Interpretation Response #PI-74-0147

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 12/03/1974

Company Name:

Individual Name:

Location State: TX Country: US

View the Interpretation Document

Response text:

December 03, 1974

Interpretations of Section 195.304
Testing of Components and Section 195.308
Testing of Tie-ins
Director, Office of Pipeline Safety

Chief, Houston Field Office

This refers to your office memorandum request for interpretations concerning a possible conflict between Section 195.304 and 195.308. You state that some operators are circumventing the requirement of hydrostatically testing replacement pipe by using the definition of “component” and a certification from the pipe mill to the effect that the pipe was hydrostatically tested at the mill.

The conflict has arisen because of the fact that various operators are alleging that “pipe” is a component and hence within the exemption for hydrostatic testing provided by Section 195.304(b) when it is accompanied by a certificate from the manufacturer stating that it was hydrostatically tested at the factory.  When the conditions for the exemption of components under Section 195.304(b) are met, it is alleged that the provisions of Section 195.308 are no longer applicable.

Under no circumstance will a normal factory hydrostatic test of the pipe which lasts only a few seconds be sufficient to meet the requirement of Section 195.308.  The same requirements for pressure and test duration applicable to a new pipeline under Section 195.302 are required for any segment of pipe added to a pipeline under Section 195.308.  Section 195.308 specifically requires that “pipe associated with tie-ins must be hydrostatically tested.”  Even though Section 195.304(b) exempts certain pipe, as a component, from the field testing requirement, as a matter of proper language construction, the specific and more stringent safety requirement of Section 195.308 has precedence over the general, less stringent provision in Section 195.304(b).

Joseph C. Caldwell

Regulation Sections