{"operation":"document","citation":"PI-74-0155","title":"Brown & Root, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-12-19","effective_on":null,"summary":"PI-74-0155 response to Brown & Root, Inc. concerning 195.208.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0155.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0155.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0155","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-12-19_BROUSSARD_195.208-DBX.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0155\nDecember 19, 1974\nMr. L.D. Broussard\nBrown & Root, Inc.\nPost Office Box Three\nHouston, TX 77001\nDear Mr. Broussard:\nThis is further to our acknowledgement of your letter of August 22, 1974, and Mr. Thomas L. Cairns' letter of November\n8, 1974, addressed to Mr. Frank Fulton. In both letters, Brown and Root has requested an interpretation of Section\n195.208.\nSection 195.208 states, \"Supports or braces may not be welded directly to pipe that will be operated at a pressure of\nmore than 100 psig.\"\nAttachments such as anchors, supports, braces, etc., may not be welded directly to carrier pipe. However, attachments\nmay be welded or bolted to a separate cylindrical member which completely encircles the pipe with the encircling\nmember welded to the pipe by continuous circumferential welds.\nSection 195.208 is more restrictive than USAS B31.4-1974, 421(d), in that Section 195.208 requires compliance to this\nsection at an operation pressure of more than 100 psig where B31.4 does not state a pressure.\nYour proposed design for Union Carbide Corporation would be in compliance with Section 195.208 as long as your pipe\nshoes completely encircles the pipe with the encircling member welded to the pipe by continuous circumferential\nwelds.\nIf we can be of any further assistance in this matter, please advise.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nNovember 8 1974\nMr. Frank Fulton, Chief of Technical Division\nOffice of Pipeline Safety TES-32\n400 7th St. Southwest\nWashington, D.C. 20590\nDear Mr. Fulton:\nTitle 49 - Transportation, 195.110 External loads states that expansion and flexibility must be provided for according to\nUSAS B31.4 and the pipe must be supported to avoid excess localized stresses. Furthermore, USAS B31.4 - 1974, 421\nDesign of Pipe Supporting Elements states that excessive local stresses should be avoided, nonintegral attachments\nsuch as pipe clamps and ring girders are preferred when they will fulfill the supporting and anchoring functions. It also\nstates that when pipe is operating close to its allowable stress all connections welded to the pipe shall be made to a\nseparate cylindrical member which completely encircles the pipe and this encircling member shall be welded to the pipe\nby continuous circumferential welds.\nHowever, Title 49, 195.208 Welding of Supports and braces, states they may not be welded directly to pipe that will be\noperated at a pressure of more than 100 psig. Does this mean that in such cases connections can be welded to a\nseparate cylindrical member which completely encircles the pipe with the encircling member welded to the pipe by\ncontinuous circumferential welds or is 195.208 more restrictive? And does 195.208 include anchors or just supports\nand braces?\nAny assistance you could provide would be helpful.\nVery truly your,\nBROWN & ROOT, INC.\nThomas L. Cairns\nStaff Specialist\n\n<<<PAGE 3>>>\n\nMr. L.D. Broussard\nBrown & Root, Inc.\nPost Office Box Three\nHouston, TX 77001\nDear Mr. Broussard:\nThis is to acknowledge your letter of August 22, 1974, in which you give details of a piping system you are designing for\nthe Union Carbide Corporation in Brownsville, Texas, and ask if your design is in compliance with Title 49, §195.28.\nThis matter is now under review by our office. You may expect a reply in the near future.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 4>>>\n\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\nTES-30\nWashington, D.C. 20590\nDear Sir:\nAs part of a project for Union Carbide Corporation in Brownsville, Texas, Brown & Root, Inc. is designing a piping system\nto transport no.6 fuel oil from a dock at the Port of Brownsville to the plant. Part of the line is above ground, steam\ntraced and insulated. We propose to weld pipe shoes to the pipe and rest the shoes on support plates. At anchor\npoints the shoes will be bolted, not welded, to the support plate. Is this design in compliance with Title 49, Paragraph\n195.28 Welding of Supports and Braces?\nYour prompt attention to this matter is appreciated.\nVery truly yours,\nBROWN & ROOT, INC.\nL.D. Broussard","truncated":false,"body_characters":4196}