Ball Engineering Company — Pipeline Safety Interpretation

Page 1May 1, 1975 Mr. Robert Buss Ball Engineering Company Consulting Engineers Centerville, Iowa Dear Mr. Buss: This responds to your letter of March 22, 1975, asking several questions regarding 49 CFR Part 192. Question 1: Does the exception from the requirement for non-destructive testing of welds under Section 192.241(b) for pipe less than 6 inches in nominal diameter also apply to field girth butt welds which must be tested under Section 192.719(a)(2)? Answer: Section 192.241(b) provides limited exceptions from the requirement that all welds on newly installed, replaced, or relocated pipe to be operated at 20 percent or more of SMYS, be non-destructively tested. In contrast, Section 192.719(a)(2) specifically requires strength or non- destructive testing for field girth butt welds made in repairing a transmission line by cutting out damaged pipe as a cylinder and replacing it. This specific requirements for testing a repair weld was established without exception because of the greater need to ensure weld quality. Question 2: Does Section 192.503(d) refer to pressure testing only of welds? Answer: Section 192.503(d) provides that the leak and strength test requirements for pipelines under Subpart J do not apply to welds used to tie-in a segment of pipeline being tested. Question 3: Does a pressure test made on replacement pipe before it is installed, as permitted by Section 192.719(a)(2), satisfy the requirement of Section 192.619(a)(2)(ii) that in establishing a maximum allowable operating pressure for certain pipe, a pressure test be made "after construction?" Answer: Because the requirements of Sections 192.619(a)(2)(ii) and 192.719(a)(2) apply in conjunction, a pressure test permitted by Section 192.719(a)(2) to be made before installation must necessarily qualify as the test required by Section 192.619(a)(2)(ii). At the same time, Section 192.719(a)(2) dal\192\719\75-05-01 1#

Page 2provides that any field girth butt weld which is not strength tested in the pre-installation testing process must be non-destructively tested after installation in accordance with Section 192.243. As you requested, we have enclosed a copy of Advisory Bulletin No. 74-7. Thank you for your interest in pipeline safety. Sincerely, Joseph C. Caldwell Director Office of Pipeline Safety Enclosure dal\192\719\75-05-01 2#