PHMSA Central Region — Pipeline Safety Interpretation

Page 1PI-84-0201 February 6, 1984 INFORMATION: Request for Regulation Clarification From: Richard L. Beam Associate Director for Pipeline Safety Regulation, DMT-30 To: Chief Central Region, DMT-14 This responds to your memo dated November 23, 1983, asking several questions about Part 195. First, you asked if a refinery's 20-mile pipeline between its storage tanks and the refinery, itself, is subject to Part 195 and the Hazardous Liquid Pipeline Safety Act of 1979. The 20- mile pipeline transports oil that is delivered to the tanks by an interstate pipeline. Given these facts, I believe the 20-mile pipeline would be subject to the Act, because it is used to move hazardous liquid in or affecting interstate or foreign commerce and the movement is not specifically excepted from the Act's jurisdiction under the definition of "transportation of hazardous liquids." Whether the 20-mile pipeline is subject to Part 195 depends on whether it is subject to the jurisdiction of FERC as stated in §195.1(a)(1). If the 20-mile pipeline is not on FERC's list of jurisdictional pipelines, it nevertheless may be subject to FERC's jurisdiction if it operates in interstate commerce. FERC's jurisdiction does not depend on passage of a pipeline across State lines. A pipeline wholly within one State may be jurisdictional if it provides the final leg of an interstate journey. Whether the 20-mile pipeline is such a final leg depends on whether the parties who arranged for the interstate movement intended the storage tanks or the refinery, itself, to be the destination of the shipment of oil. Although there are no facts given on this issue, the 20-mile pipeline would be jurisdictional only if the destination is the refinery. Secondly, you asked about the term "without leakage" in §195.302(a), which requires that certain pipelines be hydrostatically tested "without leakage." I believe this standard is clear, no part of the pipeline being tested may leak during the test. Leakage of the test equipment is significant only if it impairs the conduct of the hydrostatic test of the pipeline. Thirdly, you asked about §195.304(b), which excepts certain components from the hydrostatic testing requirements of §195.302 on the basis of hydrostatic testing by the manufacturer. As indicated by Interpretation 79-13, dated April 13, 1979, since §195.304(b)#

Page 2provides an exception from §195.302, the duration requirements of §195.302 do not apply to components to which the exception applies. Likewise, the pressure requirements do not apply. Also, as indicated by Interpretation 80-16, dated December 1, 1980, when more than a single component is being installed, §195.304(b) does not apply. A valve or pump plus an adjoining spool of pipe would be more than a single component.#

Page 3Memorandum U.S. Department of Transportation Research and Special Programs Administration Date: November 23, 1983 Subject: Request for Regulation Clarification From: Chief Central Region, DMT-14 Thru: Associate Director for Operations & Enforcement, DMT-10 To: Associate Director, Office of Pipeline Safety Regulation, DMT-30 §195.1 Applicability Background: An interstate pipeline company delivers crude oil to tankage belonging to a refinery. These tanks are twenty miles from the refinery. The crude oil is pumped through a pipeline owned by the refinery from the tanks to the refinery. Sections of the pipeline pass through residential commercial, and industrial areas in a city. The pipeline operates at a stress level over 20% of the specified minimum yield strength. Questions: Is the pipeline subject to the regulations of Part 195 and the Hazardous Liquid Pipeline Safety Act of 1979? In determining the application of the Hazardous Liquid Pipeline Safety Act of 1979 and Part 195, does it matter whether or not the pipeline crosses a state line? §195.302 General requirements Background: In §195.302(a) it states that liquid pipelines must be hydrostatically tested in accordance with Subpart E without leakage. Suppose that a test of fabricated piping is conducted. The piping being tested is totally above-ground and can be visibly inspected during the test.#

Page 4Questions: During the test a small amount of leakage occurs through a test fitting (a valve or fitting used to perform the test, but which is not a part of the permanent installation). As long as the test pressure is maintained at the required level and no other leakage is observed, is this a valid test? During the test a small amount of leakage occurs in a component of the permanent installation - such as through the threads of a threaded nipple or some other component which could be considered as not compromising the integrity of the piping. As long as the test pressure is maintained at the required level and no other leakage is observed, is this a valid test? What is the intent of the term "without leakage"? If the leakage can be accounted for, is the test acceptable? Your comments in regard to this are requested. §195.304 Testing of components Background: The regulations provide an exemption from hydrostatic testing requirements for components that are the only items being replaced or added to a pipeline system. Apparently, testing is not required if: (1) the component was hydrostatically tested at the factory; or (2) the component was manufactured under a quality control system that ensures each component is at least equal in strength to a prototype that was hydrostatically tested at the factory. Questions: Must the factory test referred to be of a duration and pressure that is equal to or greater than that specified in §195.302? The test durations specified in API Specification 6D, "API Specification for Pipeline Valves" for example, are very short. If when installing an individual component, such as replacing a valve or pump, it is necessary to install or replace short sections of piping to accommodate the new components, is it required that the component - valve or pump - be hydrostatically tested? By revising short sections of piping, I am referring to the addition or removal and replacement of a spool of pipe to accommodate dimensional differences of the component. Must a component, such as a pump or a valve, be hydrostatically tested after receipt from the manufacturer, if it has been factory tested and is not the only item being installed?#