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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-74-0141 ([California Public Utilities Commission] [Mr. William R. Johnson])

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

Interpretation Response Details

Response Publish Date:

Company Name: California Public Utilities Commission

Individual Name: Mr. William R. Johnson

Location State: CA Country: US

View the Interpretation Document

Response text:

October 18, 1974

Mr. William R. Johnson, Secretary
California Public Utilities Commission
California State Building
San Francisco, CA  94102

Dear Mr. Johnson:

This refers to you letter of August 2, 1974, requesting interpretations of three subjects under 49 CFR Part 192.

First, with respect to isolating a test segment from an adjacent segment under section 192.557(b)(5), you ask if the adjacent segment must be cut and capped or may a regulator be used to isolate the test segment.  Any means may be used to provide the required t isolation under section 192.557(b)(5), including the use of a regulator.

Secondly, you ask what type of pressure test must be performed under section 192.619(a)(2)(ii) in uprating to the level permitted by that section.  Section 192.619(a)(2)(ii) does not specify the type of pressure test required.  Therefore, any normally accepted means for leak or strength testing, such as the ones you mention, will suffice.

Finally, with respect to an interpretation published in Advisory Bulletin No.74-7 involving uprating steel pipe to a pressure which produces a hoop stress less than 30 percent of SMYS, you ask why it was stated that a "strength" test must be performed under section 192.619(a)(2)(ii).  In this interpretation, the nature of the test required by section 192,619(a)(2)(ii) was not at issue and not relevant to the decision therein.  The term "strength test" was used in a broad sense to refer to the test requirements of section 192.619(a)(2)(ii) without intending to suggest that particular criteria is involved.  We recognize, however, that to the extent the terms "strength test" and  "leak test" connote different types of pressure tests in the mind of the gas industry, the use of "strength test" in the published interpretation was an overstatement of the requirement.

We appreciate your concern for the correctness and clarity of the Federal gas pipeline safety standards and the published interpretations.  We anticipate that future rule making actions by this office will eliminate possible confusion in the areas you have discussed.

Sincerely

Joseph C. Caldwell, Director
Office of Pipeline Safety

Regulation Sections

Section Subject
192.507 Test requirements for pipelines to operate at a hoop stress less than 30 percent of SMYS and at or above 100 p.s.i. (689 kPa) gage