# Railroad Commission of Texas — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-94-024
- **title:** Railroad Commission of Texas — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1994-06-07
- **effective on:** Not available
- **summary:** PI-94-024 response to Railroad Commission of Texas concerning 192.503.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-024.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-024
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94024.pdf
**body:**

<<<PAGE 1>>>

Ms. Mary L. McDaniel, P.E.
Manager, Pipeline Safety
Railroad Commission of Texas
P.O. Box 12967
Austin, TX 78711-2967
Dear Ms. McDaniel:
Your letter of October 4, 1993, requests our assistance in responding to two questions.
Accordingly, we are providing the following information:
Question #1 What insight can RSPA provide on “ small entities” as the term is used in the
paragraph titled “ Regulatory Flexibility Act” in the Notice of Proposed Rulemaking-Drug and
Alcohol Testing Programs-published December 15, 1992, (57 FR 59714)?
Answer #1 The term “ small entity” is defined in 601 of the Regulatory Flexibility Act (5 U.S.C.
§ 601). The term “ small business” , a subset of “ small entity” is defined in 15 U.S.C. 632. In
addition to these provisions, regulations at 13 C.F.R. § 121.601 provided detailed standards to
assist in determining whether a business is a “ small business.” With respect to the pipeline
industry, size standards are discussed in 13 C.F.R. § 121.601, Division E, Major Groups 46 and
49, which were recently amended (see 59 FR 16529; April 7, 1994). I have enclosed copies of
the relevant statutory provisions and regulations.
Question #2 “ Our second question relates to the hydrostatic testing of replacement pipe under
§ 192.719(a). In a repair situation where several joints of pipe are welded together, does the
welded piece have to be hydrostatically tested as a unit? Each joint is pre-tested and the welds are
100% non-destructively tested.”
Answer #2 Section 192.719(a) is intended for testing of repairs of transmission pipelines, where
the pipe is required to be tested as a new line. The test requirements in Subpart J are applicable to
a new segment of pipeline, or the return to service of a segment of pipeline that has been
relocated or replaced.
In accordance with § 192.503(a) in Subpart J, the entire replaced segment must be tested in
accordance with Subpart J and § 192.619, except the tie-in joints that are excepted under §
192.503(d). It should be noted that the joints connecting the several pipe lengths are not tie-in
joints. However, if, in accordance with § 192.505(e), it is not practical to conduct a post
installation test, a preinstallation strength test must be conducted on each pipe length or the
segment by maintaining the pressure at or above the test pressure for at least 4 hours.
dal/192.503
94-06-07

<<<PAGE 2>>>

I am sorry for the delay in replying to you. Please let me know if you need further information on
either of the above questions.
Sincerely,
Cesar De Leon
Director, Regulatory Programs
Office of Pipeline Safety
Enclosures
cc:
dal/192.503
94-06-07
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