{"operation":"document","citation":"PI-93-002","title":"Northern Illinois Gas — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1993-01-15","effective_on":null,"summary":"PI-93-002 response to Northern Illinois Gas concerning 192.619.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93002.pdf","body":"<<<PAGE 1>>>\n\nJanuary 15, 1993\nMr. Carl P. Hendrickson\nDirector Codes and Standards\nNorthern Illinois Gas\nP.O. Box 190\nAurora, IL 60507-0190\nDear Mr. Hendrickson:\nI apologize for taking so long to respond to your letter of September 21, 1992, in which you\ncommented on a statement we made in the withdrawal notice in Docket PS-115. The statement\nwas that the grandfather exception (49 CFR 192.619(c)) has practical effect only for pipelines in\nClass 1 locations because of the additional limits on maximum allowable operating pressure\n(MAOP) that §192.611 places on pipelines in more populated areas. You suggested the\nstatement should be corrected because it may mislead operators to believe the grandfather\nexception does not apply to certain distribution system segments.\nWe recognize that the statement disregards application of the grandfather exception to high\npressure distribution systems. However, we do not believe this oversight needs correction\nbecause §192.619(c) is not a new rule for which operators may need proper instruction on\ncompliance. It is widely used, longstanding provision that is clearly drafted to cover all pipeline\nsegments, including distribution segments.\nAlso, §192.621 is the primary rule governing the MAOP of high pressure distribution systems;\nand the grandfather exception does not apply under §192.621. So, even if an operator incorrectly\nassumes the grandfather exception does not apply to a particular distribution line segment, that\nassumption would not affect the operator's responsibility to meet §192.621. To illustrate, you\nmentioned that for some pipeline segments insufficient records may exist to substantiate\ncompliance with §192.621. In such case, the operator may not rest on the grandfather exception.\nInstead, the operator must appropriately test or inspect the segments to establish the data needed\nto meet §192.621.\nWe appreciate your concern about correct application of the pipeline safety standards. Please let\nme know if we can provide any further clarification.\nSincerely,\nCesar De Leon\nDirector, Regulatory Programs\nOffice of Pipeline Safety\ndal\\192\\619\\93-01-15","truncated":false,"body_characters":2125}