Interpretation Response #PI-78-0104

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

Interpretation Response Details

Response Publish Date: 07/31/1978

Company Name:

Individual Name:

Country: US

View the Interpretation Document

Response text:

PI-78-0104

July 31, 1978
Roberto N. Artola
Gas Del Estado
Normalizacion e Informacion Tecnica
Alsina 1774
1088 Buenos Aires
Argentina

Dear Sir:
This is in reply to your letter of May 8, 1978, asking if gas pipelines to be operated above 20
percent SMYS that lie within a highway or railway right-of-way must meet the requirements of 49 CFR
192.243(d)(4) whether they cross or parallel the highway or railway.

Section 192.243(d)(4) sets forth the percentage of each day’s field butt welds that must be
nondestructively tested on pipelines to be operated at 20 percent of SMYS or more when such testing
is required by Section 192.241(b). Paragraph (d)(4) states that: “Within railroad or public highway
rights-of-way…100 percent.” Under this requirement, the term “within” refers to pipelines inside
the right-of-way, including those that either cross or parallel a railroad or highway. Thus the
applicability of Section 192.243(d)(4) is not affected by the relative position of the highway or
railroad to a pipeline within the  right-of-way.

We trust that this adequately responds to your inquiry.  If we can be of any further assistance,
please let us know.
Sincerely, Cesar DeLeon Associate Director for
Pipeline Safety Regulation
Material Transportation Bureau
Ministerio de Economia
Corporacion de Empresas Nacionales
Gas del Estado

May8,1978

Department of Transportation
400, 6th. St., S.W.
Washington, (D.C.)
20590
Estados Unidos de America del Norte
Gentlemen,
I am the manager of the Normalization and Technical Information Department of the State owned
utility Gas del Estado. Our duties include the analysis and studies of standards and specifications
to be complied with within the scope of our Company.

I am requesting you for an interpretation of the Minimum Federal Standards.

Please, kindly inform us whether the specification in 192.243 - d - 4 must be applied to all the
natural gas pipelines operating to hoop stresses of over 20 percent of the SMYS running within the
right-of-way of highways or railway lines, in parallel or in crossings.

We thank you in advance for your kind cooperation. Cordially yours,
Roberto N Artola
Jefe Departamento
p.p. Gas del Estado

Regulation Sections