{"operation":"document","citation":"PI-99-0106","title":"Colonial Pipeline Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-12-08","effective_on":null,"summary":"PI-99-0106 response to Colonial Pipeline Company concerning 195.302.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0106.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0106.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0106","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1999/g99_12_08_Gilliam_195.302_wsx.pdf","body":"<<<PAGE 1>>>\n\nPI-99-0106\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nDecember 8, 1999\nMr. Stephen E. Gilliam\nRegulatory Administrator\nColonial Pipeline Company\nResurgens Plaza\n945 East Paces Ferry Road\nAtlanta, Georgia 30326\nDear Mr. Gilliam:\nThis is in response to your letter of November 2, 1999, in which you requested an interpretation of 49 CFR\n§195.302(c)(2) regarding the testing schedule for older hazardous liquid pipelines.\nThe best way to explain this rule is by way of two examples:\nExample (1) - Assume a 100-mile long, pre-1970 untested pipeline of which 70 miles are\nElectric Resistance Welded (ERW) pipe. What is an operator required to test by December 7, 2000,\nand by December 7, 2003?\nAnswer - Because the 70 miles of ERW pipe is more than 50% by mileage of the pipeline, all 100\nmiles must be pressure tested before December 7, 2000.\nExample (2) - Assume a 300-mile, untested pre-1970 untested pipeline system. What is an\noperator required to test by December 7, 2000, and by December 7, 2003?\nAnswer - If existing records show the 300-mile pipeline contains at least 50% by mileage of pre-\n1970 ERW pipe, the entire pipeline must be tested by December 7, 2000. If the 300-mile pipeline\ncontains less than 50% pre-1970 ERW pipe, at least 50% of the pipeline must be tested by December 7,\n2000 and the remainder must be tested by December 7, 2003.\nThe regulations do not define the beginning and termination points of a pipeline. The Office of Pipeline Safety\n(OPS) recognizes that many pipeline systems are interconnected such that individual pipelines are difficult to\nidentify. For compliance purposes, OPS will accept an operator determination of the beginning and\ntermination points of a pipeline when the determination is reasonable, practicable, and is based on existing\ndocumentation. Operators who designate the beginning and termination points of a pipeline to circumvent\ntesting deadlines will be subject to compliance orders requiring testing.\nFor example, a typical 300-mile system may be determined to contain three individual 100-mile pipelines.\nConsider that one pipeline contains over 50% pre-1970 ERW pipe, the second has 40% pre-1970 ERW pipe,\nand the third has no ERW pipe. In accordance with the 195.302(c)(2)(i)-\n(A) before December 7, 2000, a pressure test is required for the entire pipeline (100 miles) that has\nover 50% pre-1970 ERW pipe. Also, before December 7, 2000, a pressure test is required for at least\n100 miles (total) in any portions of the second and/or third pipeline.\n(B) before December 7, 2003, a pressure test is required for the remaining portions of pipeline in\nthe second and third pipelines.\nIf we can be of further assistance in this matter, please contact me at (202) 366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nColonial Pipeline Company\nResurgens Plaza\n945 East Paces Ferry Road\nAtlanta, Georgia 30326\nNovember 2, 1999\nMr. Richard B. Felder\nAssociate Administrator\nU.S. Department of Transportation\nOffice of Pipeline Safety\n400 7th Street, S.W. Room 7128\nWashington, DC 20590\nDear Mr. Felder:\nColonial Pipeline Company requests a written interpretation of Part 195.302 (c)(2): For pipelines scheduled for\ntesting each operator shall —\n(i) Before December 7, 2000, pressure test —\n(A) Each pipeline identified by name, symbol, or otherwise that existing records show contains\nmore than 50 percent by mileage (length) of electric resistance welded pipe manufactured\nbefore 1970, and\n(B) At least 50 percent of the mileage (length) of all other pipelines; and\n(ii) Before December 7, 2003, pressure test the remainder of the pipeline mileage (length).\nWe have had verbal discussions with Mr. Mike Israni regarding this rule and would like to make sure we\nunderstand the intent of the code and insure we test the sections of pipe by the required date.\nSincerely,\nStephen E. Gilliam","truncated":false,"body_characters":3994}