Interpretation Response #PI-15-0012
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Mr. Lee Strobel
GE Oil & Gas
50 Thomas Patten Drive
Randolph, MA 02368
Dear Mr. Strobel:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated October 15, 2015, you requested an interpretation of 49 CFR 192.63. You asked if the requirements of § 192.63 apply to your instrumentation components of a control valve assembly.
You stated that the actuator and instrumentation system are custom designed to operate with the pipeline control valve and the whole system is shipped and installed as a complete assembly. You asked whether the control valve system complies with the requirements of § 192.63 if this whole system is marked at the assembly level.
You referenced prior interpretations you believe state that it is acceptable for components to be bundle-marked, not individually marked, as long as they are grouped in a bundle, one which stays together up to the point of installation.
Based on these interpretations, you indicated your understanding was that as long as suitable markings are visible on the complete assembly, to the point of installation, it would not be necessary for markings to be maintained on the assembly or its individual subcomponents after the system has been installed. You further asked that should your understanding be incorrect, PHMSA clarify the definition of the term component in § 192.63, and whether this section requires each fitting, bolt and length of tube in instrumentation assembly to be marked individually. Also, you asked if the requirements apply to sub-components of assemblies such as valve body and seats or O-rings.
The purpose of § 192.63 is to require a pipeline operator, operating pipeline regulated by 49 CFR Part 192 to provide positive identification of the equipment or component of the pipe, and thus, assure that it is not subjected to operating conditions exceeding those for which it was designed. Each valve, fitting, pipe, or other component used in a pipeline to which § 192.63 applies must meet the marking requirements. Section 192.63 states:
§ 192.63 Marking of materials.
(a) Except as provided in paragraph (d) of this section, each valve, fitting, length of pipe, and other component must be marked—(1) As prescribed in the specification or standard to which it was manufactured, except that thermoplastic pipe and fittings made of plastic materials other than polyethylene must be marked in accordance with ASTM D2513–87 (incorporated by reference, see § 192.7); (2) To indicate size, material, manufacturer, pressure rating, and temperature rating, and as appropriate, type, grade, and model.
(b) Surfaces of pipe and components that are subject to stress from internal pressure may not be field die stamped.
(c) If any item is marked by die stamping, the die must have blunt or rounded edges that will minimize stress concentrations.
(d) Paragraph (a) of this section does not apply to items manufactured before November 12, 1970, that meet all of the following: (1) The item is identifiable as to type, manufacturer, and model. (2) Specifications or standards giving pressure, temperature, and other appropriate criteria for the use of items are readily available.
The GE Oil & Gas control valve system in question includes components such as an instrumentation system, valves, and actuators. The question is whether GE Oil & Gas can meet § 192.63 requirements by marking its whole control valve system with a single tag and not individually mark the components within this system. Section 192.63(a) clearly states that each component, including but not limited to, valves, fittings, and length of pipe must be marked as prescribed in the specification or standard to which it was manufactured, and to indicate size, material, manufacturer, pressure rating, and temperature rating, and as appropriate, type, grade, and model. Based on § 192.63(a) requirements, GE Oil & Gas must comply with the standard to which it manufactures its control valve system and mark the components of this system, such as the instrumentation system and valves, including pressure containing components of valves and actuators, individually.
PHMSA notes the prior interpretations you referenced. In these interpretations, PHMSA has approved of bundle-marking. PHMSA continues to approve bundling marking as opposed to individually marking the components of the bundles – provided this bundle remains packaged together up to the point of installation. These interpretations are dissimilar and do not apply to your request, as you will not be bundling individual components. Instead you indicated that the instrumentation system, valves, and actuators are assembled into a working assembly, and then shipped as a complete assembly to its point of installation.
You asked PHMSA to clarify the definition of the term component in § 192.63. Component is not defined in Part 192, but it is used throughout the Part. Also, both Parts 193 and 195 define component. Therefore based on the use and the definitions in the other parts, a component can be interpreted as any part or system of parts of a pipeline as defined in § 192.3.
If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
John A. Gale
Director, Office of Standards
T:/PHP-30/Interps/Open/GE Oil & Gas-PI-15-0012-10-29-2015-Part 192.63
|§ 192.63||Marking of materials|