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Interpretation Response #PI-96-0100 ([Americas Marketing Group, Inc.] [Mr. Mike T. Deason])

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

Interpretation Response Details

Response Publish Date:

Company Name: Americas Marketing Group, Inc.

Individual Name: Mr. Mike T. Deason

Location State: AL Country: US

View the Interpretation Document

Response text:


March 4, 1996

Mr. Mike T. Deason
Americas Marketing Group, Inc.
P. 0. Box 100849
Birmingham, Alabama 35210

Dear Mr. Deason:

This is in response to your recent letters, in which you requested an interpretation of 49 CFR §192.145, in regards to testing valves. As you noted in your letter, Section 192.145 requires that valves meet the minimum requirements, or equivalent, of API 6D.

According to your letter, in your conversation with the American Petroleum Institute you were told that there was no accepted equivalent to the hydrostatic test listed in API-6D. You also indicated that you were unable to get written statements from the American National Standards Institute (ANSI) and the Manufacturers Standardization Society (MSS) that the testing requirements for valves in their standards were equivalent to API 6D standard. This lead you to conclude that there were no equivalent testing requirements to API 6D. Therefore, you requested interpretation of "or equivalent" in Section 192.145, and request that we advise you of an equivalent to the hydrostatic test.

Published standards do not cover all types and sizes of valves that are manufactured. However, there are certain basic safety features that can be applied to all valves. In Section 192.145, the word "or equivalent" is used in the sense of accepting another standard that provides an equivalent level of safety to API 6D, including quality control and inspection to API 6D. The term "or equivalent" is not necessarily used with regard to hydrostatic or air test or any other specific features of industry standards. Other nationally recognized testing and valve standards such as API 598, Valve Inspection and Testing, API 608, Metal Ball Valves - Flanged and Butt-weld Ends, and MSS-SP-61, Pressure Testing of Steel Valves, allow the use of air as the test medium. In addition, we have enclosed a copy of Technical Report NE-169, "Weldball Valve Leakage Analysis, Air versus Water" supplied by Kerotest Manufacturing Corporation, that may help you in identifying equivalent standards, such as ISO 5208 that is referenced in the report.

By not restricting minimum requirements to meet only API 6D standard, we are, in fact encouraging new developments in manufacturing and testing of valves, due to the changes in technology.

We trust that this interpretation will answer any question you might have.



Richard B. Felder
Associate Administrator
for Pipeline Safety

State of Florida
Public Service Commission
Capital Circle Office Center
2540 Shumard Oak BLVD
Tallahassee, FL 32399-0850

February 28, 1996

Mike T. Deason, President
Americas Marketing Group, Inc.
& M. T. Deason Company, Inc.
P.O. Box 100849
Birmingham, Alabama 35210

Re:  Information Request Regarding Code of Federal Regulations, 192.145 Valves

Dear Mr. Deason:

The Commission has a rule, 25-12.028, Florida Administrative Code, requiring the marking of materials used in natural gas pipelines. This rule states that each valve must be clearly marked as prescribed in the specification or standard, to which it was manufactured.

The Code of Federal Regulations (CFR), Part 192.145 Valves, requires valves to meet the minimum requirements of the American Petroleum Institute (API), Specification 6D, "Specification for pipeline Valves (Gate, Plug, Ball, and Check Valves)" (20th edition, 1991). Hydrostatic pressure testing of valves is the minimum required by API 6D. The American Petroleum Institute has recently reaffirmed its minimum hydrostatic testing requirements for valves to the natural gas industry.

Florida law requires valves to be marked, using the specification of the standard by which they are manufactured, and API 6D is the only approved standard at this time. This may change if the United States Department of Transportation or the American Petroleum Institute are forthcoming with additional information.

If you have any further questions, contact me at (904) 413-6650.


C. Edward Mills, Supervisor
Engineering and Safety
Bureau of Gas Regulation

American Petroleum Institute
Exploration & Production Department
1220 L Street, NW
Washington, DC 20005
Phone: (202) 682-8000
Fax: (202) 682-8426

J. D. Greer
Senior E&P Associate
Direct Line: (202) 682-8494

February 16, 1996

Mr. Mike Deason, President
Americas Marketing Group Inc.
PO Box 100849
Birmingham, AL 35210

Re:  API Spec 6D, Specification for Pipeline Valves (Gate, Plug, Ball and Check Valves), 21st Edition, March 31, 1994

Dear Mr. Deason:

Per our telephone conversation today, this confirms that API Spec 6D requires hydrostatic shell testing, and has no provision for air testing in lieu of hydrostatic testing. This is clearly shown in Par. 5.1 and 5.2 of Section 5, "Tests" as shown below with underlining added for emphasis:

5.1 Pressure Tests. Each valve shall be tested as set out in this section prior to shipment from the manufacturer's works. These tests shall be performed in accordance with the manufacturer's written procedures. The manufacturer shall complete shell pressure tests before painting the valves. Tests shall be made in the sequence shown in the following paragraphs. Additional tests such as those in Appendix C may be performed by the manufacturer, after the tests in Sections 5.2 and 5.3 unless otherwise noted in Appendix C.

5.2 Shell Test. Valves shall be subjected to a hydrostatic shell test....

Appendix C allows hydrostatic testing at higher pressures or for longer times than specified in Section 5.2 (Par. C2), but has no provision for air shell testing.


Regulation Sections

Section Subject
192.145 Valves