{"operation":"document","citation":"PI-82-0108","title":"Pipeline Safety Interpretation PI-82-0108","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1982-07-29","effective_on":null,"summary":"PI-82-0108 concerning 195.310.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0108.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0108.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0108","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1982/g82-07-29_Keearns_195.310-wsx.pdf","body":"<<<PAGE 1>>>\n\nPI-82-0108\nJuly 29, 1982\nMr. R. G. Keearns\nWilliams Pipe Line Company\nP.O. Box 3448\nTulsa, Oklahoma 74101\nDear Mr. Keearns:\nYour letter dated February 16, 1982, requested a waiver from compliance with §195.310 by using a digital pressure\ngauge in lieu of a dead weight tester.\nEnclosed is a Pipeline Safety Regulatory Interpretation of §195.310 which states that the use of a dead weight tester is\nnot required. Hence, a waiver from compliance with §195.310 is not required in order to use the proposed digital\npressure gauge for hydrostatic testing.\nSincerely,\nMelvin A. Judah\nActing Associate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nEnclosure\n\n<<<PAGE 2>>>\n\nNo. 82-6\nDate: July 29, 1982\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nMATERIALS TRANSPORTATION BUREAU\nPIPELINE SAFETY REGULATORY INTERPRETATION\nNote: A pipeline safety regulatory interpretation applies a particular rule to a particular set of\nfacts and circumstances, and, as such, may be relied upon only by those persons\nto whom the interpretation is specifically addresses.\nSECTION: 195.310\nSUBJECT: Use of a digital pressure gauge in lieu of a dead weight tester during hydrostatic test.\nFACTS: Williams Pipe Line Company letter dated February 16, 1982, requested a waiver from compliance with\n§195.310 to use a digital pressure gauge instead of a dead weight tester.\nINTERPRETATION:Section 195.310 does not require the use of dead weight testers during hydrostatic test. The purpose\nof the use of the term is to assure that substantial evidence of testing is kept and when\n§195.310 was adopted, dead weight testers were in common use. Comparable data\nfrom modern equipment will suffice in meeting the requirements of §195.310.\nMelvin A. Judah\nActing Associate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 3>>>\n\nFebruary 16, 1982\nMr. Melvin A. Judah\nActing Associate Director\nfor Pipeline Safety Regulations\nMaterials Transportation Bureau\nU.S. Department of Transportation\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nDear Mr. Judah:\nIn accordance with Sub-part E of Regulations for Transportation of Liquids by Pipeline, Part 195.310, we now\nuse the deadweight tester for measurement of pressure during hydrostatic testing. The field survey type deadweight\ntester, however, has presented certain problems as follows:\n1.The weights are easily dropped and scored making their mass and, therefore, the accuracy of their\nmeasurements dubious.\n2.We do not have the facilities to calibrate deadweights and, therefore, must trust the original manufacturer\ntotally.\n3.Determining a pressure reading with a field deadweight tester is complicated, making operator error a\ncommon problem.\nOur research has turned up a pressure measuring device which we feel offers better accuracy than the field\ndeadweight tester is actual service.\nEnclosed are technical specifications of the \"Gauge 1\" digital pressure gauge, manufactured by Vaetrix, a\ndivision of Taylor Tools. We have tested one of these units and found it operates well within the accuracy\nspecifications.\nWe therefore request a waiver to use the \"Gauge 1\" digital pressure gauge in place of the field deadweight\ntester for which deadweight testers are currently required by federal regulations.\nVery truly yours,\nR. G. Keearns\nManager of Environmental Affairs\nand Pipe Line Safety","truncated":false,"body_characters":3410}