Interpretation Response #PI-82-010 ([Williams Pipe Line Company] [R. G. Keearns])

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

Interpretation Response Details

Response Publish Date: 06/04/1982

Company Name: Williams Pipe Line Company

Individual Name: R. G. Keearns

Location State: OK Country: US

View the Interpretation Document

Response text:

Mr. R. G. Keearns

Manager of Environmental Affairs

and Pipeline Safety

Williams Pipe Line Company

P.O. Box 3448 Tulsa, OK 74101

Dear Mr. Keearns:

This is in response to your letter dated December 2, 1981, concerning the application of §195.304(b) to two factual situations.

The enclosed pipeline safety regulatory interpretation explains §195.304(b) and gives its application to the two factual situations presented in your letter.

We hope this meets your needs.

Sincerely,

/signed

Melvin A Judah

Acting Associate Director

for Pipeline Safety Regulation

Materials Transportation Bureau

Enclosure

DEPARTMENT OF TRANSPORTATION

RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION

MATERIALS TRANSPORTATION BUREAU

PIPELINE SAFETY REGULATORY INTERPRETATION

Note: A pipeline safety regulatory interpretation applies a particular rule to a particular set of facts and circumstances, and, as such, may be relied upon only by those persons to whom the interpretation is specifically addressed.

SECTION: 195.304(b)

SUBJECT: Testing Components

FACTS: The following facts are given in a letter dated December 2, 1981, from R. G. Keearns, Williams Pipe Line Company, to the Office of Pipeline Safety Regulation

Case I

An existing pipeline was cut to install a new pump. A new check valve was installed in the existing line together with new suction and discharge piping, tees, ells, valves, and interconnected pump. The pipe was pretested. The pump was tested by the manufacturer at the factory. All other items were manufactured to the same standard as a tested prototype. The tie-in welds were radiographed.

Question: Does this pump station installation qualify as the "only item being . . . added" under §195.304(b) and, therefore, excepted from the hydrostatic test requirement of §195.302(a)?

Case II

In a header, four flanged end valves were replaced with identical new valves which were manufactured to the same standard as a tested prototype. Because only valves were replaced, do they qualify as the "only item being replaced" under §195.304(b) and are, therefore, excepted from the test requirement of §195.302(a)?

Interpretation: Section 195.304(b) was adopted on November 2, 1970, as Amendment 195-2, Docket No. HM-6. The preamble to that amendment makes clear that §195.304(b) applies only to single item replacements or additions. In Case I, more than a single item has been added, and in Case II more than a single item has been replaced. Therefore, in both cases, §195.304(b) does not apply and hydrostatic testing is required under §195.302(a).

Melvin A. Judah

Acting Associate Director

for Pipeline Safety Regulation

Materials Transportation Bureau

Regulation Sections