{"operation":"document","citation":"PI-75-031","title":"Tennessee Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-06-24","effective_on":null,"summary":"PI-75-031 response to Tennessee Public Service Commission concerning 192.63.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-031.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-031.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-031","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1975/PI75031.pdf","body":"<<<PAGE 1>>>\n\nJune 24, 1975\nMr. John Searcy\nTennessee Public Service Commission\nCordell Hull Building\nNashville, Tennessee 37219\nDear Mr. Searcy:\nThis responds to your letter of June 10, 1975, referring to our opinion that \"a violation of Section\n192.63 occurs when a component which is not marked...is used in a pipeline...\" You state to the\ncontrary that a marking violation can never occur in light of our interpretation that \"Section\n192.63 does not require that markings be maintained after installation.\"\nIt does not follow that because markings need not be maintained after installation, Section 192.63\ncannot be violated. Like the design requirements in Part 192, the marking requirement is one\nwhich must be met before a pipeline is placed in operation. It does not have continuing\napplication thereafter. Still, because the regulations in Part 192 apply to pipeline facilities actually\nused in the transportation of gas, a person cannot be charged with a violation of Section 192.63\nuntil a component not marked as required is placed in operation.\nStrictly speaking, in the case of a violation of Section 192.63, Section 192.13 should also be\nincluded in stating the violation. That Section makes it clear that a person may not operate a\npipeline unless all applicable requirements in Part 192 are met.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192.1-b\\63\\75-06-24","truncated":false,"body_characters":1401}