{"operation":"document","citation":"PI-71-070","title":"Anderson, Greenwood & Co. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-07-29","effective_on":null,"summary":"PI-71-070 response to Anderson, Greenwood & Co. concerning 192.145.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-070.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-070.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-070","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/PI71070.pdf","body":"<<<PAGE 1>>>\n\nJuly 29, 1971\nMr. G. Frank Bright\nSales Manager\nSafety Relief Valves\nAnderson, Greenwood & Co.\nP. O. Box 400\nBellaire, Texas 77401\nDear Mr. Bright:\nThis is in reply to your letter of July 13, 1971, requesting an interpretation of paragraph\n192.505(d). You specifically questioned the use of sub-paragraph(d)(2), instead of Section\n192.145, for the strength testing of safety relief valves prior to operation.\nIt is intended that all valves including safety relief valves meet the applicable requirements of\nSection 192.145. Paragraph 192.145(a) requires, in part, that each valve meet the minimum\nrequirements of one of three specifications or the equivalent including API Standard 6D. Section\n5.1 of API Standard 6D states, \"All pressure tests required in this section (Section 5) shall be\nmade on all completed valves prior to shipment from the manufacturer's works.\" The words\n\"each valve\" and \"equivalent\" in paragraph 192.145(a) are used in the sense of providing quality\ncontrol and inspection for all valves that would at least be equivalent to that specified for the\nspecific valves mentioned in API 6D. For example, the listed specifications do not cover all sizes\nand types of valves, but a valve of a size or type not covered should at least meet the applicable\nsafety requirements in the listed specifications. Even though relief valves are not included by\nname in API Standard 6D, safety requirements \"equivalent\" to those elaborated in API Standard\n6D must be.\nIt is recognized that individual pieces of many types of components, such as pipe ells, tees, and\ncouplings are not individually strength tested at the time of manufacture. Paragraph 192.505(d)\ngives the operator an option when such a component is being replaced. This section is intended\nfor situations where a component cannot as a practical matter be given a post-construction test.\nThe operator, therefore, does not have to remove the segment of pipeline containing the replaced\nDB/dal/192.145\n71-07-29\n1\n\n<<<PAGE 2>>>\n\ncomponent and test the entire segment to prove the item has been pretested per sub-paragraph\n192.505(d)(1), or a prototype of the component was tested per sub-paragraph 192.505(d)(2).\nPlease contact me if I can be of any further assistance in this matter.\nSincerely,\n/signed/\nJoseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\nDB/dal/192.145\n71-07-29\n2\n\n<<<PAGE 3>>>\n\nAnderson, Greenwood & Company\nJuly 13, 1971\nOffice of Pipeline Safety\nRoom 315\n201 Fannin Street\nHouston, Texas 77002\nAttn: Mr. M. W. Taylor\nRe: Hydrostatic Testing of Safety Relief Valves\nfor use in Natural Gas Pipelines\nGentlemen:\nAnderson, Greenwood & Co. is a manufacturer of safety relief valves widely used as overpressure\nprotection in natural gas pipelines. For some weeks we have been conducting hydrostatic tests on\na prototype of each type, size and flange rating at test pressure of 150% of flange rating. We\nhave been running these tests for 8 hours, and of course keeping appropriate recorder chart\nrecords.\nWe have been proceeding on the assumption that a safety relief valve is a “ component other than\npipe” being added to the pipeline as described in 192.505 (d). We also plan to prepare a standard\ncertification that a prototype of all AGCO safety relief valves have been so tested, and are\nmanufactured under a quality control system to comply with 192.505(d)(2).\nRecently we have received a letter from Northern Natural Gas Co. (copy attached) expressing an\nopinion that a safety valve should be subjected to hydrostatic test per API-6D, and reference\n192.145. The position of our company is that API-6D is a test for valves other than safety relief\nvalves, and is by title not applicable to safety relief valves.\nWe ask that you give us a ruling on whether we are correct in our assumption that a safety relief\nvalve can be tested under 192.505(d). Thank you very much.\nYours very truly,\nANDERSON, GREENWOOD & CO.\nG. Frank Bright, Sales Manager\nSafety Relief Valves\nDB/dal/192.145\n71-07-29\n3\n\n<<<PAGE 4>>>\n\nNorthern\nNatural\nGas\nJuly 17, 1971\nMr. Frank Bright\nAnderson Greenwood Company [sic]\nBox 400\nBillaire [sic], Texas 77401\nDear Mr. Bright:\nMr. Buxton, Mr. Jack Baker and I had a conference on June 15 regarding testing of relief valves,\nMr. Baker’ s position as Director of Codes is that a relief valve should be tested to the same\nspecifications as a plug, gate or ball valve used in the same location. Briefly, this means that\nvalves 6” and smaller should have the same test as API-6D, 8” and larger shall be tested for 12\nhours shell and 3 hours seat (if applicable), with pressure-temperature test charts submitted. In\nthe case of ordinary valves the latter is referred to as a PL-203 test, and is an extra cost item.\nMr. Buxton’ s information was that you relied on DOT paragraph 192.505 D92) [sic], using the\nprototype approach. We are interested in knowing whether other companies will accept this. Mr.\nBaker does not approve of this approach, instead would refer to paragraph 192.145.\nPlease let us know your price schedule for a test that will match API 6D. I am enclosing a PL-\n203 specification form. Much does not apply, but Section IV through 4.82 does seem to fit relief\nvalves. Since this applies to 8” and up, please estimate such a testing cost.\nAn early reply will be appreciated.\nVery truly yours,\nP. W. Nelson\nDB/dal/192.145\n71-07-29\n4","truncated":false,"body_characters":5373}