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Interpretation Response #PI-71-079 ([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:

Mr. G. Frank Bright
Sales Manager
Safety Relief Values
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.

Sincerely,

/signed/

Joseph C. Caldwell
Acting Director
Office of Pipeline Safety

Regulation Sections

Section Subject
192.505 Strength test requirements for steel pipeline to operate at a hoop stress of 30 percent or more of SMYS