{"operation":"document","citation":"PI-78-011","title":"Borg-Warner Corporation — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1979-04-18","effective_on":null,"summary":"PI-78-011 response to Borg-Warner Corporation concerning 195.304.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-011","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/PI78011.pdf","body":"<<<PAGE 1>>>\n\nMr. Jim C. Hallmark\nSales Representative\nByron Jackson Pump Division\nBorg-Warner Corporation\nP.O. Drawer 12946\nHouston, Texas 77017\nDear Mr. Hallmark:\nThis is in reply to your letter dated April 3, 1979. Your letter\nrequests an interpretation of hydrostatic testing requirements for\ncomponents set out in 49 CFR Part 195, ?195.304. You ask whether\nthe 24-hour hydrostatic test period set forth in ?195.302(b)\napplies to components such as pumps.\nPlease be advised that the 24-hour hydrostatic test period does not\nnecessarily apply to components. Section 195.304(b) provides for\nexceptions to the 24-hour test period if the component is the only\nitem being replaced or added to the pipeline system and if the\ncomponent was hydrostatically tested at the factory or was\nmanufactured under a quality control system that ensures each\ncomponent is at least equal in strength to a prototype that was\nhydrostatically tested at the factory.\nInasmuch as the pumps you mentioned are apparently the only\ncomponents being replaced or added and inasmuch as these pumps are\nhydrostatically tested at the factory; although not for a 24-hour\nperiod, please be advised that the requirements of ?195.304(b) and\n?195.304(b((1) have been met.\nSincerely,\n/signed/\nCesar De Leon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDB\nC:\\WP51\\INTERPRT\\195\\302\\79-04-18\n1\n\n<<<PAGE 2>>>\n\nApril 3, 1979\nMr. Ceasar DeLeon\nOffice of Pipeline Safety Operations\nMaterial Transportation B\nDepartment of Transportation\n2100 2nd St. Southwest\nWashington, D. C. 20590\nDear Mr. DeLeon:\nI would like an official interpretation of your D.O.T. Reg.\n#195.304 concering the hydrostatic testing of components of a\npipeline service or in conjunction with a pipeline service.\nI have a customer, Texas Eastern Transmission, that requires a 24\nhour hydrostatic test on each pump they purchase. They use Subpart\nE, 195.300, 195.302, 195.304 as the basis for their requirement.\nI it our understanding that the 24 hour test pertains to pipeline\nand pipe and not necessarily to the components, such as pumps.\nSince we hydrostatically test all our pumps to 1.5 times the shut-\nin or 2 times the operating pressure, whichever is greater and in\naccordance with the Hydraulic Institute Standards and certify the\ntest.\nI see that this is covered by your 195.304 - B1 and B2. I stated\nall our pumps are hydro tested and all our prototypes have been\ntested but not for a 24 hour period. It does not specify the\namount of time the factory has to hydro test.\nI talked with Mr. DeLaFuenta at D.O.T. in Houston and Mr. Frank\nRobinson in Washington, D. C. and they both concur with my\ninterpretation of the D.O.T. Reg. 195.304, that is, as long as we\nhydrostatically test our pumps and certify their operation, that is\nall that is needed.\nYour cooperation in this matter will be greatly appreciated.\nVery truly yours,\nBRYON JACKSON PUMP DIVISION\nJim. C. Hallmark\nSales Representative\nDB\nC:\\WP51\\INTERPRT\\195\\302\\79-04-18\n2\n\n<<<PAGE 3>>>\n\nC: WP51INTERPRT195130279-04-18\n3","truncated":false,"body_characters":3053}