{"operation":"document","citation":"PI-74-0119","title":"Tennessee Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-05-30","effective_on":null,"summary":"PI-74-0119 response to Tennessee Public Service Commission concerning 192.195.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0119.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0119.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0119","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-05-30_Searcy_192.195-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0119\nMay 30, 1974\nMr. John Searcy\nTennessee Public Service Commission\nEngineering Division\nCordell Hull Building\nNashville, TN 37219\nDear Mr. Searcy:\nThank you for your letter of May 8, 1974, asking if the requirements in sections 192.619(b) and\n192.621(b) that pressure relief and limiting devices installed under those sections be installed in\naccordance with section 192.195 apply to pipelines constructed before November 12, 1970, since\notherwise section 192.195 does not apply to pipelines constructed before that date.\nSections 192.619 and 192.621 govern the operation of pipelines used in the transportation of gas.\nUnder the Natural Gas Pipeline Safety Act of 1968 (Act), standards governing the operation of\npipelines apply to pipelines existing when the standards are adopted as well was to pipelines\nconstructed thereafter. Sections 192.619 and 192.621 were adopted on November 12, 1970, and\napply to pipelines existing on that date.\nYou are correct that section 192.195 does not apply to pipelines constructed before November\n12, 1970. This section is a design requirement which under the Act may not apply to pipelines\nexisting when the standard was adopted on November 12, 1970. However, as referenced in\nsections 192.619(b) and 192.621(b), the provisions of section 192.195 govern the operation of\npipelines rather than design and are, therefore, a permissible regulation of existing pipelines.\nWe trust this satisfactorily responds to your inquiry.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nMay 8, 1974\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\n2100 2nd Street, SW\nWashington, D. C. 20590\nDear Mr. Caldwell:\n192.195(a) requires pressure relieving or limiting devices to prevent a maximum allowable\noperating pressure from being exceeded. 192.195, however, is not retroactive to existing\npipelines installed prior to November 12, 1970, unless changes have been made after that date.\n192.619(b) and 192.621(b) refer to 192.195, and are retroactive. Can it be concluded therefore\nthat, where 192.619(b) and 192.621(b) apply, 192.195 is retroactive and pressure relief or\nlimiting devices can be required on pipelines installed prior to November 12, 1970.\nIf 192.195 is not retroactive as described above, is there another section in the Minimum Safety\nStandards which is retroactive and requires pressure relief or limiting devices on pipelines\ninstalled prior to November 12, 1970?\nSincerely,\nJohn Searcy\nEngineering Division","truncated":false,"body_characters":2543}