{"operation":"document","citation":"PI-78-009","title":"Mr. Jack Baker — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1978-04-04","effective_on":null,"summary":"PI-78-009 concerning 195.228.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-009.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-009.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-009","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/PI78009.pdf","body":"<<<PAGE 1>>>\n\nApril 4, 1978\nMr. Jack Baker\nConsulting Engineer\nP.O. Box 34179\nOmaha, NB [sic] 68134\nDear Mr. Baker:\nThis refers to your letter dated March 11, 1978, in which you\nask, \"Does the Office of Pipeline Safety Operation believe that\ncrater cracks or star cracks 5/32 inch long or less are\nsignificant discontinuities in the assessment of a weld in a\npipeline being constructed in accordance with Part 192?\"\nUnder Section 192.241(c), \"The acceptability of a weld that is\nnondestructively tested or visually inspected is determined\naccording to the standards in Section 6 of the 1973 edition of\nAPI Standard 1104.\" Section 6.7 of API 1104 states, \"Shallow\ncrater cracks or star cracks which are located at the stopping\npoint of weld beads and which are the result of weld metal\ncontraction during solidification are not considered injurious\ndefects unless their length exceeds 5/32 inch. With exception of\nthese shallow crater cracks, no weld containing cracks,\nregardless of size or location, shall be acceptable.\" The Office\nof Pipeline Safety Operations interpreted the requirement to mean\nthat shallow crater cracks or star cracks 5/32 inch or less are\nnot significant in the assessment of a weld.\nWe trust that we have satisfactorily responded to your inquiry.\nSincerely,\n\\signed\\\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\195\\228\\78-04-04\n1\n\n<<<PAGE 2>>>\n\nMarch 11, 1978\nMr. Cesar DeLeon\nActing Director\nOffice of Pipeline Safety Operations\nMATERIALS TRANSPORTATION BUREAU\nTrans Point Building\n2100 Second Avenue, SW\nWashington, D.C. 20590\nDear Mr. DeLeon:\nYour letter of February 10, 1978 to Mr. Robert R. Young,\nCleveland, Ohio has come to my attention. As I understand it,\nthe thrust of this message is that OPSO does not regard crater\ncracks or star cracks having a length of 5/32 inch or less as\ninjurious discontinuities in the case of liquid pipelines subject\nto the provisions of Part 195. This is based on your statement:\n\"The Office of Pipeline Safety Operations interpreted the\nrequirements to mean that shallow crater cracks or star cracks\n5/32 inch or less are not significant in the assessment of a\nweld.\"\nThe foregoing statement solves a practical, everyday problem in\nthe case of pipelines constructed in accordance with Part 195,\nbut it appears to beg the question in the case of gas pipelines,\nwhich are subject to Part 192 requirements. Therefore, I wish to\nask you this question: Does the Office of Pipeline Safety\nOperations believe that crater cracks or star cracks 5/32 inch\nlong or less are significant discontinuities in the assessment of\na weld in a pipeline being constructed in accordance with Part\n192?\nYour answer to this question will be appreciated.\nSincerely,\n\\signed\\\nJack Baker\ndal\\195\\228\\78-04-04 2\n\n<<<PAGE 3>>>\n\nFebruary 10, 1978\nMr. Robert R. Young\nThe Standard Oil Company\nMidland Building\nCleveland, Ohio 44115\nDear Mr. Young:\nThis responds to your letter dated November 18, 1977, in which\nyou ask, \"does the term 'cracks' as stated in DOT Section 195.230\nand Section 195.232 exclude 'shallow crater cracks or star\ncracks' which are of acceptable dimensions and 'not considered\ninjurious defects' according to Secion [sic] 6.7 of API 1104 and\nDOT Section 195.228?\" The answer is Yes, because the\nacceptability of a weld is determined according to the standards\nin Section 6 of the 1973 edition of API Standard 1104.\nSection 6.7 of API 1104 states: \"Shallow crater cracks or star\ncracks which are located at the stopping point of weld beads and\nwhich are the result of weld metal contraction during\nsolidification are not considered injurious defects unless their\nlength exceeds 5/32 inch. With exception of these shallow crater\ncracks, no weld containing cracks, regardless of size or\nlocation, shall be acceptable.\" The Office of Pipeline Safety\nOperations interpreted the requirement to mean that shallow\ncrater cracks or star cracks 5/32 inch or less are not\nsignificant in the assessment of a weld. We believe that it\nwould be incorrect to conclude that these specific cracks are\nidentified in Section 195.230(a)(1) and Section 195.232(a), since\nthey are not considered injurious defects.\nWe trust that we have satisfactorily responded to your inquiry.\nSincerely,\n/signed/\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\195\\228\\78-04-04 3","truncated":false,"body_characters":4348}