Interpretation Response #PI-97-0103 ([Craig Company] [Mr. Paul V. Craig])

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

Interpretation Response Details

Response Publish Date: 10/31/1997

Company Name: Craig Company

Individual Name: Mr. Paul V. Craig

Location State: GA Country: US

View the Interpretation Document

Response text:

PI-97-0103

U.S. Department of Transportation
Research and Special Programs Administration

October 31, 1997

Mr. Paul V. Craig
Craig Company
Suite E
4260 Bankhead Highway
Lithia Springs, GA 30057

Dear Mr. Craig:

This responds to your letter of June 30, 1997, requesting clarification of a letter that we sent in 1983 regarding § 192.363. You note that § 192.363(b) states that "a soft seat valve may not be used if its ability to control the flow of gas could be adversely affected by exposure to anticipated heat." You further note that a 1983 interpretation letter sent from this office stated that "anticipated heat" refers to any possible source of heat to which a valve may be exposed, including fire that would make the valve inoperable. The primary standard that has been used to demonstrate the fire resistance of valves is 'Fire Test for Soft-Seated Ball Valves' API 607."

Your letter explains that you think that the reference to API 607 probably was used because it was the only standard at the time to demonstrate the capability of a soft seated valve in a fire, but that the standard was written for valves used at a wellhead in 1,400-1,800 degrees Fahrenheit for 30 minutes. You believe that such anticipated heat is too high for service line valves.

You state that the ASME BI6 subcommittee L has discussed but not yet balloted a proposal to specify the minimum extreme temperature for these valves should be 400 degrees Fahrenheit for one hour. You further argue that the requirement for soft seats in such valves to meet the fire resistance requirements in API 607 should not be appropriate to demonstrate that the valve complies with § 192.363.

Our response to the inquiry referencing the API 607 standard was only one example of an industry standard that has been used to demonstrate the fire resistance of valves; and as you suggest, it may not be an appropriate requirement today to demonstrate that a valve complies with § 192.363. The interpretation sent in 1983 does not preclude having the operator determine the anticipated heat using other industry standards, such as the standard that is currently under development in the ASME B16 subcommittee L.

I trust that this adequately responds to your question.

Sincerely,

Richard D. Huriaux
Director for Technology and Regulations
Office of Pipeline Safety

Regulation Sections