{"operation":"document","citation":"PI-94-010","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1994-02-18","effective_on":null,"summary":"PI-94-010 response to Memo: Internal concerning 192.557.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-010","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94010.pdf","body":"<<<PAGE 1>>>\n\nInformation: Interpretations of § 192.557\nCesar De Leon\nDirector, Technology and Standards Office\nIvan Huntoon\nDirector, Central Region\nThis responds to your note of November 7, 1993, which transmitted two old interpretations of\n§ 192.557 and asked if they were still correct. The following changes apply:\nLetter to John Searcy, dated March 11, 1974\nThe second sentence of the second paragraph incorrectly implies that the pressure test required in\nuprating under § 192.557 must be done concurrently with the uprating process. However, the\nsource of the pressure test requirement, §192.619(a)(2)(ii), which limits MAOP on the basis of\ntest pressure, does not prescribe the timing of the test pressure. So any previous test pressure\n(including any operating pressure that suffices as a test pressure) could qualify for uprating under\n§ 192.557. Only if the pipeline had not previously been pressure tested or if the previous test\npressure were insufficient would the pipeline have to be pressure tested concurrently with\nuprating.\nIn addition, the last sentence of the second paragraph incorrectly implies that the incremental\npressure increases required by §192.557(c) apply to pressure tests done concurrently with\nuprating. However, a comparable rule, § 192.555(e), requires incremental pressure increases only\nfor pipelines that are not tested concurrently with uprating - pipelines that either were previously\npressure tested or need not be pressure tested. Given this comparable rule, it is not reasonable to\ninterpret § 192.557(c) to require incremental pressure increases during pressure testing.\nLetter to William R. Johnson, dated May 6, 1974\nAs above, the second sentence of the second paragraph incorrectly implies that uprating under\n§ 192.557 requires concurrent pressure testing in all cases.\n#\ndal/192.557/94-02-18","truncated":false,"body_characters":1843}