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Interpretation Response #PI-71-081 ([South Carolina Public Service Commission] [Ray M. Kightlinger])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: South Carolina Public Service Commission

Individual Name: Ray M. Kightlinger

Location State: SC Country: US

View the Interpretation Document

Response text:

Mr. Ray M. Kightlinger, Chief
Gas Department-Utilities Division
South Carolina Public Service Commission
P. O. Drawer 11649
Columbia, South Carolina 29211

Dear Mr. Kightlinger:

Thank you for your letter of September 17, 1971, requesting clarification of 49 CFR Section
192.455 relating to external corrosion control on buried or submerged pipelines installed after
July 31, 1971. You posed two questions:

"1. Paragraph 192.455(a)(1) indicates these pipelines must have an external protective
coating meeting the requirements of Paragraph 192.461. Does this mean all pipe
must be externally coated or merely that if it is externally coated it must meet these
requirements? (We assume intent to be that if the pipe is coated it must meet the
requirements but does not exclude the use of bare pipe.)"

"2. We interpret Paragraph 192.455(d) to mean that all externally coated pipe installed
after January 31, 1971, must be cathodically protected in accordance with
Paragraph 192.455(a)(2), thereby indicating that Subparagraphs(b) and (c) of
Paragraph 192.455 relate to bare pipe only. There are parties who disagree with
our interpretations and we would like your comments."

The answer to these questions is that Section 192.455(a) requires all new pipe to be externally
coated and cathodically protected in accordance with Section 192.461 and 192.463, unless that
pipeline falls within the exceptions provided in Section 192.455(b) and (c). In the event the
pipeline falls within the exceptions of paragraphs (b) and (c), there is no requirement for coating
or cathodically protecting the pipe. However, if the operator should voluntarily elect to externally
coat the pipe, the external protective coating must comply with Section 192.461, and under
Section 192.455(d), the pipeline must be cathodically protected as well.

We trust that this interpretation clarifies these sections for you. Should you have additional
questions please contact us.

Sincerely,

/signed/

Joseph C Caldwell
Acting Director
Office of Pipeline Safety

Regulation Sections

Section Subject
192.461 External corrosion control: Protective coating