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good afternoon fine people: Federal DOT 49 CFR Parts 191, 192, 195 regs

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StockTank2

Petroleum
Joined
Apr 27, 2016
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6
Location
US
I am an operator in OHIO, USA (go bucks!) Mostly Utica gas production and midstream stations.
We have been AUDITED by a DOT inspector who is claiming OHIO has now adopted DOT 49 CFR Parts 191,192,..etc. Fine.
Thing is, at our compressor stations vessels are all ASME 31.3 tested to 1.3 X MAWP. The DOT code says "a component having a design pressure established in accordance with paragraph (a) or paragraph () of this section and subject to the strength testing requirements of 192.505 (b) must be tested to at least 1.5 times MAOP"
So all of our vessels on compressor packages are not stamped with MAOP but with MAWP. (this is first contention).
Second, is this DOT requirement to 1.5 MAOP even applicable to vessels within a compressor package?
thanks y'all
 
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