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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-81-0102

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name:

Location State: TX Country: US

View the Interpretation Document

Response text:

April 8, 1981
Mr. Ronald B. Miller
Williams Brothers Engineering Company
50 Briar Hollow Lane
Suite 300 W
Houston, Texas 77027

Dear Mr. Miller:
In response to your letter of March 19, 1981, I have enclosed a copy of Amendment 195-13, which
established §195.5, “Conversion to service subject to this part.”

In the first column on page 2 of the enclosure, the paragraph beginning with “Notice 77-3”
emphatically states that” a new pressure test is mandatory for all converted pipelines.” This
statement is accompanied by a reasoned explanation of why this requirement was adopted under 195.5.
therefore, conversion of the 1979 gas pipeline to interstate liquid service will require a new
pressure test in accordance with subpart E of Part 195.
Sincerely, SIGNED
Melvin A. Judah
Acting Associate Director for
Pipeline Safety Regulation
Pipeline Safety Regulation
Materials Transportation Bureau
Williams Brothers Engineering Company
50 Briar Hollow Lane
Suite 300 W
Houston, Texas 77027

March 19, 1981
Mr. B. Furrow
Office of Pipeline Safety Regulation
400 7th St. S.W. Washington, D.C. 20590

Dear Mr. Furrow:
Based on a phone conversation with you on 16 March, 1981, discussing the D.O.T. Title 49 Part
195.5, Williams Brothers
Engineering Company would appreciate an interpretation of this situation.

195.5 (a)(4) states, "The pipeline must be tested in accordance with the Subpart 'E'...". The
pipeline in question was installed and tested in 1979 and records are available for verification
according to Subpart 'E'. The pipeline is being converted from 192 to a HVL line. Will this 1979
pipeline have to be retested under Subpart 'E' even though it was orig- inally tested by 195 rules?

We would appreciate an interpretation of the D.O.T. regulation. If any questions arise, please
contact the undersigned.
Very truly yours,
WILLIAMS BROTHERS ENGINEERING COMPANY
Ronald B. Miller
Senior Project Engineer

Regulation Sections

Section Subject
195.5 Conversion to service subject to this part