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Interpretation Response #PI-71-070 ([Anderson, Greenwood & Co.] [G. Frank Bright])

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

Interpretation Response Details

Response Publish Date:

Company Name: Anderson, Greenwood & Co.

Individual Name: G. Frank Bright

Location State: TX Country: US

View the Interpretation Document

Response text:

July 29, 1971

Mr. G. Frank Bright
Sales Manager
Safety Relief Valves
Anderson, Greenwood & Co.
P. O. Box 400
Bellaire, Texas 77401

Dear Mr. Bright:

This is in reply to your letter of July 13, 1971, requesting an interpretation of paragraph
192.505(d). You specifically questioned the use of sub-paragraph(d)(2), instead of Section
192.145, for the strength testing of safety relief valves prior to operation.
It is intended that all valves including safety relief valves meet the applicable requirements of
Section 192.145. Paragraph 192.145(a) requires, in part, that each valve meet the minimum
requirements of one of three specifications or the equivalent including API Standard 6D. Section
5.1 of API Standard 6D states, "All pressure tests required in this section (Section 5) shall be
made on all completed valves prior to shipment from the manufacturer's works." The words"each valve" and "equivalent" in paragraph 192.145(a) are used in the sense of providing quality
control and inspection for all valves that would at least be equivalent to that specified for the
specific valves mentioned in API 6D. For example, the listed specifications do not cover all sizes
and types of valves, but a valve of a size or type not covered should at least meet the applicable
safety requirements in the listed specifications. Even though relief valves are not included by
name in API Standard 6D, safety requirements "equivalent" to those elaborated in API Standard
6D must be.

It is recognized that individual pieces of many types of components, such as pipe ells, tees, and
couplings are not individually strength tested at the time of manufacture. Paragraph 192.505(d)
gives the operator an option when such a component is being replaced. This section is intended
for situations where a component cannot as a practical matter be given a post-construction test.
The operator, therefore, does not have to remove the segment of pipeline containing the replaced
component and test the entire segment to prove the item has been pretested per sub-paragraph
192.505(d)(1), or a prototype of the component was tested per sub-paragraph 192.505(d)(2).

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
192.145 Valves