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Interpretation Response #PI-71-008

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

Interpretation Response Details

Response Publish Date: 01-20-1971
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.



Joseph C. Caldwell
Director, Acting
Office of Pipeline Safety

Regulation Sections

Section Subject
§ 192.719 Transmission lines: Testing of repairs