{"operation":"document","citation":"PI-79-015","title":"El Paso Natural Gas Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1979-05-21","effective_on":null,"summary":"PI-79-015 response to El Paso Natural Gas Company concerning 192.229.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-015","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1979/PI79015.pdf","body":"<<<PAGE 1>>>\n\nMr. Foch LaFitte\nSuperintendent of Welding\nEl Paso Natural Gas Company\nP.O. Box 1492\nEl Paso, Texas 79978\nDear Mr. LaFitte:\nYour letter of April 1979, indicates that El Paso Natural Gas Company qualifies welders under\nthe multiple qualification test of Section 3.2 of API Standard 1104 in accordance with Section\n192.227(a). You ask id the test required each 6 calendar months by Section 192.229(c) to\ncontinue welder qualification must include the layout, cut, and weld of a 12- by 12-inch or larger\nsaddle weld as is required in the original qualification.\nWhen a welder has been previously qualified, only one weld must be tested and found acceptable\nfor each 6-month period under either Section 3 or 6 of API Standard 1104 in order to comply\nwith Section 192.229(c). The type of weld to be used to maintain a welder's qualification is not\nspecified. A 12- by 12-inch or larger saddle weld could be selected by the operator for such\ntesting, although a butt weld or fillet weld could also be used.\nI hope that this clarifies the intent of Section 192.229(c).\nSincerely,\n/signed M.A. Judah/\nCesar DeLeon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDB\nC:\\WP51\\INTERPRT\\192\\229\\79-05-21\n1\n\n<<<PAGE 2>>>\n\nMr. Cesar DeLeon, Associate Director\nfor Pipeline Safety Regulation\nU.S. Department of Transportation\n2100-2nd Street S.W.\nWashington, D. C. 20590\nDear Mr. DeLeon:\nRegarding our telephone conversation this date, El Paso Natural Gas Company has three\noperating divisions and near each division main office we maintain a division welding shop.\nApproximately ninety percent of the division welding is done in and out of these shops, the\nremainder is done by a few welders stationed in the remote pipeline districts.\nOur division welding superintendents first tried using the single welder qualification but it was a\nproblem due to testing time plus assurance that all welders were in compliance at all times. Two\nyears ago it was decided that by using the multiple qualification for all company welders it would\nbe less trouble, less expensive and at the same time assure that all welders were in compliance\nwith the code,\nAll company welders were qualified on the multiple 12' butt weld, and a 12' on 12' saddle weld to\nAPI-1104 Code. Since then, and before the expiration of six months, they x-ray a production butt\nweld 12' or larger, fill out a test sheet, and attach the x-ray log sheet for each welder. My\nquestion is -- since we never have 12' on 12' or larger saddle production welds, are we required to\nhave each welder lay out, cut and weld a 12' on 12' or larger at the end of each six months in\norder to maintain qualification for the multiple test?\nYour truly,\nFoch LaFitte\nSuperintendent of Welding\nDB\nC:\\WP51\\INTERPRT\\192\\229\\79-05-21\n2","truncated":false,"body_characters":2804}