# Tennessee Public Service Commission — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-76-006
- **title:** Tennessee Public Service Commission — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1976-01-28
- **effective on:** Not available
- **summary:** PI-76-006 response to Tennessee Public Service Commission concerning 192.227.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-006
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76006.pdf
**body:**

<<<PAGE 1>>>

Jan 28 1976
Mr. John Searcy
Engineering Division
Tennessee Public Service Commission
Cordell Hull Building
Nashville, Tennessee 37219
Dear Mr. Searcy:
The following responds to the questions in your letter of January 2, 1976:
Question 1: Is it a correct interpretation that a welder qualified initially under 192.227(a) in
accordance with the 1968 ASME Boiler and Pressure Vessel Code, Section IX is, in effect,
required by 192.229(c) to re-qualify after 6 months in accordance with API 1104 only, not
Section IX?
Answer: A welder qualified under Section IX of the 1968 edition of the ASME Boiler and
Pressure Vessel Code in accordance with §192.227(a) may not weld unless, within the preceding
six calendar months, that welder has had at least one weld tested and found acceptable under
Section 3 or 6 of API Standard 1104, as required by §192.229(c). Section 192.229(c) does not
require that the welder requalify under API 1104.
Question 2: If the interpretation in Question 1 is correct, can a welder, after 6 months, initially
qualify again in accordance with Section IX?
Answer: Although your interpretation in Question 1 is incorrect, if a welder requalifies under
Section IX within six months, §192.229(c) would not apply.
Question 3: Is a welder qualified in accordance with 192.227(a) automatically qualified for a year
in accordance with 192.227(c) for pipe operating at less than 20% SMYS?
Answer: As prescribed by §192.229(c), a welder who qualifies under §192.227(a) to weld pipe to
be operated at any stress level allowed in the regulations may not weld that pipe, including pipe to
be operated at less than 20% of SMYS, for more than six months following his qualification
unless he has had at least one weld tested and found acceptable under Section 3 or 6 of API
Standard 1104.
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<<<PAGE 2>>>

Question 4: Is it a correct interpretation that 192.125(c) is limiting to 100 psi only the ASTM B
88 type "L" copper referred to in 192.125(b), and that copper with a greater wall thickness is not
restricted to 100 psi?
Answer: 100 psig.
No, §192.125(c) prohibits the use of copper pipe of any thickness in operation above
Sincerely,
Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations
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<<<PAGE 3>>>

TENNESSEE PUBLIC SERVICE COMMISSION
January 2, 1976
Mr. Cesar DeLeon
DEPARTMENT OF TRANSPORTATION
Office of Pipeline Safety
2100 2nd Street, SW
Washington, D.C. 20590
Dear Mr. DeLeon:
1. Is it a correct interpretation that a welder qualified initially under 192.227(a) in
accordance with the 1968 ASME Boiler and Pressure Vessel Code, Section IX is, in
effect, required by 192.229(c) to re-qualify after 6 months in accordance with API 1104
only, not Section IX?
2. If the interpretation in Question 1 is correct, can a welder, after 6 months, initially qualify
again in accordance with Section IX?
3. Is a welder qualified in accordance with 192.227(a) automatically qualified for a year in
accordance with 192.227(c) for pipe operating at less than 20% SMYS?
4. Is it a correct interpretation that 192.125(c) is limiting to 100 psi only the ASTM B 88
type "L" copper referred to in 192.125(b), and that copper with a greater wall thickness is
not restricted to 100 psi?
Sincerely,
John Searcy, Engineer
Engineering Division
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