Interpretation Response #PI-95-048 ([Massachusetts Department of Public Utilities] [Angela S. Motley])

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

Interpretation Response Details

Response Publish Date: 10/18/1995

Company Name: Massachusetts Department of Public Utilities

Individual Name: Angela S. Motley

Location State: MA Country: US

View the Interpretation Document

Response text:

October 18, 1995

Ms. Angela S. Motley

Public Utilities Engineer

Massachusetts Department of Public Utilities

Leverett Saltonstall Building

100 Cambridge Street

Boston, MA 02202

Dear Ms. Motley:

This is in response to your letter of August 2, 1995, requesting an opinion on 49 CFR 192.229(c) which states in part:

"A welder qualified under §192.227(a) may not weld unless within the preceding 6 calendar months the welder has had one weld tested and found acceptable under section 3 or 6 of API Standard 1104 . . ."

You cite a situation where welders' radiograph inspection sheets submitted to document compliance with §192.229(c) were of 16-inch welds completed by two welders. You ask: "Does this meet the code requirements since the weld was completed by more than one welder?"

The intent of the requirement in §192.229(c) is for at least one entire weld to be tested and found acceptable under section 3 or 6 of API Standard 1104 within the preceding six calendar month period in order for the welder to continue to be qualified under §192.227(a). We agree with the observation in your letter that the welder needs to demonstrate the ability to weld in all welding positions.

Sincerely,

Richard D. Huriaux, P.E.

Director for Technology and Regulations

Office of Pipeline Safety

Regulation Sections