Interpretation Response #PI-74-0119 ([Tennessee Public Service Commission] [Mr. John Searcy])

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

Interpretation Response Details

Response Publish Date: 05/30/1974

Company Name: Tennessee Public Service Commission

Individual Name: Mr. John Searcy

Location State: TN Country: US

View the Interpretation Document

Response text:

May 30, 1974

Mr. John Searcy
Tennessee Public Service Commission
Engineering Division
Cordell Hull Building
Nashville, TN  37219

Dear Mr. Searcy:

Thank you for your letter of May 8, 1974, asking if the requirements in sections 192.619(b) and 192.621(b) that pressure relief and limiting devices installed under those sections be installed in accordance with section 192.195 apply to pipelines constructed before November 12, 1970, since otherwise section 192.195 does not apply to pipelines constructed before that date.

Sections 192.619 and 192.621 govern the operation of pipelines used in the transportation of gas.  Under the Natural Gas Pipeline Safety Act of 1968 (Act), standards governing the operation of pipelines apply to pipelines existing when the standards are adopted as well was to pipelines constructed thereafter.  Sections 192.619 and 192.621 were adopted on November 12, 1970, and apply to pipelines existing on that date.

You are correct that section 192.195 does not apply to pipelines constructed before November 12, 1970.  This section is a design requirement which under the Act may not apply to pipelines existing when the standard was adopted on November 12, 1970.  However, as referenced in sections 192.619(b) and 192.621(b), the provisions of section 192.195 govern the operation of pipelines rather than design and are, therefore, a permissible regulation of existing pipelines.

We trust this satisfactorily responds to your inquiry.

Sincerely,

Joseph C. Caldwell
Director
Office of Pipeline Safety

Regulation Sections