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Interpretation Response #PI-71-068 ([ACF Industries, Inc.] [R. M. Estes])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: ACF Industries, Inc.

Individual Name: R. M. Estes

Location State: TX Country: US

View the Interpretation Document

Response text:

Mr. R. M. Estes
ACF Industries, Inc.
W-K-M Valve Division
P.O. Box 2117
Houston, Texas 77001

Dear Mr. Estes:

This is in reply to your letter of July 13, 1971, requesting an interpretation as to whether or not
certain sections of Part 192 pertain to valves.

Our reply is divided into four parts, with each part pertaining to one of the sections you

  1. 192.105 - Design Formula for Steel Pipe
    Section 192.105 is contained in Subpart C titled, "Pipe Design." The Scope of Subpart C states, "This subpart prescribes the minimum requirements for the
    design of pipe." Subpart C and therefore Section 192.105 does not pertain to valves.
  2. 192.143 - General Requirements

    Section 192.143 is contained in Subpart D titled, "Design of Pipeline
    Components." The Scope of Subpart D states in part that the subpart, "prescribes
    minimum requirements for the design and installation of pipeline components and
    facilities." A valve is a pipeline component. Section 192.143 contains general
    requirements for all components and therefore does apply to valves.
  3. 192.147 - Flanges and Flange Accessories

    Section 192.147 is also located in Subpart D. There is no exception given is
    Section 192.147 for flanges that are integrally connected to a valve. Therefore,
    end flanges of valve must meet the requirements of Section 192.147.
  4. 4. 192.149 - Standard Fittings

    The term "fittings" as used in Section 192.149 pertains to a component which is
    installed in a pipeline in place of pipe such as pipe ells and tees. Valves and flanges
    are not included since requirements for their design are located in Section 192.145
    and Section 192.147. Valves, therefor, are not subject to the requirements of
    Section 102.149.

Please contact me if I can be of any further assistance in this matter.


Joseph C. Caldwell
Acting Director
Office of Pipeline Safety

Regulation Sections

Section Subject
192.105 Design formula for steel pipe
192.143 General requirements
192.147 Flanges and flange accessories
192.149 Standard fittings