{"operation":"document","citation":"PI-78-019","title":"LAVALCO Pipeline Products Division — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1978-07-06","effective_on":null,"summary":"PI-78-019 response to LAVALCO Pipeline Products Division concerning 192.105, 192.149.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-019.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-019.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-019","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/PI78019.pdf","body":"<<<PAGE 1>>>\n\nMr. James H. Thompson, Manager\nLAVALCO Pipeline Products Division\nP. O. Box 5614\nShreveport, Louisiana 71105\nDear Mr. Thompson:\nYour letter of May 12, 1978, and the telephone call to you on June 1, 1978, by Paul Cory, of this\noffice raises the following question:\n\"If a weld fitting has been manufactured and marked in accordance with an appropriate\nspecification which is listed in 49 CFR Parts 192 and 195, but is found to be made of steel\nwith a higher yield strength than the SMYS to which it was manufactured and marked,\nmay the actual higher yield strength be used for the design instead of the SMYS?\"\nIn response to this question, your attention is called to §192.149, Standard fittings, paragraph (b),\nwhich states in part, \"Each steel butt-welding fitting must have pressure and temperature ratings\nbased on stresses for pipe of the same or equivalent material.\"\nSection 195.118, Fittings, paragraph (c), states \"The fitting must be suitable for the intended\nservice and be at least as strong as the pipe and fittings in the pipeline systems to which it is\nattached.\"\nThe intent of these sections is that fitting strength be no lower than the strength of pipe of the\nsame or equivalent material. In both §192.105, Design formula for steel pipe, and §192.106.\nInternal design pressure, it is required that the pipe design pressure be based upon the specified\nminimum yield strength. Thus, the specified minimum yield strength would be required to be used\nas the basis for determining the design pressure for weld fittings and not the actual measured yield\nstrength.\nSincerely,\n/signed/\nCesar DeLeon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDirector, Office of Pipeline Safety Operations\nDB\nC:\\WP51\\INTERPRT\\192\\149\\78-07-06\n1\n\n<<<PAGE 2>>>\n\nDepartment of Transportation\n2100 Second Street, S.W.\nWashington, D. C. 20590\nGentlemen:\nRecently Louisiana Valve & Fittings Company established a Pipeline Products Division that\ninventories High Yield Welding Fittings for the oil and gas pipeline companies. We have had\nnumerous discussions with pipeline company personnel regarding their acceptance of material we\nhave in our inventory. The point that is unclear in these discussions is whether a company will\naccept a fitting that is stencilled with a yield strength below the SMYS required but the detailed\nmetal analysis reports received from the manufacturer indicates the actual yield of the metal is the\nsame or greater than required. Parts 191, 192 & 192 of D.O.T. do not make reference to this\npoint.\nOur consensus of opinion is that each individual company or the person responsible for regulation\ninterpretation has their own criteria - in other words some companies will accept material\nstencilled with a lower yield provided test papers prove the integrity of the fitting while other will\nnot.\nI would not be interested in knowing if this question has been posed or if D.O.T. has made any\nruling on the subject. Your prompt response will be helpful in future discussions we have with\nour customers.\nVery truly yours,\nLOUISIANA VALVE 7 FITTINGS CO., INC.\nJames H. thompson, Manager\nLACALCO Pipeline Products Division\nDB\nC:\\WP51\\INTERPRT\\192\\149\\78-07-06\n2","truncated":false,"body_characters":3222}