The Pipe Line Development Company — Pipeline Safety Interpretation

Page 1PI-73-0102 2-9-73 Mr. Edward B. Smith President, The Pipe Line Development Company 1831 Columbus Road Cleveland, Ohio 44113 Dear Mr. Smith, This is in response to your letter of January 25, 1973, asking whether bolted split sleeves rather than welded split sleeves may be used in certain repairs on transmission lines in view of the requirements stated in sections 192.717 and 192.153(b)(4). Although your letter states that section 192.717 requires a welded split sleeve, a recent amendment to that section (Amendment 192-12 issued October 11, 1972) now provides an exception. Thus, if the repair is to be made on a transmission line joined by mechanical couplings and operated at less than 40 percent of SMYS, use of a bolted split sleeve would be acceptable under the amended requirement. Your letter asks whether your bolted split sleeves might be used for repair under the provision of section 192.153(b) (4), since you test them to twice working pressure. The requirements of section 192.153(b) (4), however are applicable to the design of pipeline components whereas section 193.717 applies to the permanent field repair of leaks on transmission lines. Thus section 192.153(b)(4) does not provide an exception from the repair requirements of section 192.717. If you have further questions in this matter please call on us. Sincerely, Joseph C. Caldwell Director Office Of Pipeline Safety#

Page 2The Pipe Line Development Co. 1831 Columbus Road Cleveland, Ohio 44113 January 25, 1973 Department of Transportation Director, Office of Pipeline Safety Washington, D.C. 20590 Gentlemen: Several of our customers who use our PLIDCO Split Sleeves for repairs on their underwater gas pipelines have been concerned with the requirements of the Minimum Safety Standards for Gas Pipelines. Section 192.717 requires that a repair for other than a corrosion pit must be made by a full encirclement welded split sleeve. I have enclosed a bulletin on our PLIDCO Split Sleeve; it shows that our sleeve can form a seal and be left unwelded. Welding underwater has proved to be very poor if done "wet" or extremely expensive if done in a chamber. Therefore I wonder if our customers might use bolted split sleeves for leaks other than corrosion pits under the provision in Section 192.153 (b)(4) which permits the use of components fabricated by welding if the manufacturer certifies that they have been tested to twice working pressure. We test 100% of our sleeves to twice working pressure. Sincerely yours, Edward R. Smith President#