{"operation":"document","citation":"PI-74-0135","title":"Valentine, Fisher & Tomlinson — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-08-23","effective_on":null,"summary":"PI-74-0135 response to Valentine, Fisher & Tomlinson concerning 192.455.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0135.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0135.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0135","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-08-23_Valentine_192.455-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0135\nAugust 23, 1974\nWm. M. Valentine, Esq.\nValentine, Fisher & Tomlinson\n520 Lloyd Building\nSeattle, WA 98101\nDear Mr. Valentine:\nThis is in response to your letter of August 8, 1974, in Which you suggest that the word \"not” should be inserted in\nsections 192.455(d) and 192.457(a) to clarify that coated and tested pipe is acceptable without cathodic protection.\nThere is no error in the regulations as published. The intention of the regulations is that pipe must be cathodically\nprotected as well as coated. We hope this clarifies the matter for you.\nSincerely,\nOriginal signed by:\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nValentine, Fisher & Tomlinson\n520 Lloyd Building\nSeattle, Washington 98101\nAugust 8, 1974\nDirector, Office of Pipeline Safety\nDepartment of Transportation\n400 7th Street\nWashington, D.C. 20590\nDear Sir:\nRe: Title 49, Part 192\nCode of Federal Regulations_\nSection 192.455(2)(b)(c) and (d) (enclosed) do not appear to make sense unless the word \"not\" is inserted in the third\nline of (d).\nAlso Section 192.456(a) does not make sense unless the word \"not\" is inserted in the fifth line.\nIt appears that the intent was that the word \"not\" should be inserted as indicated above. In so doing, the exceptions\nspelled out in 192.455(b) and (c) make logical reading and allow properly coated and tested pipe acceptable without\ncathodic protection.\nCould you please advise if amendments (which are not available) have been issued or will be issued inserting the word\n\"not\" as it appears to be the intent?\nYours very truly,\nVALENTINE, FISHER & TOMLINSON\nWm. M. Valentine","truncated":false,"body_characters":1634}