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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-71-054 ([Conam Inspection, Inc.] [J. Lee Ballard])

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

Interpretation Response Details

Response Publish Date:

Company Name: Conam Inspection, Inc.

Individual Name: J. Lee Ballard

Location State: NJ Country: US

View the Interpretation Document

Response text:

Mr. J. Lee Ballard
Sr. Vice President
Conam Inspection, Inc.
1385 Witherspoon Street
Rahway, New Hersey 07067

Dear Mr. Ballard:

[T]his is in reply to your letter of February 17, 1971, concerning the interpretation of 49 CFR,
Section 195.234(g), relating to liquid pipelines, and asking whether this section requires that each
completed weld radiographed must be located exactly by stake number and that the radiograph
number and weld number be listed on a form showing this location, or whether just the number of
welds made and the number of radiographies exposed must be shown by location, as is required
by 49 CFR, Section 192.243(f), relating to gas pipelines.

It is our interpretation that Section 195.234(g) requires that each radiograph be located as exactly
as is practicable in the particular circumstances.

We are aware that this record-keeping requirement for liquid lines is more restrictive than that for
gas pipelines contained in 49 CFR, Section 192.243(f). It is our intent to evaluate these
differences in the near future to determine the advisability of making the two rules more
consistent.

We appreciate your interest in pipeline safety.

Sincerely,

/signed/

Joseph C. Caldwell
Acting Director
Office of Pipeline Safety

Regulation Sections

Section Subject
192.243 Nondestructive testing