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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-76-001 ([ADB 76-1])

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

Interpretation Response Details

Response Publish Date:

Company Name: ADB 76-1

Individual Name:

Country: US

View the Interpretation Document

Response text:

OPSO Advisory Bulletin No. 76-1 January, 1976

operators install line markers at certain locations,
those areas where the operator and outsiders are
participating in a coordinated effort under law to
prevent interference with underground pipelines by
persons likely to cause damage. The precise role and
extent of participation of each party to this program,
including appropriate officials where applicable,
depends on the nature of the program established by law.

"The requirement of Section 1926.651(a) does not satisfy
this purpose for two reasons. First, the requirement is
not binding on all persons likely to interfere with
underground pipelines. Its scope is limited to persons
engaged in construction .... Secondly, the 'program'
contemplated by Section 1926.651(a) is one-sided in that
it does not require pipeline operators to provide
information or furnish assistance in response to notice
by contractors."

Relates to 49 CFR, §195.302, §195.304, §195.308, and §195.2

Question: Does Section 195.308 require that pipe at tie-ins
be hydrostatically tested if a carrier has a manufacturer's
certification for the pipe in accordance with Section 195.304?

OPSO Interpretation:...

"As a general requirement under
Section 195.302, each pipeline system or part thereof which is
installed, relocated, or replaced, must be hydrostatically
tested by the carrier. The purpose of Section 195.308 is to
provide that in hydrostatically testing pipe associated with
tie-ins in a pipeline system, the test may be made either with
the section to be tied in or separately.

"The exception from the general requirement under Section
195.304, where the manufacturer of a component makes a
certification regarding hydrostatic testing at the factory,
does not apply to pipe.

"While Section 195.2 includes the term 'pipe' within the
definition of the term 'component,' the two terms are used
distinctly in Section 195.304 to provide that only components
other than pipe need not be hydrostatically tested.

"Under this interpretation, a hydrostatic test performed on
pipe at the factory would not meet the requirements of Section
195.302 and 195.308 that pipe at tie-ins be hydrostatically
tested by the carrier for at least 24 hours either with the
section to be tied in or separately."

Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

The Secretary of Transportation has determined ....

Regulation Sections

Section Subject
195.2 Definitions
195.302 General requirements
195.304 Test pressure
195.308 Testing of tie-ins