Interpretation Response #PI-74-0149 ([Dow Chemical U.S.A.] [Mr. D. Glynn Rea, Jr])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Dow Chemical U.S.A.
Individual Name: Mr. D. Glynn Rea, Jr
Location State: LA Country: US
View the Interpretation Document
Response text:
December 6, 1974
Mr. D. Glynn Rea, Jr.
Dow Chemical U.S.A.
Louisiana Division
Plaquemine, LA 70764
Dear Mr. Rea:
This responds to your letter of November 6, 1974, asking whether or not 49 CFR 192.243(f) or 195.234(g) requires that the location of welds be recorded by station number or geographic feature. You further ask if recording the location of welds is required, why this is necessary when a weld is X-rayed and found acceptable.
Section 192.243(f) provides;
“(f)When nondestructive testing is required under §192.241(b), each operator must retain, for the life of the pipeline, a record showing by milepost, engineering station, or by geographic feature, the number of girth welds made, the number nondestructively tested, the number rejected, and the disposition of the rejects."
This section does not require that the precise location of welds be recorded. Rather, it requires the recording by milepost, engineering station, or geographic feature of certain information with respect to welds on the pipeline. Your practice of measuring lengths of pipe to locate each weld is not necessary to comply with §192.243(f).
Section 195.234(g) provides:
"(g) A record of the nondestructive testing must be retained by the carrier who is involved, including (if radiography is used) the developed film with, so far as practicable, the location of the weld. This record must be retained for 3 years after the line is placed in operation."
This section requires, where it is practicable to do so, recordation of the location of welds with the developed radiographic film. Any method of recording the location of welds may be used. Recording location by station number or geographic feature is one means of complying with the requirement. Recording the location of welds is of value for purposes of investigating accidents or compliance with the requirement for testing welds. The burden of complying with §195.234(g) is limited to the tests to which it applies. Any tests which your company voluntarily makes in addition to those to which §195.234(g) applies need not be recorded.
We realize recordation requirement of §195.234 (g) is more restrictive than §192.243(f). Consequently, we are considering the issuance of a notice of proposed rulemaking to amend §195.234(g).
Sincerely,
Original signed by:
Joseph C. Caldwell
Director
Office of Pipeline Safety