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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-81-0115

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: NY Country: US

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Response text:

PI-81-0115

October 2, 1981

Mr. Thomas D. McMenamin
American Society of Mechanical Engineers
United Engineering Center
145 E. 47th Street
New York, NY  10017

Dear Mr. McMenamin:

Your letter of June 25, 1981, requests that we amend §192.719(a)(2) to refer to §192.241 rather than 192.243 so that the exceptions from the requirement for nondestructive testing of new girth welds will apply to nondestructive testing of tie-in welds made when a damaged segment of a transmission line is cut out and replaced.

The request is supported by several arguments in favor of the suggested rule change, one of which challenges the basis for an "Advisory Bulletin No. 75-11."  We have reexamined the basis for this interpretation and found the interpretation invalid.  As a result, a new interpretation of §§192.719(a)(2) and 192.241(b), which supersedes the earlier one, is enclosed.

This new interpretation declares that the exceptions under §192.241(b) were intended to apply to tie-in welds made in repairing damaged pipe sections.  Because of the significance of this action, the interpretation will be published in the Advisory Bulletin.  We also believe that changing the rule as you suggest would clarify this issue and eliminate the need for an interpretation.  Therefore, we will schedule a rulemaking action to so amend §192.719(a)(2).

We appreciate your concern for correct application of the Federal pipeline safety standards.

Sincerely,

Melvin A. Judah
Acting Associate Director for
Pipeline Safety Regulation
Materials Transportation Bureau

Regulation Sections

Section Subject
192.243 Nondestructive testing