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Interpretation Response #PI-76-016 ([Corrosion Associates] [Richard B. Bender])

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

Interpretation Response Details

Response Publish Date:

Company Name: Corrosion Associates

Individual Name: Richard B. Bender

Location State: TX Country: US

View the Interpretation Document

Response text:

April 8, 1976

Mr. Richard B. Bender
Corrosion Associates
P.O. Box 11302
Fort Worth, Texas 76110

Dear Mr. Bender:

In your letter of March 31, 1976, you ask whether the exemptions
contained in Section 192.455 apply to pipelines which are subject
to the requirements of Section 192.457. We presume the question
arises from the wording of Section 192.457 which provides that
certain pipelines must be cathodically protected "in accordance
with this subpart."

By its terms, Section 192.455 specifically applies to pipelines
installed after July 31, 1971. Likewise, Section 192.457
specifically applies to pipelines installed before August 1, 1971.

This distinction in the scope of the two sections indicates that
the exemptions under Section 192.455 are intended to apply only to
pipelines installed after July 31, 1971.

In Section 192.457, the phrase "in accordance with this subpart" is
not intended to reference the exemptions from the cathodic
protection requirement of Section 192.455. This is particularly
true in light of the analogous usage of the phrase in Section
192.455 where exemptions are otherwise set forth. Rather, in both
sections the phrase is grammatically used to describe the
requirement for cathodic protection. The phrase indicates that
other regulations in Subpart I, namely Section 192.463, govern the
protection which must be provided.

Sincerely,

'signed'

Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections

Section Subject
192.455 External corrosion control: Buried or submerged pipelines installed after July 31, 1971
192.457 External corrosion control: Buried or submerged pipelines installed before August 1, 1971