{"operation":"document","citation":"PI-74-021","title":"Middle Tennessee Natural Gas — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-03-18","effective_on":null,"summary":"PI-74-021 response to Middle Tennessee Natural Gas concerning 192.603, 192.63.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-021.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-021.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-021","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/PI74021.pdf","body":"<<<PAGE 1>>>\n\nMr. Stephen C. Stinson\nMiddle Tennessee Natural Gas\nUtility District\nP. O. Box 231\nSmithville, TN 37166\nDear Mr. Stinson:\nThan you for your letter to Mr. Frank Fulton of February 12, 1974. In response to the questions\nyou ask, we offer the following:\nQuestion: In section 192.63 you say each piece of pipe must be marked. What happens when this\nis covered by coating?\nAnswer: The intent of the regulation is that the product, pipe, fitting, etc., be clearly identified\nfrom point of manufacture to installation. Where pipe is coated before installation, covering the\nmarking, the coated pipe must be remarked unless some other means of identification permitted\nby section 192.63 is used.\nQuestion: If the specifications of the pipe are listed on the bill of lading and the original purchase\norder, is a blanket identification sufficient?\nAnswer: A blanket identification where permitted under section 192.63 is sufficient only if the\nitems involved are clearly identified from point of manufacture to installation, as when all items so\nidentified are used at a single installation. Where individual items covered by a blanket\nidentification are used separately, each item must be marked exclusive of the blanket\nidentification.\nQuestion: How have people maintained marking that was put on the coating? As you know,\nultra violet light attacks PVC and ink on it. Do you require identification to be maintained on\ncoal tar? If so, how do you identify field coated pipe?\nAnswer: For coated pipe in short term storage or protected storage , a marking on the coating or\ncoating wrapper will normally remain legible until installation. For coated pipe in long term\nstorage, marking is usually maintained by painting the pipe inside each end. Also, some operators\npaint a color code on pipe. It is an operator's responsibility to use markings that will identify\nmaterial until it is installed. Section 192.63 does not require that markings be maintained after\ninstallation, but materials used in any segment of pipeline must be identifiable for the life of the\nDB\nC:\\WP51\\INTERPRT\\192\\603\\74-03-18\n1\n\n<<<PAGE 2>>>\n\nfacility to ensure proper operation and maintenance. This is accomplished by maintaining\nappropriate records.\nWe hope that his sufficiently answers your questions. If we may assist further, please let us know.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nDB\nC:\\WP51\\INTERPRT\\192\\603\\74-03-18\n2\n\n<<<PAGE 3>>>\n\nFebruary 12, 1974\nMr. Frank Fulton, Chief Engineer\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D. C. 20590\nDear Frank:\nReally enjoyed your discussion in Nashville but I have a few questions concerning marking.\n1. In section 192.63 you say each piece of pipe must be marked. What happens when\nthis is covered by coating?\n2. If the specifications of the pipe are listed on the bill of lading and the original\npurchases order, is a blanket identification sufficient?\n3. How have people maintained marking that was put on the coating? As you know,\nultra violet light attacks PVC and ink on it? Do you require identification to be\nmaintained on coal tar? If so, how do you identify field coated pipe?\nYour comments would be appreciated.\nSincerely,\nMIDDLE TENNESSEE UTILITY\nStephen C. Stinson\nDB\nC:\\WP51\\INTERPRT\\192\\603\\74-03-18\n3","truncated":false,"body_characters":3307}