{"operation":"document","citation":"PI-15-0012","title":"GE Oil and Gas — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-07-18","effective_on":null,"summary":"PI-15-0012 response to GE Oil and Gas concerning 192.63.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0012.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0012.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-15-0012","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/Pipeline/2016/GE%20Oil%20and%20Gas-PI-15-0012-07-18-2016-Part%20192.63.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\nJUL18 2016\n1200 New Jersey Avenue SE\nWashington DC 20590\nMr. Lee Strobel\nSenior Engineer/Technologist\nGE Oil & Gas\n50 Thomas Patten Drive\nRandolph, MA 02368\nDear Mr. Strobel:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nOctober 15, 2015, you requested an interpretation of 49 CFR 192.63. You asked ifthe\nrequirements of§ 192.63 apply to your instrumentation components of a control valve assembly.\nYou stated that the actuator and instrumentation system are custom designed to operate with the\npipeline control valve and the whole system is shipped and installed as a complete assembly.\nYou asked whether the control valve system complies with the requirements of§ 192.63 if this\nwhole system is marked at the assembly level.\nYou referenced prior interpretations you believe state that it is acceptable for components to be\nbundle-marked, not individually marked, as long as they are grouped in a bundle, one which\nstays together up to the point of installation.\nBased on these interpretations, you indicated your understanding was that as long as suitable\nmarkings are visible on the complete assembly, to the point of installation, it would not be\nnecessary for markings to be maintained on the assembly or its individual subcomponents after\nthe system has been installed. You further asked that should your understanding be incorrect,\nPHMSA clarify the definition of the term component in§ 192.63, and whether this section\nrequires each fitting, bolt and length of tube in instrumentation assembly to be marked\nindividually. Also, you asked if the requirements apply to sub-components of assemblies such as\nvalve body and seats or 0-rings.\nThe purpose of§ 192.63 is to require a pipeline operator, operating pipeline regulated by\n49 CFR Part 192 to provide positive identification of the equipment or component of the pipe,\nand thus, assure that it is not subjected to operating conditions exceeding those for which it was\ndesigned. Each valve, fitting, pipe, or other component used in a pipeline to which§ 192.63\napplies must meet the marking requirements. Section 192.63 states:\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\n§ 192.63 Marking of materials.\n(a) Except as provided in paragraph (d) of this section, each valve, fitting, length of pipe,\nand other component must be marked-(1) As prescribed in the specification or standard\nto which it was manufactured, except that thermoplastic pipe and fittings made of plastic\nmaterials other than polyethylene must be marked in accordance with ASTM D2513-87\n(incorporated by reference, see§ 192.7); (2) To indicate size, material, manufacturer,\npressure rating, and temperature rating, and as appropriate, type, grade, and model.\n(b) Surfaces of pipe and components that are subject to stress from internal pressure may\nnot be field die stamped.\n( c) If any item is marked by die stamping, the die must have blunt or rounded edges that\nwill minimize stress concentrations.\n(d) Paragraph (a) of this section does not apply to items manufactured before November\n12, 1970, that meet all of the following: (1) The item is identifiable as to type,\nmanufacturer, and model. (2) Specifications or standards giving pressure, temperature,\nand other appropriate criteria for the use of items are readily available.\nThe GE Oil & Gas control valve system in question includes components such as an\ninstrumentation system, valves, and actuators. The question is whether GE Oil & Gas can meet\n§ 192.63 requirements by marking its whole control valve system with a single tag and not\nindividually mark the components within this system. Section l 92.63(a) clearly states that each\ncomponent, including but not limited to, valves, fittings, and length of pipe must be marked as\nprescribed in the specification or standard to which it was manufactured, and to indicate size,\nmaterial, manufacturer, pressure rating, and temperature rating, and as appropriate, type, grade,\nand model.1 Based on§ 192.63(a) requirements, GE Oil & Gas must comply with the standard\nto which it manufactures its control valve system and mark the components of this system, such\nas the instrumentation system and valves, including pressure containing components of valves\nand actuators, individually.\nPHMSA notes the prior interpretations you referenced. In these interpretations, PHMSA has\napproved of bundle-marking. PHMSA continues to approve bundling marking as opposed to\nindividually marking the components of the bundles - provided this bundle remains packaged\ntogether up to the point of installation. These interpretations are dissimilar and do not apply to\nyour request, as you will not be bundling individual components. Instead you indicated that the\ninstrumentation system, valves, and actuators are assembled into a working assembly, and then\nshipped as a complete assembly to its point of installation.\n1 Except that thermoplastic pipe and fittings made of plastic materials other than polyethylene must be marked in\naccordance with ASTM D2513-87\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\nYou asked PHMSA to clarify the definition of the term component in§ 192.63. Component is\nnot defined in Part 192, but it is used throughout the Part. Also, both Parts 193 and 195 define\ncomponent. Therefore based on the use and the definitions in the other parts, a component can\nbe interpreted as any part or system of parts of a pipeline as defined in § 192.3.\nlfwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nGE Oil & Gas\nMr. Lee Strobel\nSenior Engineer/Technologist\nGE Oil & Gas\nFlow & Process Technologies\n50 Thomas Patten Drive\nRandolph, MA 02368\nTel: (508) 562 5022\nE-mail: lee.strobel@ge.com\nOffice of Pipeline Safety (PHP-30)\nPHMSA, US Department of Transportation\n1200 New Jersey Avenue SE\nWashington, DC 20590-0001\n15 October, 2015\nDear Sir/Madam,\nI am writing to request a formal interpretation of your 49 CFR 192 regulation, relating to\ntransportation of natural and other gas by pipeline, as it relates to the instrumentation components of\na control valve assembly. Our fundamental question being: Are instrumentation components of control\nvalve assemblies within scope of section 192.63 (Marking of Materials)? If so, are these components\neach required to be individually marked with the information referenced in that section?\nIn our business, we design and manufacture control valve assemblies that are used in natural\ngas transmission and distribution pipelines, covering a range of pipe sizes from 2” to 30”+ and pipeline\npressures that can exceed 1000 psi. Our control valves are typically powered by a pneumatic actuator,\nwhich is controlled by an instrumentation system attached to the valve assembly. The pneumatic\nactuator is powered by the pipeline gas and the instrumentation system would typically include several\ncomponents, such as smaller regulators and valves, which measure the pressure of the pipeline gas\nand regulate the flow of gas to the actuator (a description of a typical GE Becker control valve system is\nincluded in an addendum following this letter). The actuator and instrumentation system are custom-\ndesigned to operate with the pipeline control valve and the whole system is shipped and installed as a\ncomplete assembly. Therefore, our position has been that a marking at the assembly-level should be\nsufficient to cover the whole control valve system. We are asking for clarification of whether this meets\nthe requirements of 49 CFR 192.\nWe would like to make reference to some interpretations that have previously been published\nby PHMSA, which may be relevant in this situation:\nSeveral prior interpretations (e.g. PI#-71-0118 (1971) and PI#-74-018 (1974)) indicate that it is\nacceptable for lengths of pipe to be ‘bundle-marked’, as long as the bundle stays together up to the\npoint of installation. Interpretation PI#-95-049 (1995) indicates that this ‘bundle-marking’ would also\napply to valves and so, presumably, other components. So, if this logic is extended to our control\nvalves, it would seem to follow that it would be acceptable for us to have one marking applied to the\noverall control valve assembly, rather than each individual subcomponent having to be marked\nindividually, as long as the control valve system is shipped and installed as a complete assembly.\nInterpretation #PI-74-021 (1974) also states that ‘… The intent of the regulation is that the\nproduct, pipe, fitting, etc., be clearly identified from point of manufacture to installation.’ It also states\nthat ‘Section 192.63 does not require that markings be maintained after installation …’. So, this would\nseem to suggest that, as long as suitable markings are visible on the complete assembly, up to the\nDresser, Inc.\n\n<<<PAGE 5>>>\n\npoint of installation, then it would not be necessary for such markings to be maintained, either on the\nassembly or individual subcomponents, after the system has been installed.\nWe would be most grateful for any guidance you can provide as to whether our reasoning\nabove is consistent with the intent of the 49 CFR 192 regulation. If you believe our reasoning to be\nincorrect, then could you please clarify the definition of the term ‘component’ in section 192.63 and the\nscope of the marking requirement? For example, would each fitting, bolt and length of tube in an\ninstrumentation assembly (such as that depicted in Figure 1 in the addendum) need to be marked\nindividually? What about sub-components of assemblies, such as the valve body, seats or o-rings?\nPlease do not hesitate to contact me if you would like to discuss further.\nYours sincerely,\nLee Strobel\n\n<<<PAGE 6>>>\n\nADDENDUM:\nThe intent of this addendum is to provide a more detailed description of the control valve assemblies\nthat are manufactured by GE Oil & Gas, Becker Control Valves.\nFigure 1 below shows a diagram of a typical GE Becker control valve system:\nInstrumentation\nSystem\nValve\nActuator\nFigure 1 – GE Becker control valve\nsystem\nThe main valve connects directly into the gas pipeline and is controlled by the pneumatic actuator and\ninstrumentation system. Figure 2 shows a typical GE Becker control valve installation:\nFigure 2 – typical GE\nBecker installation.\n\n<<<PAGE 7>>>\n\nFigures 3 and 4 below show the stainless steel tags that are typically attached to the control valve\nassembly, which include the information specified in section 192.63. As mentioned in the letter, the\nmarking is currently being applied at the assembly level, given that the control valve, actuator and\ninstrumentation system are shipped together as a complete functional assembly.\nFigure 3 – GE Becker control valve tag\nFigure 4 – GE Becker system ID tag.","truncated":false,"body_characters":12303}