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Interpretation Response #PI-73-0108 ([The Pipe Line Development Company] [Mr. Ronald D. Gardner])

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

Interpretation Response Details

Response Publish Date:

Company Name: The Pipe Line Development Company

Individual Name: Mr. Ronald D. Gardner

Location State: OH Country: US

View the Interpretation Document

Response text:

April 30, 1973

Mr. Ronald D. Gardner, Manager
Research and Development
The Pipe Line Development Company
1831 Columbus Road
Cleveland, Ohio 44113

Dear Mr. Gardner:

Your letter of April 10, 1973, enclosed a sketch of a domed, contoured welding cap used to cover a pit hole clamp. The cap is field welded for permanency on pipe of not more than 40,000 p.s.i. SMYS. You ask, in effect, whether the design of this cap is governed by the standards of §192.717(c).

As here relevant, §192.717(c) is applicable to welded steel plates that are used to repair corrosion pits. However, the cap described in the sketch appears to be a fitting or component rather than a plate. The provisions of §192.717(c) would therefore not apply to your cap. Although the regulations contained in Part 192 do not purport to cover the specific design requirements of every type of component or fitting that might be safely welded onto a pipeline, they do, however, set forth general design requirements for pipeline components including components fabricated by welding. Thus Subpart D of Part 192, including in particular §192.153, would be applicable to the design of the welding cap. Subpart E of Part 192, covering the welding of steel in pipelines, would also have general applicability with reference to the design of welding caps.

To the extent that you consider your welding cap to be a branch connection as suggested in your letter, the applicable design requirement is set forth in §192.155. That requirement is stated as a performance standard rather than a detailed specification, and the means of compliance is left with the designer.

For your information, a copy of Part 192 is enclosed. If you have further questions in this regard, we will be pleased to respond.


Original signed by:
Joseph C. Caldwell


Regulation Sections

Section Subject
192.153 Components fabricated by welding