Pipeline Safety Interpretation PI-78-0104

Page 1PI-78-0104 July 31, 1978 Roberto N. Artola Gas Del Estado Normalizacion e Informacion Tecnica Alsina 1774 1088 Buenos Aires Argentina Dear Sir: This is in reply to your letter of May 8, 1978, asking if gas pipelines to be operated above 20 percent SMYS that lie within a highway or railway right-of-way must meet the requirements of 49 CFR 192.243(d)(4) whether they cross or parallel the highway or railway. Section 192.243(d)(4) sets forth the percentage of each day’s field butt welds that must be nondestructively tested on pipelines to be operated at 20 percent of SMYS or more when such testing is required by Section 192.241(b). Paragraph (d)(4) states that: “Within railroad or public highway rights-of-way…100 percent.” Under this requirement, the term “within” refers to pipelines inside the right-of-way, including those that either cross or parallel a railroad or highway. Thus the applicability of Section 192.243(d)(4) is not affected by the relative position of the highway or railroad to a pipeline within the right-of-way. We trust that this adequately responds to your inquiry. If we can be of any further assistance, please let us know. Sincerely, Cesar DeLeon Associate Director for Pipeline Safety Regulation Material Transportation Bureau#

Page 2Ministerio de Economia Corporacion de Empresas Nacionales Gas del Estado May 8, 1978 Department of Transportation 400, 6th. St., S.W. Washington, (D.C.) 20590 Estados Unidos de America del Norte Gentlemen, I am the manager of the Normalization and Technical Information Department of the State owned utility Gas del Estado. Our duties include the analysis and studies of standards and specifications to be complied with within the scope of our Company. I am requesting you for an interpretation of the Minimum Federal Standards. Please, kindly inform us whether the specification in 192.243 - d - 4 must be applied to all the natural gas pipelines operating to hoop stresses of over 20 percent of the SMYS running within the right-of-way of highways or railway lines, in parallel or in crossings. We thank you in advance for your kind cooperation. Cordially yours, Roberto N Artola Jefe Departamento p.p. Gas del Estado#