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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-22-0014

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

Interpretation Response Details

Response Publish Date:

Company Name: National Grid

Individual Name: Mr. Michael Kern

Location State: NY Country: US

View the Interpretation Document

Response text:

Mr. Michael Kern
Director, Gas Transmission Engineering and Design
National Grid
25 Hub Drive
Melville, NY 11747

Dear Mr. Kern:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated August 16, 2022, you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 192 with respect to what is acceptable for traceable, verifiable, and complete (TVC) documentation requirements of §§ 192.517(a) and 192.624(a) for onshore steel gas transmission pipelines.

You stated that National Grid operates and maintains transmission and distribution pipelines in the State of New York. You stated your request is pertaining to a PL E18 pipeline built in 1964 and that significant pipeline documentation exists in support of the pipeline’s maximum allowable operating pressure (MAOP).

You believe the documents you possess, multiple and complementary formal written correspondence explicitly stating that a post construction pressure test was performed in accordance with existing New York State Pipeline Safety Regulations in effect at the time of installation, is enough to meet the TVC requirements. You stated, unfortunately, as of your interpretation request, actual pressure test chart records are not retrievable, and noted that charts were not required at the time of construction under the New York regulations. You listed five items as the complementary correspondence documents and attached the actual correspondence letters with your request but did not provide actual test data.

You stated that in the absence of the actual pressure test recording charts, you are seeking an interpretation regarding whether the New York State Public Service Commission can accept as evidence the official correspondence at the time of commissioning as proof of pressure test in fulfillment of the requirements of § 192.624(a)(1).

The applicable 49 CFR Part 192 section is reprinted below:

§ 192.517 Records.
(a) An operator must make, and retain for the useful life of the pipeline, a record of each test performed under §§ 192.505, 192.506, and 192.507. The record must contain at least the following information:

(1) The operator's name, the name of the operator's employee responsible for making the test, and the name of any test company used.
(2) Test medium used.
(3) Test pressure.
(4) Test duration.
(5) Pressure recording charts, or other record of pressure readings.
(6) Elevation variations, whenever significant for the particular test.
(7) Leaks and failures noted and their disposition.

The § 192.517(a) records requirements are the minimum requirements for pressure tests to meet § 192.624(a). Therefore, TVC pressure test records (i.e., test pressure logs or charts or a pressure test summary log of the test) must contain the following supporting data:

  • Name of person conducting the test and test being conducted by whom – operator or test company.
  • Test medium used during the test.
  • Location of the pipeline segment being tested by mile posts or survey stations that can be referenced to pipeline alignment or fabrication drawings.
  • Time interval of the pressure test - Time, Day, Month, and Year.
  • Minimum test pressure throughout the test duration. A pressure chart records pressure throughout the test, so a single test pressure does not support documentation throughout the test.
  • Minimum test pressure must be supported by known elevation changes throughout the pressure test segment. If the elevations are unknown, the pipeline segment can be resurveyed for elevation variances to meet §§ 192.517(a) and 192.624(a).
  • Documentation of any leaks of failures. If the log or chart does not show these as being found during the test, no additional documents are required.

To satisfy 49 CFR Part 192, Subpart J, pressure test records must also document the MAOP, class location, and that an 8-hour test duration was maintained. To meet § 192.624(a)(2), a pressure test segment must have material properties records required by § 192.624(c)(1)(ii) or (iii). A pressure test segment should be documented in a pipeline alignment drawing that shows the pipeline location, stationing, class location, pipe diameter, pipe wall thickness, pipe grade (minimum yield strength, ultimate tensile strength), pipe seam type, MAOP, and other attributes. To confirm that the test pressure meets the § 192.624(c)(1)(i) requirements for minimum test pressure, the operator is required to provide verification of the pipeline segment class location.

To satisfy § 192.624(a)(1), a pressure test segment that does not have material properties, must have material properties records obtained opportunistically to meet other sections of the regulations that require material records (i.e., §§ 192.712(d) and (e), 192.619(a)(4), 192,714(b), 192.929(b)(4)(i), and 192.933(a) as applicable).

Operators must ensure that TVC records meet the §§ 192.517(a), 192.619(a)(2), and 192.624(c)(1)(i) pressure test requirements, as applicable, or a new pressure test that meets both §§ 192.517(a) and 192.624(c)(1) with verification of material properties is required.

In this case, you did not provide test records. Without test records, correspondence letters whether official or not are not acceptable TVC records to meet the requirements of §§ 192.517(a) and 192.624(a) for an onshore steel gas transmission pipeline.

If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.


John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.517 Records