Interpretation Response #PI-71-008 ([United Natural Gas Company] [Richard M. DiValerio])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: United Natural Gas Company
Individual Name: Richard M. DiValerio
Location State: PA Country: US
View the Interpretation Document
Response text:
January 20, 1971
Mr. Richard M. DiValerio
United Natural Gas Company
308 Seneca Street
Oil City, Pennsylvania 16301
Dear Mr. DiValerio:
This is in reply to your letter requesting an interpretation of the relationship of 49 CFR, Sections
192.241(b) and 192.719(a)(2).
Section 192.241(b) established limited exceptions to the requirement for non-destructive testing
of all welds on pipe to be operated at 20 percent or more of SMYS, while §192.719(a)(2) deals
only with repair welds.
As you have mentioned repairs usually consist of replacing a short section of pipe. The tie-in
welds on these short sections of pipe are generally more difficult to make and more often
performed under adverse conditions. Experience has demonstrated there is a greater need to
require weld quality in these situations.
Therefore, if these welds are not strength tested, the requirements of §192.719(a)(2) must
override the exceptions in §192.241(b).
Thank you for your interest in pipeline safety.
Sincerely,
/signed/
Joseph C. Caldwell
Director, Acting
Office of Pipeline Safety