Interpretation Response #PI-81-0108
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
July 10, 1981
Mr. Louis C. Baldacci, Jr. Vice President
The Peoples Gas Light & Coke Co.
122 South Michigan Avenue
Chicago, IL 60603
Dear Mr. Baldacci:
This refers to your letter of April 22, 1981, in which you request a determination that a
particular pipeline that now transports naphtha from the Union 76 refinery to an SNG plant may be
used to transport alternately naphtha and refinery gas.
The applicable Federal regulations governing the transportation of naphtha by pipeline in
interstate commerce are set forth in 49 CFR Part 195. Regulations governing the pipeline
transportation of gas in or affecting interstate commerce are in 49 CFR Part 192. These regulations
do not preclude a pipeline from being used in the manner your have proposed, provided the
applicable requirements of each set of regulations are met.
In this regard, the pipeline need not meet each design and construction requirements of Part 192,
that would otherwise apply to a pipeline newly readied for gas service, if it is qualified for use
under the conversion rules of §192.14. Note that this section would require that the pipeline be
pressure tested under Subpart J, even though it has been tested previously under Part 195. The MAOP
for gas service would be determined under
§192.619 based on the new pressure test.
The regulations do not require notification of the proposed changeover.
Melvin A. Judah
Acting Associate Director for
Pipeline Safety Regulation
Materials Transportation Bureau
|§ 192.14||Conversion to service subject to this part|