{"operation":"document","citation":"PI-77-006","title":"Piedmont Natural Gas Company, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1977-02-02","effective_on":null,"summary":"PI-77-006 response to Piedmont Natural Gas Company, Inc. concerning 192.621.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-77-006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1977/PI77006.pdf","body":"<<<PAGE 1>>>\n\nFebruary 2, 1977\nMr. E. L. Manning\nVice President\nOperations Services\nPiedmont Natural Gas Company, Inc.\nP.O. Box 1968\nCharlotte, North Carolina 28233\nDear Mr. Manning:\nThis responds to your letter dated October 5, 1976, in which you ask for clarification of the\nrelationship between 49 CFR 192.619(a) and 49 CFR 192.621(a) regarding the maximum\nallowable operating pressure of pipelines in a high pressure distribution system.\nSection 192.619(a) prescribes the maximum allowable operating pressure for all steel and plastic\npipelines. Section 192.621(a) prescribes additional limitations which apply to pipelines in high\npressure distribution systems. In order to establish a maximum allowable operating pressure for a\nhigh pressure distribution pipeline, you must comply with the requirements of both sections.\nMore specifically, you have asked whether Section 192.619(a)(3) requires that pressure be limited\nto the highest actual operating pressure occurring during the 5 years preceding July 1, 1970.\nUnder the requirements of Sections 192.619(a) and 192.621(a), this limitation would apply only if\nit is the lowest pressure among those listed in the two sections and the pipelines concerned were\nnot tested or uprated as stated in Section 192.619(a)(3).\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\192\\621\\77-02-02\n1\n\n<<<PAGE 2>>>\n\nOctober 5, 1976\nMr. Cesar DeLeon\nActing Director\nOffice of Pipeline Safety Operations\nDepartment of Transportation\n2100 Second St., SW\nWashington, D.C. 20590\nDear Mr. DeLeon:\nPiedmont Natural Gas requests a clarification of the relationship between Sections\n192.619 and 192.621 of D.O.T. 192.\nWe have always felt that the two sections are independent, with 192.619 applying only to\npipelines in the traditional USAS B31.8 sense and not to a distribution system. We do not feel\nthat 192.619 was intended to supplement 192.621. In particular, we do not think the law requires\nus to limit distribution system pressures to the highest actual operating pressure to which the\nsegment was subjected during the 5 years preceding July 1, 1970. The interpretation in this area\nis quite important to us since the outcome could have a major impact on how Piedmont operates\nits distribution systems and the future flexibility of these systems.\nIt seems evident to us that if 192.619(3) was intended to apply to a high pressure\ndistribution system, it would have been repeated in 192.621, as 192.619(a)(1), (a)(6), and (b)\nwere repeated.\nWould you please consider this matter and advise us whether or not 192.619 applies to a\ndistribution system.\nSincerely,\nE. L. Manning, Vice President\ndal\\192\\621\\77-02-02\n2\n\n<<<PAGE 3>>>\n\nOperations Services\ndal\\192\\621\\77-02-02\n3","truncated":false,"body_characters":2742}