{"operation":"document","citation":"PI-84-0201","title":"PHMSA Central Region — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1984-02-06","effective_on":null,"summary":"PI-84-0201 response to PHMSA Central Region concerning 195.1, 195.302, 195.304.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0201.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0201.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0201","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2026-04/PHMSA-Central-Region-PI-84-0201-2-6-1984-Parts-195.1-195.302-195.304.pdf","body":"<<<PAGE 1>>>\n\nPI-84-0201\nFebruary 6, 1984\nINFORMATION: Request for Regulation Clarification\nFrom: Richard L. Beam\nAssociate Director for Pipeline Safety Regulation, DMT-30\nTo: Chief Central Region, DMT-14\nThis responds to your memo dated November 23, 1983, asking several questions about\nPart 195.\nFirst, you asked if a refinery's 20-mile pipeline between its storage tanks and the refinery,\nitself, is subject to Part 195 and the Hazardous Liquid Pipeline Safety Act of 1979. The 20-\nmile pipeline transports oil that is delivered to the tanks by an interstate pipeline. Given\nthese facts, I believe the 20-mile pipeline would be subject to the Act, because it is used to\nmove hazardous liquid in or affecting interstate or foreign commerce and the movement is\nnot specifically excepted from the Act's jurisdiction under the definition of \"transportation\nof hazardous liquids.\"\nWhether the 20-mile pipeline is subject to Part 195 depends on whether it is subject to the\njurisdiction of FERC as stated in §195.1(a)(1). If the 20-mile pipeline is not on FERC's list of\njurisdictional pipelines, it nevertheless may be subject to FERC's jurisdiction if it operates\nin interstate commerce. FERC's jurisdiction does not depend on passage of a pipeline\nacross State lines. A pipeline wholly within one State may be jurisdictional if it provides the\nfinal leg of an interstate journey. Whether the 20-mile pipeline is such a final leg depends\non whether the parties who arranged for the interstate movement intended the storage\ntanks or the refinery, itself, to be the destination of the shipment of oil. Although there are\nno facts given on this issue, the 20-mile pipeline would be jurisdictional only if the\ndestination is the refinery.\nSecondly, you asked about the term \"without leakage\" in §195.302(a), which requires that\ncertain pipelines be hydrostatically tested \"without leakage.\" I believe this standard is clear,\nno part of the pipeline being tested may leak during the test. Leakage of the test equipment\nis significant only if it impairs the conduct of the hydrostatic test of the pipeline.\nThirdly, you asked about §195.304(b), which excepts certain components from the\nhydrostatic testing requirements of §195.302 on the basis of hydrostatic testing by the\nmanufacturer. As indicated by Interpretation 79-13, dated April 13, 1979, since §195.304(b)\n\n<<<PAGE 2>>>\n\nprovides an exception from §195.302, the duration requirements of §195.302 do not apply\nto components to which the exception applies. Likewise, the pressure requirements do not\napply. Also, as indicated by Interpretation 80-16, dated December 1, 1980, when more than\na single component is being installed, §195.304(b) does not apply. A valve or pump plus an\nadjoining spool of pipe would be more than a single component.\n\n<<<PAGE 3>>>\n\nMemorandum\nU.S. Department of Transportation\nResearch and Special Programs Administration\nDate: November 23, 1983\nSubject: Request for Regulation Clarification\nFrom: Chief Central Region, DMT-14\nThru: Associate Director for Operations & Enforcement, DMT-10\nTo: Associate Director, Office of Pipeline Safety Regulation, DMT-30\n§195.1 Applicability\nBackground:\nAn interstate pipeline company delivers crude oil to tankage belonging to a refinery. These\ntanks are twenty miles from the refinery. The crude oil is pumped through a pipeline owned\nby the refinery from the tanks to the refinery. Sections of the pipeline pass through\nresidential commercial, and industrial areas in a city. The pipeline operates at a stress level\nover 20% of the specified minimum yield strength.\nQuestions:\nIs the pipeline subject to the regulations of Part 195 and the Hazardous Liquid Pipeline\nSafety Act of 1979?\nIn determining the application of the Hazardous Liquid Pipeline Safety Act of 1979 and Part\n195, does it matter whether or not the pipeline crosses a state line?\n§195.302 General requirements\nBackground:\nIn §195.302(a) it states that liquid pipelines must be hydrostatically tested in accordance\nwith Subpart E without leakage. Suppose that a test of fabricated piping is conducted. The\npiping being tested is totally above-ground and can be visibly inspected during the test.\n\n<<<PAGE 4>>>\n\nQuestions:\nDuring the test a small amount of leakage occurs through a test fitting (a valve or fitting\nused to perform the test, but which is not a part of the permanent installation). As long as\nthe test pressure is maintained at the required level and no other leakage is observed, is\nthis a valid test?\nDuring the test a small amount of leakage occurs in a component of the permanent\ninstallation - such as through the threads of a threaded nipple or some other component\nwhich could be considered as not compromising the integrity of the piping. As long as the\ntest pressure is maintained at the required level and no other leakage is observed, is this a\nvalid test?\nWhat is the intent of the term \"without leakage\"? If the leakage can be accounted for, is the\ntest acceptable? Your comments in regard to this are requested.\n§195.304 Testing of components\nBackground:\nThe regulations provide an exemption from hydrostatic testing requirements for\ncomponents that are the only items being replaced or added to a pipeline system.\nApparently, testing is not required if: (1) the component was hydrostatically tested at the\nfactory; or (2) the component was manufactured under a quality control system that\nensures each component is at least equal in strength to a prototype that was\nhydrostatically tested at the factory.\nQuestions:\nMust the factory test referred to be of a duration and pressure that is equal to or greater\nthan that specified in §195.302? The test durations specified in API Specification 6D, \"API\nSpecification for Pipeline Valves\" for example, are very short.\nIf when installing an individual component, such as replacing a valve or pump, it is\nnecessary to install or replace short sections of piping to accommodate the new\ncomponents, is it required that the component - valve or pump - be hydrostatically tested?\nBy revising short sections of piping, I am referring to the addition or removal and\nreplacement of a spool of pipe to accommodate dimensional differences of the\ncomponent.\nMust a component, such as a pump or a valve, be hydrostatically tested after receipt from\nthe manufacturer, if it has been factory tested and is not the only item being installed?","truncated":false,"body_characters":6386}