{"operation":"document","citation":"PI-84-007","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1984-11-19","effective_on":null,"summary":"PI-84-007 response to Memo: Internal concerning 192.245.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-007.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-007.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-007","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1984/PI84007.pdf","body":"<<<PAGE 1>>>\n\nMEMORANDUM\nDATE: November 9, 1984\nSUBJ: INFORMATION: Interpretation Request - Repair of girth welds using\nsplit sleeves\nFROM: Richard L. Beam\nAssociate Director for Pipeline Safety Regulation, DMT- 30\nTO: Edward Ondak, Chief, Central Region, OOE, DMT-14\nThru: Robert L. Paullin Associate Director for Operations\n& Enforcement, DMT-10\nResponding to your request of October 23, 1984, the following clarification of the\nregulations is more appropriate than an interpretation, which we do not believe the\nconditions warrant.\nYour first two paragraphs generally paraphrase the intent and meaning of\n§§192.245(c) and 192.715(c) to the extent you state them, except that\n§192.715(c) requires the repair of a defective weld with a sleeve rather than\n\"allows\" it if it \"cannot be repaired in accordance with paragraph (a) or (b).\nThe problem you present arises because of inappropriate application of §192.715\nwhich is for the permanent field repair of welds in the maintenance of an existing\nline. It is not a \"construction\" requirement. When the operator repairs the Dresser\ncoupled pipeline by \"removing a section of pipe and welding in a new section\" all\napplicable sections of Subpart E must be complied with in \"replacement\" of that\nsection by welding, including §192.245. Repair of the \"crack in one of the tie-in\nwelds\" must be in accordance with §192.245, and it would not be permissible to\ninstall \"a full encirclement welded split sleeve\" for such a repair. After the\noperator elected to repair the pipe by replacement of a welded tie-in section, the\nfact that the original pipeline was Dresser coupled is irrelevant.\nThe repair method you hypothesized is not appropriate for a replacement section in\na \"welded line\" for the same reasons that it was not for the Dresser coupled one.\n2\ndal\\192.200\\245\\84-11-19\n1\n\n<<<PAGE 2>>>\n\nRequirements of §192.715(a) and (b) appear to be clear and specific, and if they\ncannot be met in the permanent field repair of welds in the maintenance of an\nexisting pipeline, then paragraph (c) \"must be\" met. Circumstances in which\nparagraph (c) would apply would include those where it is not feasible to take the\ntransmission line out of service and the conditions of paragraph (b) cannot be met\n(e.g., defective weld is leaking).\nWhen the operator decides to repair the pipeline by \"replacement\" of a section, it\ndoes not enjoy the prerogative of being \"not interested in establishing and\nqualifying procedures for repair of cracks\" in the tie-in welds it must perform.\n#\ndal\\192.200\\245\\84-11-19\n2\n\n<<<PAGE 3>>>\n\nMEMORANDUM\nDATE:October 25, 1984\nSUBJ: INTERPRETATION REQUEST: using split sleeves\nRepair of girth welds\nFROM: Chief, Central Region, DMT-14\nThru: Associate Director, OOE, DMT-10\nTO: Associate Director, OPSR, DMT-30\n192.245(c) requires that repair of a girth weld containing a crack be made in accordance\nwith qualified written weld repair procedures.\n192.715(c) allows for the repair of a defective weld by installing a full encirclement\nwelded split sleeve of appropriate design if the weld cannot be repaired in accordance with\n192.715(a) or (b).\nIf an operator, in repairing a dresser coupled pipeline made that repair by removing a\nsection of pipe and welding in a new section of pipe, determined that there was a crack in\none of the tie-in welds, could he satisfy the requirements of the regulations by installing a\nfull encirclement welded split sleeve? Keep in mind that this is a dresser coupled pipeline,\nor contains dresser couplings, and the joints could have been made by using dresser\ncouplings in the first place.\nCould this same type of repair be made if the pipeline were a welded line?\nWhat circumstances could warrant the weld \"not repairable\" by the criteria of 192.715(a)\nor (b)?\nFor the above situations, assume the operator is not interested in establishing and\nqualifying procedures for repair of cracks and repair of previously repaired areas.\ndal\\192.200\\245\\84-11-19\n3","truncated":false,"body_characters":3958}