{"operation":"document","citation":"PI-96-0100","title":"Americas Marketing Group, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1996-03-04","effective_on":null,"summary":"PI-96-0100 response to Americas Marketing Group, Inc. concerning 192.145.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-0100.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-0100.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-96-0100","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1996/g96_03_04_Deason_192.145_nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-96-0100\nMarch 4, 1996\nMr. Mike T. Deason\nPresident\nAmericas Marketing Group, Inc.\nP. 0. Box 100849\nBirmingham, Alabama 35210\nDear Mr. Deason:\nThis is in response to your recent letters, in which you requested an interpretation of 49 CFR §192.145, in regards to\ntesting valves. As you noted in your letter, Section 192.145 requires that valves meet the minimum requirements, or\nequivalent, of API 6D.\nAccording to your letter, in your conversation with the American Petroleum Institute you were told that there was no\naccepted equivalent to the hydrostatic test listed in API-6D. You also indicated that you were unable to get written\nstatements from the American National Standards Institute (ANSI) and the Manufacturers Standardization Society (MSS)\nthat the testing requirements for valves in their standards were equivalent to API 6D standard. This lead you to conclude\nthat there were no equivalent testing requirements to API 6D. Therefore, you requested interpretation of \"or\nequivalent\" in Section 192.145, and request that we advise you of an equivalent to the hydrostatic test.\nPublished standards do not cover all types and sizes of valves that are manufactured. However, there are certain basic\nsafety features that can be applied to all valves. In Section 192.145, the word \"or equivalent\" is used in the sense of\naccepting another standard that provides an equivalent level of safety to API 6D, including quality control and inspection\nto API 6D. The term \"or equivalent\" is not necessarily used with regard to hydrostatic or air test or any other specific\nfeatures of industry standards. Other nationally recognized testing and valve standards such as API 598, Valve Inspection\nand Testing, API 608, Metal Ball Valves - Flanged and Butt-weld Ends, and MSS-SP-61, Pressure Testing of Steel Valves,\nallow the use of air as the test medium. In addition, we have enclosed a copy of Technical Report NE-169, \"Weldball\nValve Leakage Analysis, Air versus Water\" supplied by Kerotest Manufacturing Corporation, that may help you in\nidentifying equivalent standards, such as ISO 5208 that is referenced in the report.\nBy not restricting minimum requirements to meet only API 6D standard, we are, in fact encouraging new developments\nin manufacturing and testing of valves, due to the changes in technology.\nWe trust that this interpretation will answer any question you might have.\nSincerely,\nRichard B. Felder\nAssociate Administrator\nfor Pipeline Safety\n\n<<<PAGE 2>>>\n\nState of Florida\nPublic Service Commission\nCapital Circle Office Center\n2540 Shumard Oak BLVD\nTallahassee, FL 32399-0850\nFebruary 28, 1996\nMike T. Deason, President\nAmericas Marketing Group, Inc.\n& M. T. Deason Company, Inc.\nP.O. Box 100849\nBirmingham, Alabama 35210\nRe: Information Request Regarding Code of Federal Regulations, 192.145 Valves\nDear Mr. Deason:\nThe Commission has a rule, 25-12.028, Florida Administrative Code, requiring the marking of materials used in\nnatural gas pipelines. This rule states that each valve must be clearly marked as prescribed in the specification or\nstandard, to which it was manufactured.\nThe Code of Federal Regulations (CFR), Part 192.145 Valves, requires valves to meet the minimum requirements\nof the American Petroleum Institute (API), Specification 6D, \"Specification for pipeline Valves (Gate, Plug, Ball, and Check\nValves)\" (20th edition, 1991). Hydrostatic pressure testing of valves is the minimum required by API 6D. The American\nPetroleum Institute has recently reaffirmed its minimum hydrostatic testing requirements for valves to the natural gas\nindustry.\nFlorida law requires valves to be marked, using the specification of the standard by which they are\nmanufactured, and API 6D is the only approved standard at this time. This may change if the United States Department\nof Transportation or the American Petroleum Institute are forthcoming with additional information.\nIf you have any further questions, contact me at (904) 413-6650.\nRespectfully,\nC. Edward Mills, Supervisor\nEngineering and Safety\nBureau of Gas Regulation\n\n<<<PAGE 3>>>\n\nAmericas Marketing Group, Inc.\nP.O Box 100849\nBirmingham, Alabama 35210\nFebruary 26, 1996\nMr. Cesar De Leon\nU.S. Department of Transportation\nRSPA/Office of Pipeline Safety\n400 7th Street SW\nWashington, DC 20590\nReference: 192.145 Valves, API-6D or \"equivalent\". Dear Mr, De Leon:\nI hope at the writing of this letter that you have received the copy of ISO 5208 ( International Standard for\nTesting Industrial Valves) that I mailed you on February 15, 1996. Please find a letter enclosed that I received from Mr.\nJ.D. Greer, Senior E&P Associate with the American Petroleum Institute. Mr. Greer confirms in this letter that API-6D\nspecification requires hydrostatic shell testing for steel valves and has no provisions for air testing in lieu of the\nhydrostatic test.\nIn my telephone conversation with you on February 15, 1996, you discussed with me the ISO test. I committed\nduring our conversation to provide you with the ISO 5208 test you made reference to. The ISO 5208 standard has\nprovisions for testing with a fluid listed under section 2.2 and 2.2.1 on page one. I also refer you to 4.1.1 and 4.1.2 of the\nstandard that requires testing with a fluid having the velocity not greater than that of water.\nBroen, manufacturer of the BALLOMAX steel ball valves, interprets 192.145 of the Code of Federal Regulations,\nthat each valve must meet the minimum requirements, or \"equivalent\" of API-6D standard for testing valves. Therefore,\nthe American Petroleum Institute has clearly defined there is no equivalent for air testing. Also, the ISO 5208 test has\nprovisions for hydrostatically testing valves.\nThe interpretation we, Americas Marketing Group Inc., representing Broen, are requesting relates to air testing\nof valves under 192.145 of the Code of Federal Regulations. In my opinion, the interpretation of this section of the code\nmust come from Mr. Richard B. Felder, Associate Administrator, U.S. Department of Transportation, Office of Pipeline\nSafety, 400 Seventh St. S.W. Room 2335, Washington, D.C., 20590.\nTo date no one with this agency has had the courtesy to respond to any of our request for an interpretation in\nwriting. Our company is experiencing a price disadvantage in regards to manufacturers testing with air. Your delay and\nnon-response has cost our company sales. Our company meets the requirements and test procedures under API-6D. In\nthe event of an accident, what ruling or interpretation would DOT render in regards to \"air testing\" steel valves under\nthis section of the code? In the interest of safety, how could any valve company be requested on a 900 ANSI valve, to\nperform a minimum air shell test to 3250 PSI? I hope you would agree the valve company would have a potential bomb.\nOur company has gone through the appropriate and suggested chain of command in regards to our request for\nthis interpretation of the code. If I receive no written response you leave me no alternative but to solicit help from my\nstate senator.\nI look forward to your written response and interpretation of what is \"equivalent\" to API-6D. If the air test is\nequivalent, please state so.\nWith warmest personal regards, I remain,\nYours truly,\nAmericas Marketing Group, Inc.\nMike T. Deason\nPresident\n\n<<<PAGE 4>>>\n\nAmerican Petroleum Institute\nExploration & Production Department\n1220 L Street, NW\nWashington, DC 20005\nPhone: (202) 682-8000\nFax: (202) 682-8426\nJ. D. Greer\nSenior E&P Associate\nDirect Line: (202) 682-8494\nFebruary 16, 1996\nMr. Mike Deason, President\nAmericas Marketing Group Inc.\nPO Box 100849\nBirmingham, AL 35210\nRe: API Spec 6D, Specification for Pipeline Valves (Gate, Plug, Ball and Check Valves), 21st Edition, March 31, 1994\nDear Mr. Deason:\nPer our telephone conversation today, this confirms that API Spec 6D requires hydrostatic shell testing, and has no\nprovision for air testing in lieu of hydrostatic testing. This is clearly shown in Par. 5.1 and 5.2 of Section 5, \"Tests\" as\nshown below with underlining added for emphasis:\n5.1 Pressure Tests. Each valve shall be tested as set out in this section prior to shipment from the\nmanufacturer's works. These tests shall be performed in accordance with the manufacturer's written\nprocedures. The manufacturer shall complete shell pressure tests before painting the valves. Tests shall be made\nin the sequence shown in the following paragraphs. Additional tests such as those in Appendix C may be\nperformed by the manufacturer, after the tests in Sections 5.2 and 5.3 unless otherwise noted in Appendix C.\n5.2 Shell Test. Valves shall be subjected to a hydrostatic shell test. . . .\nAppendix C allows hydrostatic testing at higher pressures or for longer times than specified in Section 5.2 (Par. C2), but\nhas no provision for air shell testing.\nSincerely,\n\n<<<PAGE 5>>>\n\nAmericas Marketing Group, Inc.\nP.O. Box 100849\nBirmingham, Alabama 35210\nFebruary 15, 1996\nMr. Cesar De Leon\nU.S. Department of Transportation\nRSPA/Office of Pipeline Safety\n400 7th Street SW\nWashington, DC 20590\nReference: ISO 5208\nDear Mr. De Leon:\nEnclosed is a copy of the International Standard ISO 5208 for your review. Please read this and let me know if\nthis is considered an \"equivalent\" referred to in 192.145. Thank you for the time and courtesy you have extended me\nover the phone today. I am contacting Mr. Jim Greer today with API and will keep you informed of my progress. I hope\nyou would agree whoever wrote the word \"equivalent\" in the code certainly gave DOT the responsibility to interpret\nwhat is \"equivalent\" or the code is left to the interpretation of anyone who manufacturers valves. I have always believed\nthe Code of Federal Regulations set standards for the natural gas industry to follow. Even though I respect your position,\nI totally disagree and fully believe that the interpretation of this statement must come from the Department of\nTransportation.\nIt is our opinion that all interpretations regarding code compliance and an official interpretation of the\nrequirements of standards must come from the U.S. Department of Transportation: Office Pipeline Safety, Washington,\nDC, 20590.\nI respectfully request your reply in writing and hope you would present this to your legal staff as mentioned over\nthe phone.\nSincerely,\nAMERICAS MARKETING GROUP, INC.\nMike T. Deason\nPresident\n\n<<<PAGE 6>>>\n\nAmericas Marketing Group, Inc.\nP.O. Box 100849\nBirmingham, Alabama 35210\nJanuary 3, 1996\nMr. Cesar De Leon\nU.S. Department of Transportation\nRSPA/Office of Pipeline Safety\n400 7th Street SW\nWashington, DC 20590\nSubject: Code of Federal Regulations, Title 49, Part 192, Section 192.145, Minimum Requirements for Testing\nNatural Gas Valves\nDear Mr. De Leon:\nI want to thank you for the courtesy you extended me yesterday over the telephone. Please find enclosed some\nof the correspondence with state and federal officials regarding testing of steel valves per the above code.\nWe, Americas Marketing Group, Inc., are the master distributor for Broen Industries for their steel BALLOMAX\nball valve. All valves are hydrostatically tested per API 6-D which is referenced in 192.145 of the Federal Code.\nPlease render an interpretation of this section of the code regarding testing. Does an air test meet the\nrequirements of this section of the code?\nOur company is hydrostatically testing all valves. Some of our competitors are interpreting the code that an air\ntest meets 192.145. Our company is at a tremendous disadvantage from a competitive situation by performing the\nhydrostatic test if it is not required under 192.145.\nWe respectfully request in writing an interpretation of this code so our company can compete in the natural gas\ndistribution market with our competitors.\nWith warmest personal regards, I remain,\nYours truly,\nMike T. Deason\n\n<<<PAGE 7>>>\n\nAmericas Marketing Group, Inc.\nP.O. Box 100849\nBirmingham, Alabama 35210\nDecember 21, 1995\nMr. Richard B. Felder\nAssociate Administrator for Pipeline Safety, DPS-1\n400 7th Street, SW\nWashington, DC 20590\nSubject: Code of Federal Regulations, Title 49, Part 192, Section 192.145, Minimum Requirements for Testing\nNatural Gas Valves\nDear Mr. Felder,\nI want to thank you for the time and courtesy you extended me this morning over the telephone.\nWe have experienced much confusion in regards to testing of steel valves referred to in the above section of the\ncode of Federal Regulations. The confusion surrounds the word \"equivalent\". I am enclosing for your review the\ncorrespondence between Americas Marketing Group, Inc. and federal and local authorities.\nWe, Americas Marketing Group, Inc., have been referred to you for an interpretation of the code. I know you\nwould agree that no manufacturer of a product is in a position to interpret the code for a gas system. It is our obligation\nto make sure we meet or exceed the minimum requirements.\nCertain manufacturers of steel valves have taken upon themselves the responsibility to inform customers that\nan air test is equivalent to the API 6-D hydro test. If the air test meets the Code of Federal Regulations, would you please\nnotify us in writing so we will no longer be required to hydrostatically test each valve per API 6-D. A manufacturer\nrequired to perform the API 6-D test and mark valves accordingly is at a tremendous price disadvantage against\ncompetition only performing the air test.\nIt is our position that steel valves must be hydrostatically tested as specified in the standard unless you rule and\ngive the specific interpretation of the word \"equivalent\". It is our opinion that the interpretation of this requirement\nmust come from your office only.\nPlease accept this letter and enclosed correspondence as our genuine effort not to misinform our natural gas\nclients. Our sincere interest is to assist in the development of pipeline safety.\nYours truly,\nJohn M. Webb\nSales Representative\nAmericas Marketing Group, Inc","truncated":false,"body_characters":13921}