{"operation":"document","citation":"PI-90-035","title":"State of Minnesota Office of Pipeline Safety — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1990-12-31","effective_on":null,"summary":"PI-90-035 response to State of Minnesota Office of Pipeline Safety concerning 192.227, 192.229.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-90-035.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-90-035.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-90-035","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1990/PI90035.pdf","body":"<<<PAGE 1>>>\n\nMr. William C. Barbeau\nDirector\nState of Minnesota\nOffice of Pipeline Safety\n175 Aurora Avenue\nSt. Paul, MN 55103\nDear Mr. Barbeau:\nI am responding to your letter of November 21, 1990, regarding welder qualifications under 49\nCFR 192.227 and limitations on welders under 49 CFR 192.229.\nAs you requested, we are addressing the following:\n1. \"The code does not clearly specify that welders who qualify under API Standard 1104 or\nASME\nare automatically qualified under the less stringent Appendix C. It is the understanding of this\nOffice that they are not.\"\nSection 192.227 provides that to weld on low stress pipe (less than 20 percent of SMYS), a\nwelder must be qualified by one of these methods: Appendix C of Part 192, Section 3 of API\nStandard 1104, or Section IX of the ASME Boiler and Pressure Vessel Code. Although each\nmethod is a route to qualification on low stress pipe, the methods contain different requirements,\nAPI Standard 1104 and the ASME Code being more stringent than Appendix C. It is not possible\nto perform a single test weld that can satisfy both Appendix C and one of the other methods.\nTherefore, a welder who qualifies under API Standard 1104 or the ASME Code does not\nautomatically qualify under Appendix C.\n2. \"The code does not clearly specify under what conditions welders may downgrade their\nqualification from API Standard 1104 to Appendix C. It is the understanding of this Office that\nthey cannot.\"\nSection 192.227 does not permit an operator to change the basis of a welder's qualification from\none method to another except by qualification under the other method. A welder who wishes to\nqualify under Appendix C must perform one or more welds that are acceptable under Appendix C\nrequirements.\n3. DB\n\"It is unclear to this Office whether the welder in question would have been eligible to\nC:\\WP51\\INTERPRT\\192\\222\\90-12-31.wp\n1\n\n<<<PAGE 2>>>\n\nre-qualify under API Standard 1104 after October 289, 1990. Does six calendar months mean,\nfor instance, April 27 through October 27, or could it mean April 27 through October 31? T.S.I.\nhas previously expressed to our office that six calendar months means date to date, e.g., March 15\n- September 15.\"\nSection 192.229(c) provides that a welder qualified under API Standard 1104 \"may not weld\nunless within the preceding 6 calendar months the welder has had one weld tested and found\nacceptable under section 3 or 6 of API Standard 1104.\" In this provision, the term \"calendar\nmonth\" serves as an expression of time. We have always applied the term consistent with its\nordinary dictionary sense, which is the period between a day in one month and the corresponding\nday in the next month, or the end of the next month if there is no corresponding day. Six calendar\nmonths is the period between a day in one month and the corresponding day in the sixth month\nthereafter, or the last day of that month if there is no corresponding day.\nAccording to you letter, the welder was last re-qualified under API Standard 1104 on April 27,\n1990. In addition, we assume that between then and October 27, 1990, the welder had not\nperformed an acceptable test weld as required by §192.229(c). Therefore, the 6-calendar-month\nperiod ended midnight, October 27, 1990. After that expiration date, the welder was not\npermitted to weld on a gas pipeline without re-qualifying under §192.227. Passage of the 6-\ncalendar-month period does not affect a welder's eligibility to re-qualify under §192.227.\nPlease let me know if you need further assistance in this matter.\nSincerely,\n/signed/\nGeorge W. Tenley, Jr.\nAssociate Administrator for\nPipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\222\\90-12-31.wp\n2","truncated":false,"body_characters":3668}