Chief, Technical Division (TES-32)\nRe: Possible conflict between §195.304, Testing of Components, and §195.308, Testing of Tie-ins.\nSome liquid pipeline operators acquire certification from the pipe mill to the effect that the pipe was\nhydrostatically tested at the mill. This certification coupled with the definition of \"component\" under\n§195.2 which by definition includes \"pipe\", is used to circumvent the requirement of hydrostatically\ntesting the pipe in place or separately when a joint or short segment of pipe is used for replacement\nin an existing pipeline as per §195.308.\nI would like an interpretation from your office as to under what conditions if any, a pipe mill test\ncertification overrides the requirement of §195.308, because these operators contend that a mill test\nand certification are sufficient when pipe is the component being replaced. Until I get a definitive\nruling on this I will have to keep possible compliance action in abeyance.\nJose L. de la Fuente","truncated":false,"body_characters":4052}