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Interpretation Response #PI-94-024 ([Railroad Commission of Texas] [Mary L. McDaniel, P.E.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Railroad Commission of Texas

Individual Name: Mary L. McDaniel, P.E.

Location State: TX Country: US

View the Interpretation Document

Response text:

Ms. Mary L. McDaniel, P.E.

Manager, Pipeline Safety

Railroad Commission of Texas

P.O. Box 12967

Austin, TX 78711-2967

Dear Ms. McDaniel:

Your letter of October 4, 1993, requests our assistance in responding to two questions. Accordingly, we are providing the following information:

Question #1 What insight can RSPA provide on "small entities" as the term is used in the paragraph titled "Regulatory Flexibility Act" in the Notice of Proposed Rulemaking-Drug and Alcohol Testing Programs-published December 15, 1992, (57 FR 59714)?

Answer #1 The term "small entity" is defined in 601 of the Regulatory Flexibility Act (5 U.S.C. § 601). The term "small business", a subset of "small entity" is defined in 15 U.S.C. 632. In addition to these provisions, regulations at 13 C.F.R. § 121.601 provided detailed standards to assist in determining whether a business is a "small business." With respect to the pipeline industry, size standards are discussed in 13 C.F.R. § 121.601, Division E, Major Groups 46 and 49, which were recently amended (see 59 FR 16529; April 7, 1994). I have enclosed copies of the relevant statutory provisions and regulations.

Question #2 "Our second question relates to the hydrostatic testing of replacement pipe under § 192.719(a). In a repair situation where several joints of pipe are welded together, does the welded piece have to be hydrostatically tested as a unit? Each joint is pre-tested and the welds are 100% non-destructively tested."

Answer #2 Section 192.719(a) is intended for testing of repairs of transmission pipelines, where the pipe is required to be tested as a new line. The test requirements in Subpart J are applicable to a new segment of pipeline, or the return to service of a segment of pipeline that has been relocated or replaced.

In accordance with § 192.503(a) in Subpart J, the entire replaced segment must be tested in accordance with Subpart J and § 192.619, except the tie-in joints that are excepted under § 192.503(d). It should be noted that the joints connecting the several pipe lengths are not tie-in joints. However, if, in accordance with § 192.505(e), it is not practical to conduct a post installation test, a preinstallation strength test must be conducted on each pipe length or the segment by maintaining the pressure at or above the test pressure for at least 4 hours.

I am sorry for the delay in replying to you. Please let me know if you need further information on either of the above questions.


Cesar De Leon

Director, Regulatory Programs

Office of Pipeline Safety



Regulation Sections

Section Subject
192.503 General requirements