# Memo: Internal — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-93-041
- **title:** Memo: Internal — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1993-07-16
- **effective on:** Not available
- **summary:** PI-93-041 response to Memo: Internal concerning 195.406.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-041
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93041.pdf
**body:**

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FROM: DeLeon, Cesar
TO: Huntoon, Ivan DATE: 07/16/93
TIME: 1:39 PM
CC: DeLeon, Cesar
SUBJECT: Records for pressure tests - HVL lines
PRIORITY:
ATTACHMENTS:
--------------------------------------------------------------------------------------------------
Your July 14, 1993 draft letter to Mosteller regarding testing records that must be
maintained to satisfy requirements of 195.406(a) (5) is O.K. Send it.
Your 7/14/93 fax attaching "Ulysses to Scott City Pipeline; Hydrostatic Test Daily Report;
Ulysses to Holcomb Station" requested to know if this daily report complied with the
requirements for "recording charts or logs" in 195.406(a)(5). No it does not, because it is
a daily report of the hydrostatic testing, rather than the "recording" chart and log.
dal\195.406\93-07-16

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July 14, 1993
Mr. Glen Mosteller
Plant Manager
Trident NGL, Inc.
Jayhawk Plant
Route 1, Box 14D
Satanta, Kansas 67870
This letter is in response to Mr. Bodenhamer's request for a determination as to the
requirements for testing records that must be maintained to satisfy the requirements of
§195.406(a)(5) of the Regulations for the Transportation of Hazardous Liquids by
Pipelines (Title 49 C.F.R., Part 195). Records pertaining to pressure testing of specific
pipelines accompanied the April 28, 1993 request.
The regulation, as it pertains to your request, stipulates a requirement for the
determination of maximum operating pressure for an onshore interstate HVL line
constructed before January 8, 1971, and an onshore intrastate pipeline constructed before
October 21, 1985, and not tested under Subpart E of Part 195. Section 195.406(a)(5)
limits the maximum operating pressure based on a pressure test or previous operating
pressure. The limitation is:
a. 80% of the test pressure to which the pipeline was subjected for four or
more continuous hours, or
b. 80% of the operating pressure to which the pipeline was subjected for four
or more continuous hours.
Additionally, the pressure test or the operating pressure, whichever is used, must be
documented by recording charts or logs made at the time the test or operations were
conducted.
Clarification of the requirements for documentation of the test pressure or operating
pressure is found in the discussion of the final rule of the amendment to the regulations
which provided this criteria for determination of maximum operating pressure,
Amendment 195-17, Testing Highly Volatile Liquid Pipelines. A copy of this document is
attached. It states:
"the final rules require carriers who wish to demonstrate that pipelines have been
previously tested to 125 percent of MOP to use recording charts or logs made at
the time the test was conducted."
dal\195.406\93-07-16

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Therefore, the documentation required must include the recording charts or logs of the
pressures that were made over the 4-hour period during which the test or operation was
conducted. A summary report or a declaration that the test or operation was conducted is
not satisfactory documentation.
Based on our review of the records submitted, only those records which include a
recording chart or a log documenting the pressures maintained over the 4-hour period
would be acceptable. The chart or log must have been made throughout the duration of
the 4-hour period. Charts and/or logs, as required by this rule, only accompanied the
records for the pipelines identified as:
a. Cheney - Hutchinson 6"
b. Cheney - Wichita 6"
c. Jayhawk - Hutchinson 8"
d. Wilburton - Postle Hough 2"
Please let me know if you have any questions in regard to this matter.
Sincerely,
Ivan A. Huntoon
Director, Central Region
Office of Pipeline Safety
Attachment
dal\195.406\93-07-16
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