Interpretation Response #PI-76-013

Interpretation Response Details

March 26, 1976

Mr. Hines D. Lively
Manager, Piping Design
Brown & Root, Inc.
P.O. Box 3
Houston, TX 77001

Dear Mr. Lively:

This is in response to your letter of January 21, 1976, requesting information concerning the jurisdiction of the Federal standards for the Transportation of Liquids by Pipeline, Part 195 of Title 49 of the Code of Federal Regulations (Part 195), and the ANSI B31.4, Code for Pressure Piping, Liquid Petroleum Transportation Piping Systems.

Under the Transportation of Explosives Act, 18 U.S.C. 831-835, the Department of Transportation (DOT) has jurisdiction over common, contract, and private carriers engaged in interstate or foreign commerce who transport liquid hazardous materials by pipeline. Safety regulations issued under 18 U.S.C. 834 governing the design, construction, operation, and maintenance of interstate liquid pipelines are published in Part 195.

The ANSI B31.4 code is an industry standard developed under the direction of the American National Standards Committee B31 organized under the procedures of the American National Standards Institute, Inc., and is under the administrative sponsorship of the American Society of Mechanical Engineers. ANSI B31.4 is enforceable as a Federal standard only for the specific paragraphs referenced in Part 195.

The following is our response to your specific questions:

Question 1: Does a pipeline as shown in SK-1-20-76 fall under the jurisdiction of DOT or only ANSI B31.4? Please answer separately for sections A, B, and C as shown on sketch.

Sections A, B, and C would be subject to the regulations in 49 CFR Part 195 only if they are used in the transportation of liquid hazardous materials by pipeline in interstate or foreign commerce.

The electrical transmission line indicated in the lower part of Sketch SK-1-20-76 is not a part of the pipeline and is not considered when the question of pipeline jurisdiction is determined.

Question 2: When DOT does apply does section 421 apply (which is not even referred to by Title 49) or does section 195.208 apply?

Section 421, Design of Pipe Supporting Elements, in ANSI B31.4 has not been referenced in Part 195 and is not applicable; however, Section 195.208, Welding of supports and braces, in Part 195 is applicable.

Question 3: If 195.208 applies, is nonintegral support preferred?

The regulations in Part 195 are for the most part performance standards. Where a specific method is neither required nor excluded then the operator has the responsibility of selecting a method of compliance that will conform with the appropriate standards.

Questions 4: If not, can "excess thickness" be considered sufficient reinforcement is lieu of a "cylindrical member continuously welded around the pipe."

This question is moot as the answers to questions 2 and 3 indicate that Section 195.208 is applicable.

ANSI B31.4 is not a Federal standard unless it is specifically referenced in Part 195. The Office of Pipeline Safety Operation considers it a useful guide, providing procedures that may be helpful in complying with the performance requirements of the Federal standards. Any questions you might have relative to ANSI B31.4 should be directed to:

Secretary
American National Standards Committee B31
The American Society of Mechanical Engineers
United Engineering Center
345 East 47th Street
New York, New York 10017

We appreciate your interest in pipeline safety. If you have any further questions, do not hesitate to call or write.

Sincerely,

Cesar DeLeon

Acting Director
Office of Pipeline
Safety Operations

Regulation Sections