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Interpretation Response #PI-76-006 ([Tennessee Public Service Commission] [John Searcy])

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

Interpretation Response Details

Response Publish Date:

Company Name: Tennessee Public Service Commission

Individual Name: John Searcy

Location State: TN Country: US

View the Interpretation Document

Response text:

Jan 28 1976

Mr. John Searcy
Engineering Division
Tennessee Public Service Commission
Cordell Hull Building
Nashville, Tennessee 37219

Dear Mr. Searcy:

The following responds to the questions in your letter of January 2, 1976:

Question 1: Is it a correct interpretation that a welder qualified initially under 192.227(a) in
accordance with the 1968 ASME Boiler and Pressure Vessel Code, Section IX is, in effect,
required by 192.229(c) to re-qualify after 6 months in accordance with API 1104 only, not
Section IX?

Answer: A welder qualified under Section IX of the 1968 edition of the ASME Boiler and
Pressure Vessel Code in accordance with §192.227(a) may not weld unless, within the preceding
six calendar months, that welder has had at least one weld tested and found acceptable under
Section 3 or 6 of API Standard 1104, as required by §192.229(c). Section 192.229(c) does not
require that the welder requalify under API 1104.

Question 2: If the interpretation in Question 1 is correct, can a welder, after 6 months, initially
qualify again in accordance with Section IX?

Answer: Although your interpretation in Question 1 is incorrect, if a welder requalifies under
Section IX within six months, §192.229(c) would not apply.

Question 3: Is a welder qualified in accordance with 192.227(a) automatically qualified for a year
in accordance with 192.227(c) for pipe operating at less than 20% SMYS?

Answer: As prescribed by §192.229(c), a welder who qualifies under §192.227(a) to weld pipe to
be operated at any stress level allowed in the regulations may not weld that pipe, including pipe to
be operated at less than 20% of SMYS, for more than six months following his qualification
unless he has had at least one weld tested and found acceptable under Section 3 or 6 of API
Standard 1104.

Question 4: Is it a correct interpretation that 192.125(c) is limiting to 100 psi only the ASTM B
88 type "L" copper referred to in 192.125(b), and that copper with a greater wall thickness is not
restricted to 100 psi?

Answer: No, §192.125(c) prohibits the use of copper pipe of any thickness in operation above
100 psig.

Sincerely,

Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections

Section Subject
192.227 Qualification of welders and welding operators