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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-76-042 ([ADB 76-8])

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 76-8

Individual Name:

Country: US

View the Interpretation Document

Response text:

Advisory Bulletin No. 76-8 August, 1976

Relates to 49 CFR, Part 192

FACILITIES...On August 9, 1976, the Materials Transportation Bureau (MTB) issued an
amendment to the Federal gas pipeline safety standards to modify many of the design,
construction, testing, operation, and maintenance regulations in 49 CFR Part 192 as they relate to
gas pipeline facilities and the transportation of gas offshore in or affecting interstate or foreign
commerce. The amendment also enlarges the scope of Part 192 by deleting the exemption in
Section 192.1 for certain rural gathering lines located offshore. The regulations will apply to the
offshore gathering of gas downstream from the outlet flange of each facility on the outer
continental shelf where hydrocarbons are produced or where produced hydrocarbons are first
separated, dehydrated, or otherwise processed, whichever facility is farther downstream. Purpose
of the amendment is to more clearly delineate the applicability of Part 192 to offshore gas
pipelines and to better assure the safe operation of those pipelines.

New or amended provisions cover offshore facilities as they relate to sections on scope of part,
definitions, class locations, general provisions, design factor for steel pipe, support and anchors,
design and construction of compressor stations, emergency shutdown of compressor stations,
transmission line valves--repair or removal of defects, protection from hazards, installation of pipe
in a ditch, cover over buried transmission line, external corrosion control monitoring, external
corrosion control test stations, atmospheric corrosion control monitoring, maximum allowable
operating pressure for steel or plastic pipelines, transmission lines--leakage surveys, transmission
lines--permanent field repair of imperfections and damages and permanent field repair of leaks,
and abandonment or inactivation of facilities.

The amended regulations generally become effective on November 1, 1976. However, additional
lead time to August 1, 1977, is provided for certain sections identified in the amendment.

Reprints of Amendment 192-27, Docket No. OPS-30 (41 Fed. Reg. 34598, August 16, 1976), are
being sent to those parties on the appropriate OPSO mailing lists.

Relates to 49 CFR, Part 195

AMENDED...On August 9, 1976, the MTB issued an amendment to the Federal liquid pipeline
safety standards, particularly as they apply to offshore pipeline facilities. The amendment modifies
many of the design, construction, testing, operation, and maintenance regulations in 49 CFR Part
195 as they relate to offshore transportation by pipeline in interstate or foreign commerce of
hazardous materials, petroleum, or petroleum products. It also enlarges the scope of Part 195 by
deleting the exemption in Section 195.1(b)(4) for rural gathering lines located offshore.

Regulations will apply to transportation in offshore pipelines which are located downstream from
the outlet flange of each facility on the outer continental shelf where hydrocarbons are produced
or where produced hydrocarbons are first separated, dehydrated, or otherwise processed,
whichever facility is farther downstream.

The purpose of the amendment is to more clearly delineate the applicability of Part 195 to
offshore liquid pipelines and to better assure the safe operation of those pipelines. In accordance
with Section 8(a) of the Deepwater Port Act of 1974 (33 USC 1507 (a)), the offshore pipelines
subject to the regulations in Part 195 and this amendment include the pipeline facilities which are
part of a deepwater port. Most of the amendments pertain to steel pipelines which are the ones
commonly used offshore. Provisions of the amendment cover offshore liquid pipeline facilities in
the specific subject areas of scope, internal design pressure, welds--repair of defects, welds--nondestructive testing and retention of testing records, external coating, cathodic protection
system, installation of pipe in a ditch, cover over buried pipeline, valves--general, valves--location,
test medium, general requirements, and cathodic protection. The amendments become effective
on November 1, 1976, except that additional lead time to August 1, 1977, is provided for specific
sections. Reprints of Amendment 195-11, Docket No. OPSO-35 (41 Fed. Reg. 34035, August
12, 1976), are being sent to those parties on the appropriate OPSO mailing lists.

Relates to 49 CFR, Part 195

PIPELINE SYSTEM...In recent weeks, the Department of Transportation (DOT) and its MTB
and OPSO have taken several actions with regard to the monitoring of construction work on the
Trans-Alaska Pipeline System. Early in July, Deputy Secretary of Transportation John W.
Barnum announced the following courses of action: (1) To identify all the girth welds that do not
meet the prescribed DOT standards, to have the irregularities corrected, and to assure that the
remainder of the construction work is carefully monitored to prevent any recurrence of the
problem; (2) Alyeska Pipeline Service Company has been directed to furnish DOT a plan and a
schedule for correcting all welding deficiencies, actions which will be verified to assure
compliance; (3) Retired Coast Guard Rear Admiral Joseph Steele was named to head an onsite
DOT task force to monitor pipeline progress during the balance of the 1976 construction season;
(4) Two members of the DOT's Office of Pipeline Safety Operations are conducting onsite overall
surveillance; and (5) Five additional DOT welding experts were sent to inspect welding and
radiography of girth welds.

The Deputy Secretary of DOT, along with representatives of other concerned Federal agencies,
conducted an onsite inspection of the Trans-Alaska Pipeline System in July to further assess the
situation and to consider new pipeline testing methods.

Relates to 49 CFR, Part 195

ALASKA WELDING PROBLEMS...DOT, MTB, and OPSO personnel recently testified before
two Congressional Committees on matters relating to the Trans-Alaska pipeline. On June 21,
Deputy Secretary of Transportation John W. Barnum, MTB Director James T. Curtis, Jr., OPSO
Acting Director Cesar DeLeon, and Lance Heverly and Lloyd Ulrich of the OPSO staff testified
before the Subcommittee on Energy and Power of the House Committee on Interstate and
Foreign Commerce. Testimony covered various matters about the construction of the oil pipeline
being built in Alaska by the Alyeska Pipeline Service Company. The areas of greatest concern to
the Subcommittee were those related to girth welds, weld inspection, recordkeeping of the
welding and weld inspection program, quality control and quality assurance programs of the
pipeline, and other matters related to assuring that the completed pipeline would meet the Federal
pipeline safety standards contained in 49 CFR Part 195.

On July 21, Deputy Secretary John W. Barnum and MTB Director James T. Curtis, Jr., appeared
before the Senate Interior and Insular Affairs Committee to testify concerning the construction of
the Trans-Alaska Pipeline System. Specific topics covered in the testimony included the
background of the Trans-Alaska construction developments, OPSO monitoring of construction
activities, relationship of DOT monitoring activities with those of other Federal agencies, studies
of stress design levels on the Alyeska pipeline, welding and weld inspection matters, current
welding problems and DOT's actions toward solving them, radiography of the pipeline welds,
additional methods of verifying the quality of the welds which are now being considered, and the
current DOT monitoring activities onsite in Alaska.

Relates to 49 CFR, §195.212 and Subpart D

3, 1976, the MTB issued a waiver to Alyeska Pipeline Service Company from compliance with
the requirement in Section 195.212 which provides that for each field bend of steel pipe
containing a longitudinal welds, "the longitudinal weld must be as near as practicable to the
neutral axis of the bend." In consideration of all available information, MTB found that under
present pipeline technology, there is little, if any, risk of pipe damage from placing a longitudinal
seam in a position other than near the neutral axis during bending. Accordingly, the waiver from
49 CFR 195.212 was granted subject to the following conditions: (1) All bends must be made
using an internal bending mandrel, and (2) Alyeska shall report all unacceptable seam damage due
to bending and bend failures during testing to MTB. Because of the significance of the findings,
in the near future MTB will issue a notice of proposed rule making to modify the general
requirement in 49 CFR 195.212(b)(3) consistent therewith.

On August 12, 1976, the OPSO issued a notice (Docket No. 76-12W) concerning the Trans-Alaska pipeline--anticipated petition for waivers. Alyeska Pipeline Service Company has advised the DOT that it expects to petition the MTB for waivers to allow girth weld defects or arc burns greater than allowed by 49 CFR Part 195, Subpart D, on the basis of a fracture mechanics concept. The anticipated petition(s) and the proceedings thereon may raise issues that require analysis of interrelated technical problems. The notice was published to bring the nature of those problems to the attention of interested Federal and State agencies and other interested persons at the earliest practicable time. In consideration of the nature and number of possible weld defects to be addressed, the notice also sets forth requirements covering preliminary determination of the information and data required for processing any request for a waiver.

Persons planning to file comments on Docket No. 76-12W or on the anticipated petition(s) who
wish to be served with copies of future notices issued by the OPSO in this matter, may file a
request to be placed on the Notice Mailing List for that Docket with the Docket Clerk at the
Office of Pipeline Safety Operations, Department of Transportation, Washington, D.C. 20590.

All comments received will be considered and will be made available in the docket for public
inspection along with the petition(s) and related analyses for public inspection upon receipt.

Reprints of the waiver, Docket No. Pet. 76-11W (41 Fed. Reg. 34103, August 12, 1976), and of
the Notice, Docket No. 76-12W (41 Fed. Reg. 34375, August 13, 1976), were sent to those
parties on the Associations and Publications mailing lists.

BAILEY NAMED NTSB MEMBER...Miss Kay Bailey, a former Texas legislator and one-time
aide to Anne Armstrong, the U.S. Ambassador to Britain, has been sworn in as a member of the
National Transportation Safety Board (NTSB). Bailey, who is a lawyer and a former television
news correspondent, will serve as Vice Chairman of the Board for the first two years of her five year

A Republican, Miss Bailey was elected to the Texas House of Representatives in 1972. She was
reelected in 1974, and was seeking a third term when President Ford nominated her to replace
Isabel A. Burgess whose NTSB term expired December 31, 1974. Miss Bailey's legislative work
centered on transportation. She cosponsored a bill to reorganize the Texas Highway Department
and to create a mass transit authority for Houston, Texas. She also was appointed to the
Transportation Task Force of the National Legislative Conference. The Conference studied
problems of railroads, highways, airports, and the trucking industry.

Miss Bailey, 32, was born in Galveston, Texas. She attended the University of Texas and the
University of Texas School of Law, receiving an LL.B. in 1967. She was admitted to the Texas
State Bar in 1967. From 1969 to 1971, Bailey was a political correspondent for television station
KPRC, Houston, the first woman to hold the job. She also has been in the private practice of law
with the firm of Reynolds, White, Allen, and Cook.

seminars, "Safety Requirements for Gas Pipeline Systems," have been scheduled for the remainder
of the year:

September 8-9, 1976 Wisconsin
September 27-28, 1976 Louisiana
Sept. 30-Oct. 1, 1976 Louisiana
October 18-19, 1976 Texas
October 21-22, 1976 Texas
October 27-28, 1976 Ohio
November 29-30, 1976 Pennsylvania
December 2-3, 1976 Pennsylvania
December 15-16, 1976 North Carolina
December 20-21, 1976 O P E N

Questions concerning the scheduling of future 2-day gas industry safety seminars should be
addressed to the Chief, State Programs Division, OPSO. Persons interested in attending any of
the above scheduled seminars should contact their appropriate State agency for details. Seminars
have substantial emphasis on cathodic protection and gas failure investigation, particularly as they
relate to operators of smaller gas systems.

PERCENT...For the first time since the OPSO gas pipeline safety program was established in the
DOT in 1968, the program now includes all 50 States and the District of Columbia and Puerto
Rico. The most recent State to affiliate with the national gas pipeline safety program was New
Jersey. The Board of Public Utility Commissioners has signed a 5(b) agreement with OPSO and
expects to participate along with 45 other States in the Federal grant-in-aid program for 1977.

been developed by OPSO to assist State agencies in applying for and administering grant-in-aid
funds. This Guide, which is designed to simplify the pipeline safety grant program, will be
distributed with the grant application material this month.

Relates to 49 CFR, §192.223, §192.227, and §192.229


Question: Must a welder who qualified under 49 CFR 192.227(a)(2) by making a 12-inch butt
weld and 12-inch inverted tee test have a butt weld and a fillet weld cut out to verify his
qualifications under Section 192.227(c)(2)(i)?

OPSO Interpretation:..."As provided by Section 192.223(b), each welder must perform a
qualifying test for the welding procedure to be used. When a welder qualifies under Section
192.227 (a)(2), to maintain the qualification, Section 192.229(c) requires that within the
preceding six calendar months, the welder must have had at least one weld tested and found
acceptable under either Section 3 or 6 of API Standard 1104. Section 192.227(c)(2)(i) requires
that a production weld be cut out, tested, and found acceptable in accordance with the qualifying
test only if a welder qualifies under Section 192.227(c).

"When a welder initially qualifies for more than one welding procedure, to maintain the
qualification for a particular procedure, the welder must have a weld using that procedure
tested, and found acceptable. A welder need not maintain the qualifications for all the procedures
for which the welder initially qualifies in order to weld under a single procedure."


Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

The Secretary of Transportation has determined that publication of this periodical is necessary in
the transaction of the public business required by law of this Department. Use of funds for
printing this periodical has been approved by the Director of the Office of Management and
Budget through November 30, 1976.

Regulation Sections

Section Subject
192.227 Qualification of welders and welding operators
192.229 Limitations on welders and welding operators
195.212 Bending of pipe