{"operation":"document","citation":"PI-79-039","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1979-11-01","effective_on":null,"summary":"PI-79-039 response to Memo: Internal concerning 195.214.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-039.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-039.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-79-039","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1979/PI79039.pdf","body":"<<<PAGE 1>>>\n\nNovember 1, 1979\nInterpretation of Para. 195.230(a)(2);\nLetter Response to C. R. Brashears,\nOctober 24, 1979, DMT-32; To File DMT-32\nW. A. Gloe, DMT-32\nCesar DeLeon, Frank Fulton, Lucian Furrow, Mel Judah, and Lloyd\nUlrich\n1. We have an indication that there may not be universal\nagreement with regard to whether or not Para. 195.230(a)(2) would\nallow local weld repair during the welding operation without\nidentifying the weld as then \"previously repaired\" to avoid the\nprohibition against further repair.\n2. The case in point is the answer to C. R. Brashear's [sic]\nQuestion 2.B.; both question and answer set out below as given:\n\"B. Is it considered a repair if a welder repairs his weld\nduring the process of making the weld?\n\"Ex.: A welder has completed the stringer bead and hot\npass (Ref: Attachment A) and is aware of incomplete fusion\nbetween stringer bead and hot pass. The welder either\ngrinds out the hot pass and rewelds it from the outside or\ngrinds out the stringer bead and rewelds it from the inside.\nThe welder now completes the weld and the x-ray reveals\nlack of fusion in the same area, can this weld be repaired a\nsecond time?\n\"Answer:\n\"B. It is not considered a repair within the meaning of ?195.230\nif a welder takes corrective action during the original welding\noperation to assure acceptability of his weld. However, the\nrequirements for ?195.214(b) should be considered in this regard\nto assure that there is no departure from the written welding\nprocedure in the welder's corrective action and that \"sound,\nductile welds\" and thus produced. In the case that x-ray reveals\nlack of fusion in the same area, the weld may be repaired as a\nfirst repair, since the use of the term 'repair' in the\nregulations means repair of the completed weld, not corrective\nactions taken in the original welding operation.\"\n3. One understanding is that our answer would be more clear and\ndal\\195\\214\\79-11-01\n1\n\n<<<PAGE 2>>>\n\nconsistent if we had specified that the welder may make such an\nin-process repair as described if the weld has not yet cooled.\n2\nIn this way, it is felt that we would be consistent with later\nprohibition of second repair to a weld segment on the basis of\nadverse effects due to double reheating of the heat affected zone\nof the weld.\n4. One reason for expressing the answer to Question 2.B. in the\nmanner selected is to recognize that it is not possible to avoid\ncooling of a weld bead other than by following with another weld\nbead or applying heat by some means. In the situation described,\nthe stringer bead and the hot pass would have undoubtedly cooled,\nmaking it necessary to accept this condition as a definitive part\nof the question.\n5. Further, since cooling of a weld may mean different things to\ndifferent people, it would be necessary to specify a limiting\ncondition, i.e., a specific temperature, or \"hot to the touch,\"\n\"warm to the touch,\" etc. Since weld cooling rate is an\nessential factor in weld quality, it is included in the welding\nprocedure, and almost singly mandates the use of a qualified\nwelding procedure. Therefore, the answer to the question\nrightfully refers to Para. 195.214(b) and specifies that there\nmay be no departure from the written welding procedure.\n6. Another view is that the reheating of a weld bead during\nrepair by the welder as described has the same effect as\nreheating in the repair of a completed weld. This view\napproaches the essential dividing line in the interpretation as\ngiven, although from the opposite point. The answer given is\nphrased \"within the meaning of ?195.230,\" which section discusses\nrepair of defects in completed welds. Therefore, though the view\nmay or may not be correct, the regulations do not prescribe\nconditions for partially completed welds other than by referring\nto written welding procedures, and the answer aptly describes\nthis fact. The answer otherwise would appear to assume\nrequirements that do not exist.\n7. If the intent of the regulations were to include single bead\nrepair during the welding operation with repair of the completed\nweld under Para. 195.230(a)(2), it would appear that the control\nof Section 195.228 would have to be extended to in-process\naspects of welding, and the reference to Section 6.0 of API\nStandard 1104 would have to be qualified or removed. If\nacceptability of a weld were to be determined at any time before\ncompletion, the only disposition that could be made in accordance\nwith Section 6.0 would be to reject the weld.\ndal\\195\\214\\79-11-01\n2\n\n<<<PAGE 3>>>\n\n8. Based on the above, it is concluded that the interpretation\ngiven is applicable, notwithstanding the fact that in extreme\nsituations a technical conflict may be posed. It is also\n3\nconsidered that the interpretation is consistent with both safety\nand industry standards to the maximum extent possible.\n9. Therefore, unless there is other information which should be\nconsidered, it is felt that the interpretation should stand\nas-is.\nW.A. Gloe\nNote: This part of the interpretation will be reviewed with\nDick Gwinn on 11/2 and his comments will be attached as\na part of the record.\ndal\\195\\214\\79-11-01\n3","truncated":false,"body_characters":5129}