{"operation":"document","citation":"PI-81-0112","title":"Pipeline Safety Interpretation PI-81-0112","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1981-08-18","effective_on":null,"summary":"PI-81-0112 concerning 192.145.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-0112.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-0112.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-0112","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1981/g81-08-18_Schmitt_192.145-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-81-0112\nAugust 18, 1981\nMr. E. L. Schmitt\nNicotine Manufacturing Corporation\n1525 Liberty Avenue\nPittsburgh, PA. 15222\nDear Mr. Schmitt:\nThis refers to you letter of April 16, 1981, in which you requested the advice of this office on what action you should\ntake so that the use of malleable iron covers on you275 WOG valves will conform to applicable standards in 49 CFR part\n192. As you noted in your letter, §192.145 requires that valves meet the minimum requirements, or the equivalent, of\nthe industry standard, API 6A, API 6D, or MSS SP-70, all three of which require steel covers to be used on you 275 WOG\nvalves.\nSince §192.145 permits the equivalent of the standard quoted above to be used, you may use a malleable iron cover in\ncomplying with §192.145 if it can be demonstrated that the 275 WOG valve constructed with a malleable iron cover\nwould provide at least the same level of safety under expected operating conditions as one constructed with a steel\ncover. You may use any qualified expertise in making this determination, but one source, of course, would be industry\ngroups responsible for the quoted standards. This office does not make equivalency determinations for manufacturers\nor operators; however, Federal or State inspection personnel may judge the correctness of any determination as part of\ntheir enforcement duties when visiting an operator’s facilities.\nTo answer your question as to whether you should formally request a waiver, if equivalency is demonstrated there is no\nneed for a waiver since §192.145 would be satisfied. Moreover, section 3 of the Natural gas Pipeline Safety Act of 1968,\nas amended by Title 1 of the Pipeline Safety Act of 1979, permits the secretary of transportation to grant waivers only to\npersons engaged in the transportation of gas or the operation of pipeline facilities. Since it appears that you are engaged\nin the manufacturing of components for gas pipelines and not in the transportation of gas or operation of pipeline\nfacilities, you would not fall into the category of petitioners to whom a waiver could be granted.\nIf equivalency cannot be demonstrated but there is reason to believe the 275 WOG valve can be used safely under\nexpected operating conditions, you may petition us to amend §192.145 to allow the use of 275 WOG type valves with\nmalleable iron covers in gas pipelines. Such a petition should clearly set forth the reasons why the valve should be\npermitted even though it does not provide the level of safety now required by §192.145.\nSincerely,\nMelvin A. Judah\nActing Associate Director\nPipeline safety regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nKerotest Manufacturing Corp\n2525 Liberty Avenue\nPittsburgh, PA 15222\nApril 16, 1981\nDirector, Office of Pipeline Safety Operations\nDepartment of Transportation\n2100 Second Street, S.W.\nWashington D.C., 20590\nDear Sir:\nParagraph 192.145 of CFR stipulates that valves must meet the minimum requirements or the equivalent, of API\n6A, API 6D, MSS SP-70, etc. Kerotest Mfg. Corp. at the present time has a unique situation regarding this paragraph.\nWe have been manufacturing a line of valves, the Model 1 Valve, which was developed around 1960, exclusively for the\nnatural gas industry. It had to be competitive with cast iron valves and yet have the capabilities of being welded in the\nline. This was accomplished by making the bodies of steel and the covers of malleable iron. This acceptable combination\ncaused problems when it became necessary to adhere to a specific code.\nWe make a 275 WOG Series and a 500 WOG Series of valves. The 500 WOG is a cast iron rating (250 Series) and\nconforms to MSS SP-70 since this specification states you can construct the valve from more qualified material than cast\niron. The 275 WOG is a steel rating (150 Series) and when the Federal Code incorporated API 6D, we had to put steel\ncovers on this class of valves for conformance. Prior to this, we sold thousands of these valves with the malleable covers.\nOur interpretation of the Federal Code is that we are permitted to place a valve rated at 500 WOG with a malleable\ncover in a pipeline, but the 275 WOG valves, which is lower rated, must have a steel cover. This is not logical and we are\nlooking for a way to justify using malleable covers.\nWe are requesting your comments on this situation and request you advise us on what action we should take to\njustify returning to malleable covers on the 275 WOG valves and still conform to the Federal Code. Should we formally\nrequest a waiver?\nIt is requested you give this some thought and notify us of your recommendations. Thank you for your time and\neffort.\nYours truly,\nE. L. Schmitt\nKerotest Manufacturing Corporation","truncated":false,"body_characters":4718}