Are there alternative methods to Part 195 Subpart E pressure testing requirements for a hazardous liquid pipeline?
One operator asked and received an answer.
December 20, 2012
Ms. Michelle Denault
Regulatory Compliance Manager
Interstate Storage and Pipe Line Corporation
400 Amherst Street, Suite 405
Nashua, NH 03063
Dear Ms. Denault:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated August 1, 2012, the Interstate Storage and Pipe Line Corporation (ISPC) requested an interpretation of the applicability of the Federal pipeline safety regulations at 49 CFR Part 195 Subpart E. Specifically, ISPC requested a determination on whether a certain alternative test method can be utilized to satisfy the Part 195 pressure testing requirements for a buried pipeline.
Under Part 195 requirements, a pipeline that is not visually inspected for leakage during a pressure test must undergo an eight hour pressure test. ISPC proposed an alternative approach developed by Hansa Consult of North America involving a 45-minute test followed by a stress test that places the pipeline at 125 percent of maximum operating pressure for a two-to-four hour period. ISPC stated that the proposed technique would determine tightness or lack of leaks in the pipeline to an accuracy of 0.002 percent of line test segment volume and would minimize stresses on the pipeline and thus the growth of defects.
The alternative approach to pressure testing you have described does not meet the requirements of 49 CFR Part 195, Subpart E for pressure testing pipeline. Should you elect to do so, you may apply for a special permit that, if granted, would waive or modify the existing requirement under controlled conditions. The special permit application process is outlined in 49 CFR 190.341(b) – How do I apply for a special permit?
I hope that this information is helpful to you. If I can be of further assistance, please contact me at 202-366-4046.
John A. Gale
Director of Standards and Rulemaking
Office of Pipeline Safety
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