{"operation":"document","citation":"PI-86-006","title":"Mid-America Pipeline Co. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1986-08-21","effective_on":null,"summary":"PI-86-006 response to Mid-America Pipeline Co. concerning 195.422.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-86-006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-86-006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-86-006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1986/PI86006.pdf","body":"<<<PAGE 1>>>\n\nAug 21 1986\nMr. R. E. Penderson\nManager Engineering\nMid-America Pipeline Co.\n1800 South Baltimore Ave.\nPost Office Box 645\nTulsa, Oklahoma 74101-0645\nDear Mr. Penderson:\nYour letter of July 16, 1986, requests that we amend Part 195 to\npermit the use of encirclement sleeves as a repair method for\ndefective welds in operating pipelines. Your letter indicates\nthat ANSI B31.4 permits their use as an acceptable repair method\nin either maintenance or construction.\nThe regulation governing the repair of hazardous liquid pipelines\nin operation is ?195.422. This regulation does not disallow the\nuse of encirclement sleeves to repair defects in operating\npipelines, including weld defects.\nPart 195 does not, however, permit the use of encirclement\nsleeves to repair weld defects discovered during construction.\nThese defects must be removed or repaired in accordance with the\nrequirements of ?195.230.\nIn our view, ANSI B31.4 does not differ from Part 195 regarding\nthe permissibility of using encirclement sleeves to repair weld\ndefects. Their use is permitted by section 451.6 as an allowable\nrepair method for weld defects in operating pipelines, but not\nweld defects in pipelines under construction. These latter weld\ndefects are required by section 434.8.7(b) to be repaired\naccording to API Standard 1104, which in section 7 sets forth\nspecific weld removal and repair standards that do not include\nthe use of encirclement sleeves.\nSince Part 195 does not prohibit the use of encirclement sleeves\nto repair weld defects in operating pipelines, there is no need\nfor an amendment to permit such usage. Also, since the B31.4\ncode does not permit the use of sleeves for weld repair during\nconstruction, there does not appear to be an adequate basis for\nchanging Part 195 to permit their use in this respect.\nSincerely,\nRobert L. Paullin\nDirector\ndal\\195\\422\\86-08-21\n1\n\n<<<PAGE 2>>>\n\nOffice of Pipeline Safety\nMID-AMERICA PIPELINE COMPANY\n16 July 1986\nU.S. Department of Transportation\nOffice of pipeline Safety\n400 7th Street SW\nWashington, DC 20590\nAttention: Dr. Robert Paullin\nDear Dr. Paullin:\nMid-America Pipeline Company i s in the business of\ntransporting primarily highly volatile liquids, that is natural\ngas liquids and anhydrous ammonia. In following the approved\nweld repair method as described in Part 195.230 \"Repair or\nRemoval of Defects\" and Part 195.422 \"Pipeline Repairs\" the\noperator of \"in service\" pipelines is required, when repairing\ndefective welds that require the removal of a cylinder of pipe\nincluding the weld, to set \"stopples\" or otherwise evacuate the\npipeline. This unnecessarily exposes employees to the product\nvapors and in the case of anhydrous ammonia requires that the\nwork be performed while wearing gas mask or other breathing\napparatus.\nFor the reason summarized above, Mid-America Pipeline\nCompany does hereby petition the Commission to revise Part 195\nby adding the repair procedure as described in ANSI B31.4 as an\nacceptable repair method in either maintenance or construction.\nThat is, the application of a complete encirclement sleeve over\nthe defective weld when found in an operating pipeline. This, we\nbelieve, will satisfy the intent of Part 195 to protect the\npublic as well as the operators employees and will provide an\nadditional repair procedure that is currently accepted as proper\nand safe.\nSincerely,\nR. E. Penderson\nManager Engineering\ndal\\195\\422\\86-08-21\n2","truncated":false,"body_characters":3434}