{"operation":"document","citation":"PI-82-010","title":"Williams Pipe Line Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1982-06-04","effective_on":null,"summary":"PI-82-010 response to Williams Pipe Line Company concerning 195.304.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-010","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1982/PI82010.pdf","body":"<<<PAGE 1>>>\n\nMr. R. G. Keearns\nManager of Environmental Affairs\nand Pipeline Safety\nWilliams Pipe Line Company\nP.O. Box 3448\nTulsa, OK 74101\nDear Mr. Keearns:\nThis is in response to your letter dated December 2, 1981,\nconcerning the application of ?195.304(b) to two factual\nsituations.\nThe enclosed pipeline safety regulatory interpretation explains\n?195.304(b) and gives its application to the two factual situations\npresented in your letter.\nWe hope this meets your needs.\nSincerely,\n/signed\nMelvin A Judah\nActing Associate Director\nfor Pipeline Safety Regulation\nMaterials Transportation Bureau\nEnclosure\nDB\nC:\\WP51\\INTERPRT\\195\\304\\82-06-04\n1\n\n<<<PAGE 2>>>\n\nNo. 82-4\nDate: June 4, 1982\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nMATERIALS TRANSPORTATION BUREAU\n_________________________________________________________________\nPIPELINE SAFETY REGULATORY INTERPRETATION\n_________________________________________________________________No\nte:A pipeline safety regulatory interpretation applies a particular\nrule to a particular set of facts and circumstances, and, as such,\nmay be relied upon only by those persons to whom the interpretation\nis specifically addressed.\nSECTION: 195.304(b)\nSUBJECT: Testing Components\nFACTS: The following facts are given in a letter dated December\n2, 1981, from R. G. Keearns, Williams Pipe Line Company,\nto the Office of Pipeline Safety Regulation\nCase I\nAn existing pipeline was cut to install a new pump. A new check\nvalve was installed in the existing line together with new suction\nand discharge piping, tees, ells, valves, and interconnected pump.\nThe pipe was pretested. The pump was tested by the manufacturer\nat the factory. All other items were manufactured to the same\nstandard as a tested prototype. The tie-in welds were\nradiographed.\nQuestion: Does this pump station installation qualify as the \"only\nitem being . . . added\" under ?195.304(b) and, therefore, excepted\nfrom the hydrostatic test requirement of ?195.302(a)?\nCase II\nIn a header, four flanged end valves were replaced with identical\nnew valves which were manufactured to the same standard as a tested\nprototype. Because only valves were replaced, do they qualify as\nthe \"only item being replaced\" under ?195.304(b) and are,\ntherefore, excepted from the test requirement of ?195.302(a)?\nInterpretation: Section 195.304(b) was adopted on November 2,\n1970, as Amendment 195-2, Docket No. HM-6. The preamble to that\namendment makes clear that ?195.304(b) applies only to single item\nreplacements or additions. In Case I, more than a single item has\nbeen added, and in Case II more than a single item has been\nDB\nC:\\WP51\\INTERPRT\\195\\304\\82-06-04\n2\n\n<<<PAGE 3>>>\n\nreplaced. Therefore, in both cases, ?195.304(b) does not apply and\nhydrostatic testing is required under ?195.302(a).\nMelvin A. Judah\nActing Associate Director\nfor Pipeline Safety Regulation\nMaterials Transportation Bureau\nDB\nC:\\WP51\\INTERPRT\\195\\304\\82-06-04\n3\n\n<<<PAGE 4>>>\n\nDecember 2, 1981\nMr. Melvin A. Judah\nActing Associate Director\nfor Pipeline Safety Regulation\nMaterials Transportation Bureau\nU.S. Department of Transportation\n400 Seventh Street SW\nWashington, D. C. 20590\nDear Mr. Judah:\nIn making pipeline repairs, e.g., replacing a section of\ndamaged pipe, we have interpreted the intent of hydrostatic testing\nrequirements as permitting the use of pretested pipe, weldneck\nflanges for connection to existing pipes, and radiographic\ninspection of welds. This minimizes down time in displacing the\npipeline with water, the subsequent testing and dewatering.\nPipeline Safety personnel have indicated such repair methods comply\nwith the regulations. In making such a repair, four weldneck\nflanges are used which does not comply exactly with Paragraph\n195.304(b) of the regulations. Four components (weldneck flanges)\nare used rather than a component.\nSince several components are used in the above illustration,\nwe have a question in regard to how broad of an interpretation can\nbe placed on Paragraph 195.304(b). I have attached two sketches\nwhich depict two situations which come under Paragraph 195.304(b).\nThe first sketch is of a pump connected to a line. The line is in\nalmost continuous use which if shut down for a hydrostatic test of\nthe connecting fittings, valves, and pump would create product\nmovement problems. The weld tees, ells, flanges, and valves are\nall manufactured in accordance with a prototype as required by\nParagraph 195.304(b)(2). The pump was hydrostatically tested at\nthe factory by the manufacturer. By using pretested pipe and x-\nraying the welds, which are the remaining items to complete the\nfabrication , all segments of the installation then meet the intent\nof the regulations. Would it be necessary to hydrostatically test\nthe complete installation? Such testing would seem to be\nsuperfluous since all materials utilized have been constructed,\nhydrostatically tested or nondestructively tested in accordance\nwith requirements.\nThe second sketch depicts a header with four connecting lines,\nincluding valves. Assume all four valves are to be replaced.\nWould hydrostatic testing be required?\nDB\nC:\\WP51\\INTERPRT\\195\\304\\82-06-04\n4\n\n<<<PAGE 5>>>\n\nPlease consider the questions presented and advise at your\nconvenience. If clarification might be needed, you may contact me\nat 918 588-3248. Thank you.\nVery truly yours,\nR. G. Keearns\nManager of Environmental Affairs\nand Pipeline Safety\nATTACHMENTS\nDB\nC:\\WP51\\INTERPRT\\195\\304\\82-06-04\n5","truncated":false,"body_characters":5482}