Valentine, Fisher & Tomlinson — Pipeline Safety Interpretation

Page 1PI-74-0135 August 23, 1974 Wm. M. Valentine, Esq. Valentine, Fisher & Tomlinson 520 Lloyd Building Seattle, WA 98101 Dear Mr. Valentine: This is in response to your letter of August 8, 1974, in Which you suggest that the word "not” should be inserted in sections 192.455(d) and 192.457(a) to clarify that coated and tested pipe is acceptable without cathodic protection. There is no error in the regulations as published. The intention of the regulations is that pipe must be cathodically protected as well as coated. We hope this clarifies the matter for you. Sincerely, Original signed by: Joseph C. Caldwell Director Office of Pipeline Safety#

Page 2Valentine, Fisher & Tomlinson 520 Lloyd Building Seattle, Washington 98101 August 8, 1974 Director, Office of Pipeline Safety Department of Transportation 400 7th Street Washington, D.C. 20590 Dear Sir: Re: Title 49, Part 192 Code of Federal Regulations_ Section 192.455(2)(b)(c) and (d) (enclosed) do not appear to make sense unless the word "not" is inserted in the third line of (d). Also Section 192.456(a) does not make sense unless the word "not" is inserted in the fifth line. It appears that the intent was that the word "not" should be inserted as indicated above. In so doing, the exceptions spelled out in 192.455(b) and (c) make logical reading and allow properly coated and tested pipe acceptable without cathodic protection. Could you please advise if amendments (which are not available) have been issued or will be issued inserting the word "not" as it appears to be the intent? Yours very truly, VALENTINE, FISHER & TOMLINSON Wm. M. Valentine#