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Interpretation Response #PI-79-015 ([El Paso Natural Gas Company] [Foch LaFitte])

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

Interpretation Response Details

Response Publish Date:

Company Name: El Paso Natural Gas Company

Individual Name: Foch LaFitte

Location State: TX Country: US

View the Interpretation Document

Response text:

Mr. Foch LaFitte

Superintendent of Welding

El Paso Natural Gas Company

P.O. Box 1492

El Paso, Texas 79978

Dear Mr. LaFitte:

Your letter of April 1979, indicates that El Paso Natural Gas Company qualifies welders under the multiple qualification test of Section 3.2 of API Standard 1104 in accordance with Section 192.227(a). You ask if the test required each 6 calendar months by Section 192.229(c) to continue welder qualification must include the layout, cut, and weld of a 12- by 12-inch or larger saddle weld as is required in the original qualification.

When a welder has been previously qualified, only one weld must be tested and found acceptable for each 6-month period under either Section 3 or 6 of API Standard 1104 in order to comply with Section 192.229(c). The type of weld to be used to maintain a welder's qualification is not specified. A 12- by 12-inch or larger saddle weld could be selected by the operator for such testing, although a butt weld or fillet weld could also be used.

I hope that this clarifies the intent of Section 192.229(c).


/signed M.A. Judah/

Cesar DeLeon

Associate Director for

Pipeline Safety Regulation

Materials Transportation Bureau

Regulation Sections

Section Subject
192.229 Limitations on welders and welding operators