{"operation":"document","citation":"PI-82-0112","title":"Pipeline Safety Interpretation PI-82-0112","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1982-12-22","effective_on":null,"summary":"PI-82-0112 concerning 192.105.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0112.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0112.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0112","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1982/g82-12-22_Gray_192.105-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-82-0112\nDecember 22, 1982\nMr. J. Malcolm Gray\nMicro alloying International, Inc\nSuite 360\n7670 Woodway\nHouston, TX 77063\nDear Mr. Gray:\nThis answers your letter of November 9, 1982, and previous correspondence from Mr. R. T. Hill of Nucorp Energy, Inc.,\nconcerning the qualification of induction heated pipe bends under 49 CFR Parts 192 and 195. You state in your letter\nthat “The mechanical properties of the pipe body, weld and HAZ of induction bends meet or exceed the properties of\nthe as-received pipe, therefore, it appears that the spirit, and the reason underlying Paragraphs 195.106(a) and\n192.105(b), is not applicable to the product under discussion.”\nA previous January 27, 1982 letter from Nucorp Energy, Inc., to which you refer, concomitantly makes the statement,\n“Because the mechanical properties of induction heated bends are obtained through the heating, quenching and, where\napplicable, post bend tempering operations, there is not a degradation of mechanical properties.\nThough your statements may be correct, we are unable to obtain a corroborative meaning from Section 192.105(b) and\n195.106(a) that would exempt what in effect are “hot bends” from the stated derating requirements. Lacking any other\nsupport, the Materials Transportation Bureau (MTB) must find that the above sections are applicable.\nPrecedent information for this decision may be found in American National Standards Institute (ANSI) standards B31.8\nand B31.4, the 1967 and 1966 editions, respectively, from which the DOT regulations were originally developed. We\nnote that there has been no substantive change in these documents with regard to reducing the pipe design pressure for\nthe effect of heating steel pipe that has been cold worked to meet the specified minimum yield strengths.\nSection 841.233 of the 1967 edition of ANSI B31.8 states that “Hot bends made on cold worked or heat treated pipe\nshall be designed for lower stress levels in accordance with Section 841.14(e).” Section 841.14(e) specifies the 600\ndegree Fahrenheit temperature limit and provides the derating factor to be used in the design formula of Section 841.1,\nwhich is identical with the requirements of the DOT regulations.\nBecause the regulations in question originated within the industry, the MTB has limited technical background upon\nwhich to offer relief and can only suggest that you review your purchase records and other test data to determine if, in\nfact, you are using pipe that has been cold worked to meet the specified minimum yield strength. The MTB has a\nrulemaking underway to raise the temperature limits set by the above-referenced sections of the DOT regulations, but\nbecause of limited data that has been made available the proposed revision may not alleviate your problem. We would,\nhowever, be happy to consider any further technical data you may wish to submit on this subject before a final rule is\nissued. A copy of the Notice of Proposed Rulemaking is enclosed for your information.\nWe trust that this will provide a complete answer to your correspondence. In the event that you have any further\nquestion, let us hear from you.\nSincerely,\nRichard L. Beam\nAssociate Director for Pipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nMicro alloying International, Inc\nSuite 360\n7670 Woodway\nHouston, TX 77063\nNovember 9, 1982\nMr. M. A. Judah\nActing Associate Director for Pipeline Safety Regulations\nU.S. Department of Transportation\n400 Seventh Street, S.W.\nRoom 8423\nWashington, D.C. 20590\nRe: Pipe Bends Produced by Induction Heating & Quenching\nDear Mr. Judah:\nWe refer to correspondence dated January 27 and April 19, 1982 between our colleague, Mr. R. T. Hill of Nucorp\nEnergy, Inc., and the various offices of the DOT (copies attached).\nOur interest relates to interpretation of the Code of Federal Regulations, particularly the derating of cold\nworked pipe which has been heated above 600 F, except by welding.\nThe cycle of induction heating, bending and quenching closely parallels that utilized in the manufacture of\nprimary pipe by the quenching and tempering process. In fact, the relevant metallurgical processes are indistinguishable\nfrom those operative in conventional heat-treating practices. After critical engineering assessment induction bends have\nbeen included in several major installations. The growing acceptance in the pipeline industry can be traced to the\nadvantages cited in the enclosed brochure.\nThe mechanical properties of the pipe body, weld and HAZ of induction bends meet or exceed the properties of\nthe as-received pipe, therefore, it appears that the spirit, and the reasoning underlaying, Paragraphs 195.106(a) and\n192.105(b), is not applicable to the product under discussion.\nSince we are actively involved in the qualification and application of induction bent pipe we would greatly\nappreciate hearing from you concerning the interpretation of Federal Regulations by OPSR and distinctions applicable to\nquenched and tempered product.\nPlease let us know if we can supply technical data or answer any questions that you may have on this subject.\nAlso, note that we are available to meet with you if this will assist in the timely resolution of this contentious issue.\nYours faithfully,\nJ. Malcolm Gray","truncated":false,"body_characters":5275}