{"operation":"document","citation":"PI-76-024","title":"D. Russell Associates, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-05-20","effective_on":null,"summary":"PI-76-024 response to D. Russell Associates, Inc. concerning 195.208.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-024.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-024.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-024","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76024.pdf","body":"<<<PAGE 1>>>\n\nMr. Douglas Russell, P.E.\nD. Russell Associates, Inc.\n553 Mission Street\nSan Francisco, CA 94105\nDear Mr. Russell:\nYour letter of April 9,1976, to the attention of Mr. Jack Overly in\nthe Western Regional Office of the Office of Pipeline Safety\nOperations (OPSO) has been referred to headquarters for a reply.\nYour letter concerned Section 195.208, Welding of supports and\nbraces (49 CFR Part 195, Transportation of Liquids by Pipeline),\nand Section 421.1 Supports, Braces, and Anchors, in ANSI B31.4\n(Liquid Petroleum Transportation Piping Systems).\nThe regulations in Part 195 are for the most part performance\nstandards. Where a specific method is neither required nor\nexcluded, the operator has the responsibility of selecting a method\nof compliance that will conform with the appropriate standard.\nIf you comply with the requirements of Section 421.1 in ANSI B31.4-\n1974, the requirements of Section 195.208 in Part 195 will have\nbeen met.\nDo not hesitate to call or write, if OPSO can be of any further\nassistance.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\nDB\nC:\\WP51\\INTERPRT\\195\\208\\76-05-20\n1\n\n<<<PAGE 2>>>\n\nTO: Chief, Operations Division MTP-50\nFROM:Chief, Western Regional Office\nSUBJECT: Question by D. Russell, Associates\nCopy of letter by D. Russell Associates, Inc. is enclosed for\nheadquarters action and answer.\nThe references to ANSI B31.4 cannot be checked as this office\ndoes not have a copy.\nJack. C. Overly\nAttachment\nDB\nC:\\WP51\\INTERPRT\\195\\208\\76-05-20\n2\n\n<<<PAGE 3>>>\n\nDepartment of Transportation\nOffice of Pipeline Safety\n831 Mitten Road\nBurlingame, California 94010\nAttention:Mr. Jack Overly\nSubject: Welding to Pipelines Operated in Excess 100 PSIG\nGentlemen:\nWe are designing a pipeline system in accordance with Title 49,\nChapter I, Subchapter B, Part 195 - \"Transportation of Liquids by\nPipeline\". A section of the pipeline will be built on a trestle\nand aboveground. In this portion of the pipeline, it will be\nnecessary to support as well as anchor for thermal expansion. We\nare in a quandary as to the acceptable methods to engage both the\nsupports and the anchor to the pipeline.\nThe referenced regulation to which we are designing (Part 195)\n\"Transportation of Liquids by Pipeline\", Paragraph 195.208,\n\"Welding of Supports and Braces\", states, \"Supports or braces may\nnot be welded directly to pipe that will be operated at a pressure\nof more than 100 PSIG.\"\nANSI Code B31.4 requires under such circumstances that a band of\nsteel encircle the pipeline, be welded to the pipeline and that all\nbraces and anchors be welded in turn to the band.\nIt would seem to us that the practice set forth in B31.4 would meet\nthe requirements of D.O.T. Regulation 195.208 as the brace or\nsupport would not \"directly\" engage the pipeline.\nWill you please advise us if following B31.4 for this purpose would\nbe acceptable to the Department of Transportation, Office of\nPipeline Safety? If such practice would not meet the acceptance of\nyour office, would you please advise us what procedure would? We\nwould like to point out that welding is preferred to bolting to\npipe supports and the pipe anchor in this section of the pipeline\nunder study.\nThank you for your help in this matter. We sincerely appreciate\nit.\nYour truly,\nD. RUSSELL ASSOCIATES, INC.\nDouglas Russell, P.E.\nDB\nC:\\WP51\\INTERPRT\\195\\208\\76-05-20\n3\n\n<<<PAGE 4>>>\n\nDB\nC: WP511INTERPRT11951208176-05-20","truncated":false,"body_characters":3431}