Marking of materials

Marking of materials is required for gas pipelines under §192.63.  Marking is a critical aspect of the design and construction of a system as it provides an operator with verification that the correct materials are used.  It also becomes important in a failure investigation to assist in determining the exact type of pipe or component that failed.

The following interpretation published in the OPSO Advisory Bulletin No. 76-3 discusses several aspects of marking.  The specifics of question #3 may be a bit dated, the the underlying compliance concepts still apply.

WinDOT subscribers have access to all the OPSO Newsletters from the start page of the Regulatory Reference module.

Interpretation 192.63  19
OPSO Advisory Bulletin No. 76-3          March, 1976      Page 3

Relates to 49 CFR, §192.63

Question 1:  “Is it the intent of Section 192.63 to include nipples and fittings used in meter sets – even those downstream of the regulator with operating pressure of 7″ W.C.?”
Answer:  As stated in paragraph (a) of Section 192.63 and Section 192.51, each valve, fitting, pipe, or other component used in a pipeline to which Section 192.63 applies must meet the marking requirements of that Section.  The fittings in a meter set are expressly covered by Section 192.63; as components of a pipeline, nipples are also subject to the marking requirements.

Your question indicates some doubt about the jurisdiction of Part 192 over pipelines downstream of a regulator.  As indicated by the definition of “service line” in Section 192.3, the jurisdiction of Part 192 extends to (and incudes) a customer meter or the connection to a customer’s piping whichever is farther downstream.  This jurisdictional limit is irrespective of the location of a regulator or the gas pressure involved.

Question 2:  “At what point does a violation of 192.63 occur–when an unmarked fitting is purchased, then it is placed in warehouse stock, or when it is actually used in a gas system?”
Answer:  A violation of Section 192.63 occurs when a component which is not marked in accordance with that Section is used in a pipeline to which Section 192.63 applies.

Question 3:  “Assume a meter was placed in service in 1965.  If this meter is removed, does Section 192.63 prohibit the reuse of these pipe fittings due to inability to determine manufacturer and specification?”

Answer:  As provided by Section 192.13, Section 192.63 applies to components use in a pipeline which is readied for service after March 12, 1971, or replaced, relocated, or otherwise changed after November 21, 1970.  If a meter installed in 1965 is removed from a pipeline, Section 192.63 would not apply to the continued use in the same location of the accompanying pipe fittings because they are not replaced, relocated, or otherwise changed.  However, the fittings could not be used in a different location unless the requirements of Section 192.63 are met, including, if Section 192.63(d) applies, the requirements that the manufacturer be identifiable.

Question 4:  “Would not the intent of 192.63 be met if components were marked or color coded to indicate the maximum allowable operating pressures to which they may be used, that is:  red for pressures to 600 PSI, blue for pressures to 300 PSI, etc?”
Answer:  Section 192.63 requires, except for certain items manufactured before November 21, 1970, that a component be marked as prescribed in the specification or standard to which it was manufactured, or “Standard Markings for Valves, Fittings, Flanges and Unions,” MSS Standard Practice, SP-25.  Color coding of components, as your describe, would not comply with Section 192.63 because it does not meet the requirements of applicable specifications or standards to which components are manufactured or MSS Standard Practice, SP-25.  Of course, in addition to the required markings, an operator may voluntarily use color coding to mark components for any purpose other than compliance with the requirements of Section 192.63.

Thank you for your interest in pipeline safety.  If we can be of further assistance, please contact us.

Sincerely,

Joseph C. Caldwell
Director
Office of Pipeline Safety

All this and more in WinDOT, The Pipeline Safety Encyclopedia.

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