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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-82-0105

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name:

Location State: MO Country: US

View the Interpretation Document

Response text:

June 30, 1982

Mr. Dale W. Johansen
Assistant Director, Gas Department
Engineering Section
Missouri Public Service Commission
P.O. Box 360
Jefferson City, Missouri  65102

Dear Mr. Johansen:
We regret the delay in answering your letter about a compliance issue involving the Laclede Gas
Company.

As we understand your inquiry, it is whether Section 3(a)(1) of the Natural Gas Pipeline Safety Act
of 1968, as amended (49 USC 1672(a)(1)), permits retroactive application of the cathodic protection
standards in Subpart I of Part 192 to pipeline facilities in existence when the standards were
adopted.

Section 3(a)(1) provides that standards applying to emergency plans and procedures, extension,
operation, replacement, maintenance, subsequent inspection, or subsequent testing may be applied to
pipeline facilities in existence when the standards are adopted.  With respect to existing
facilities (installed before August 1, 1971), Subpart I requires the determination of areas
of active corrosion and the application of cathodic protection to these areas and to any repaired
or replaced areas, with subsequent inspection and testing to ascertain whether the cathodic
protection is working properly.  These requirements are examples of standards specifically
permitted by Section 3(a)(1) for replacement, maintenance, inspection, and testing of existing
pipeline facilities.  They are not standards which would require modification of a pipeline's
design to achieve compliance; and we agree that such standards would be forbidden by Section
3(a)(1).

Sincerely,

Melvin A. Judah
Acting Associate Director for
Pipeline Safety Regulation
Materials Transportation Bureau

Regulation Sections

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