{"operation":"document","citation":"PI-77-022","title":"Pipetech, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-09-21","effective_on":null,"summary":"PI-77-022 response to Pipetech, Inc. concerning 192.147.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-022.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-022.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-022","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/PI77022.pdf","body":"<<<PAGE 1>>>\n\nSeptember 21, 1977\nMr. Gunter Schlicht\nPipetech, Inc.\nOne Northwood Drive #5\nOrinda, California 94563\nDear Mr. Schlicht:\nYour letter of July 7, 1977, requests an interpretation of the applicable requirements of Parts 192\nand 195 relating to the design and testing of pipeline flanges. Your specific question is: are the\nrequirements of the ASME Boiler and Pressure Vessel Code, Section VIII, Division 1 (Boiler\nCode) considered as an equivalent as intended in Section 192.147 to the referenced specifications\nfor flanges in Part 192? Also, does the Boiler Code meet the requirements for flanges of Section\n195.126 in Part 195?\nThe Boiler Code, which is referenced in both Parts 192 and 195, and the ANSI B16.5 and MSS-\nSP-44 specifications that are referenced in Part 192 are intended for the conventional design\nflanges that would be manufactured by casting or forging rather than the convoluted design that\nwould be folded into shape.\nIn Appendix II, Paragraphs UA-45 thru UA-59, inclusive, of the Boiler Code, the procedure for\ndesigning flanges for manufacture by casting or forging is set forth. It is suggested in this\nAppendix that if the procedure set forth is not appropriate for the design, then in order to\nestablish allowable working pressures, the flange should be proof tested under the provisions of\nthe Boiler Code, Section UG-101, Proof Tests, to establish maximum allowable working\npressure. The testing required by UG-101, that is applicable to all pressure vessels, is more\nsevere and thorough than that required by any of the other referenced specifications for flanges.\nIt is our opinion that a detailed design and stress analysis supported by a proof test under the\nprovisions of UG-101 of the Boiler Code provides the equivalent level of safety intended by\nSection 192.147.\nSection 195.126 states, with respect to a flange connection, that the \"connection as a unit must be\nsuitable for the service in which it is to be used.\" It does not provide any standard or test method\nto be used to determine the suitability.\ndal/192.147\n77-09-21\n1\n\n<<<PAGE 2>>>\n\nIt is our opinion that the stress analysis and Boiler Code testing under the provision of UG-101\nwould be sufficient to determine whether flange connections are suitable under Section 195.126.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal/192.147\n77-09-21\n2\n\n<<<PAGE 3>>>\n\nJuly 7, 1977\nMr. Cesar DeLeon MTP-1\nActing Director\nOffice of Pipeline Safety Operations\nDepartment of Transportation\nWashington, D.C. 20590\nSubject: Interpretation of Code Title 49\nParts 192 and 195 Relative to\nConvoluted Pipe Flanges\nDear Mr. DeLeon:\nOn June 30, 1977, I met with Mr. Paul J. Cory relative to the acceptance of Syspac, Inc., Orinda,\nCa. and Nibco, Inc., Elkhart, Indiana, pipe flanges for the jurisdictional areas as defined in your\nRegulations for the Transportation of Natural and Other Gases and Liquids by Pipeline, Title 49,\nParts 192 and 195 respectively.\nSpecifically Part 192.147 of Title 49 - Flanges and Flange Accessories - states that flanges must\nmeet minimum requirements of ANSI B16.5 or the equivalent which we interpret to mean flange\ndesign per ASME Section VIII, Division 1 of the Pressure Vessel Code.\nOur pipe flanges meet the requirements of Section VIII (see attached documentation). In order to\nprovide flange users with a uniform statement and code clarification we request respectfully your\ninterpretation of Title 49, Parts 192 and 195 in view of Section VIII flange design criteria.\nWe trust that the enclosed material is all encompassing for your acceptance review. Your\nresponse at your earliest convenience will be appreciated. In essence, we are hopeful of receiving\nfrom your office a statement that clearly delineates that our convoluted flanges are acceptable in\nlieu of ANSI B16.5 flanges as long as Section VIII criteria is being met.\nAwaiting your response we remain,\nYours truly,\nPIPETECH, INC.\nGunter Schlicht\ndal/192.147\n77-09-21\n3","truncated":false,"body_characters":3990}