{"operation":"document","citation":"PI-96-006","title":"Kerotest Manufacturing Corp. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1996-03-07","effective_on":null,"summary":"PI-96-006 response to Kerotest Manufacturing Corp. concerning 192.145.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1996/PI96006.pdf","body":"<<<PAGE 1>>>\n\nMr. David M. Lakatos, P.E.\nEngineering Manager\nKerotest Manufacturing Corp.\n5500 Second Avenue\nPittsburgh, PA 15207-1807\nDear Mr. Lakatos:\nThis is in response to your recent letters, in which you have provided your justification for using\nair as the test medium for testing valves during their manufacture in lieu of water as required by\nAPI 6D which is referenced in 49 CFR § 192.145. In support of your justification, you provided\nus reasons and enclosed a copy of Technical Report NE-169, \"Weldball Valve Leakage Analysis,\nAir versus Water\". You indicated that the term \"or equivalent\" in § 192.145 allows you to\nchoose other standards such as ISO 5208 that allow air as the test medium and provide an\nequivalent level of safety to API 6D, including structural integrity and leak tightness.\nWe have enclosed a copy of the Research and Special Programs Administration's response to an\ninquiry from the Americas Marketing Group, Inc., requesting an interpretation of \"or equivalent\nof API 6D\" in § 192.145. We believe that our interpretation will answer any questions you might\nhave.\nSincerely,\nRichard B. Felder\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\nRichard E. Sanders, TSI\nDPS-11/10/2/1;\nMisrani:interp.192:March 7, 1996\n05/11/99 192.145\n96-03-07.doc\n\n<<<PAGE 2>>>\n\nMr. Mike T. Deason\nPresident\nAmericas marketing Group, Inc.\nP. O. Box 10084\nBirmingham, Alabama 35210\nDear Mr. Deason:\nThis is in response to your recent letters, which you requested an interpretation of 49 CFR\n§192.145, in regards to testing valves. As you noted in your letter, Section 192.145 requires that\nvalves meet the minimum requirements, or equivalent, of API 6D.\nAccording to your letter, in your conversation with the American Petroleum Institute you were\ntold that there was no accepted equivalent to the hydrostatic test listed in API-6D. You also\nindicated that you were unable to get written statements from the American National Standards\nInstitute (ANSI) and the Manufacturers Standardization Society (MSS) that the testing\nrequirements for valves in their standards were equivalent to API 6D standard. This lead you to\nconclude that their [sic] were no equivalent testing requirements to API 6D. Therefore, you\nrequested interpretation of \"or equivalent\" in Section 192.145, and request that we advise you of\nan equivalent to the hydrostatic test.\nPublished standards do not cover all types and sizes of valves that are manufactured. However,\nthere are certain basic safety features that can be applied to all valves. In Section 192.145, the\nword \"or equivalent\" is used in the sense of accepting another standard that provides an\nequivalent level of safety to API 6D, including quality control and inspection to API 6D. The\nterm \"or equivalent\" is not necessarily used with regard to hydrostatic or air test or any other\nspecific features of industry standards.\nOther nationally recognized testing and valve standards such as API 598, Valve Inspection and\nTesting, API 608, Metal Ball Valves - Flanged and Butt-weld Ends, and MSS-SP-61, Pressure\nTesting of Steel Valves, allow the use of air as the test medium. In addition, we have enclosed a\ncopy of Technical Report NE-169, \"Weldball Valve Leakage Analysis, Air versus Water\" supplied\nby Kerotest Manufacturing Corporation, that may help you in identifying equivalent standards,\nsuch as ISO 5208 that is referenced in the report.\nBy not restricting minimum requirements to meet only API 6D standard, we are, in fact\nencouraging new developments in manufacturing and testing of valves, due to the changes in\ntechnology.\nWe trust that this interpretation will answer any question you might have.\nSincerely,\nRichard B. Felder\n05/11/99 192.145\n96-03-07.doc\n\n<<<PAGE 3>>>\n\nAssociate Administrator\nfor Pipeline Safety\ncopy: Richard E. Sanders, TSI\nDPS-11/10/2/1;\nMisrani:interp.192:<Date>\n05/11/99 192.145\n96-03-07.doc","truncated":false,"body_characters":3884}