{"operation":"document","citation":"PI-71-079","title":"Anderson, Greenwood & Co. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1971-09-29","effective_on":null,"summary":"PI-71-079 response to Anderson, Greenwood & Co. concerning 192.505.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-079.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-079.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-71-079","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1971/PI71079.pdf","body":"<<<PAGE 1>>>\n\nMr. G. Frank Bright\nSales Manager\nSafety Relief Values\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 192.505(d). You\nspecifically questioned the use of sub-paragraph(d)(2), instead of Section 192.145, for the strength testing\nof safety relief valves prior to operation.\nIt is intended that all valves including safety relief valves meet the applicable requirements of Section\n192.145. Paragraph 192.145(a) requires, in part, that each valve meet the minimum requirements of one of\nthree specifications or the equivalent including API Standard 6D. Section 5.1 of API Standard 6D states,\n\"All pressure tests required in this section (Section 5) shall be made on all completed valves prior to\nshipment from the manufacturer's works.\" The words \"each valve\" and \"equivalent\" in paragraph\n192.145(a) are used in the sense of providing quality control and inspection for all valves that would at\nleast be equivalent to that specified for the specific valves mentioned in API 6D. For example, the listed\nspecifications do not cover all sizes and types of valves, but a valve of a size or type not covered should at\nleast meet the applicable safety requirements in the listed specifications. Even though relief valves are not\nincluded by name in API Standard 6D, safety requirements \"equivalent\" to those elaborated in API\nStandard 6D must be.\nIt is recognized that individual pieces of many types of components, such as pipe ells, tees, and couplings\nare not individually strength tested at the time of manufacture. Paragraph 192.505(d) gives the operator an\noption when such a component is being replaced. This section is intended for situations where a component\ncannot as a practical matter be given a post-construction test. The operator, therefore, does not have to\nremove the segment of pipeline containing the replaced component and test the entire segment to prove the\nitem has been pretested per sub-paragraph 192.505(d)(1), or a prototype of the component was tested per\nsub-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\nC:\\WP51\\INTERPRT\\192\\145\\71-07-29.N\n1","truncated":false,"body_characters":2335}