{"operation":"document","citation":"PI-09-0014","title":"ExxonMobil Pipeline Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-08-18","effective_on":null,"summary":"PI-09-0014 response to ExxonMobil Pipeline Company concerning 195.567.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0014","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2009/PI-09-0014.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nAUG 1 8 2009\nMr. K. G. (Kevan) McCrae\nEnvironmental Coordinator\nExxonMobil Pipeline Company\n800 Bell Street - (PL-EMB-603B)\nHouston, TX 77002\nDear Mr. McCrae:\nOn January 30, 2009, you wrote to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) to request an interpretation of the corrosion control monitoring requirements in\n49 CFR Part 195 of the Federal pipeline safety regulations that apply to your Portland to Bangor,\nMaine pipeline system. You stated that you are requesting an interpretation of § 195.567(a)\nwhich requires electrical test leads for monitoring the adequacy of corrosion control. As a result\nof an April 2008 inspection of the Portland to Bangor pipeline system, on July 28,2008, the\nPHMSA Eastern Region issued a warning letter to ExxonMobil Pipeline Company (EMPCo) for\nnot following the requirements of § 195.567(a). The warning letter alleged that EMPCo\ncommitted a probable violation of § 195.567(a) by taking electrical readings directly from\nexposed piping in three specified locations rather than having test leads in place.\nYou expressed your disagreement with the interpretation reflected in the warning letter. You\nbelieve that test leads are only necessary when a pipeline and its appurtenances are not physically\naccessible to take cathodic protection readings. You stated that EMPCo's pipeline facilities are\nequipped with test leads where the pipelines and appurtenances are buried and inaccessible but\nnot where pipe and appurtenances were accessible. You stated that the pipeline in question is\n124.7 miles long and includes 95 total test points. Of the 95 test points, 17 pipe-to-soil readings\nare taken directly off the pipeline or its appurtenances and the remaining 78 pipe-to-soil readings\nare taken at test lead stations.\nYou further stated that: (1) you checked with other pipeline operators on this issue and all\noperators confirmed in taking direct readings where facilities are accessible on both gas and\nhazardous liquid pipelines as a standard industry practice; (2) EMPCo's previous and recent\nexperience with PHMSA have not identified its cathodic protection survey procedures as\ninadequate; and (3) PHMSA's regulations governing natural gas pipeline corrosion control\nmonitoring recognizes contact points other than test leads as legitimate (§ 192.469) and you\nbelieve there is no technical basis for treating a hazardous liquid pipeline differently. In\naddition, you provided an independent opinion letter by CC Technologies to support your\nassertion that taking pipe-to-soil readings where a pipeline is physically accessible is an\nacceptable practice.\n\n<<<PAGE 2>>>\n\n2\nEnsuring cathodic protection maintained at adequate levels is a key part of pipeline safety.\nPipeline operators are obligated to install and maintain test leads at intervals frequent enough to\nobtain measurements indicating the adequacy of cathodic protection. To the extent readings\nsufficient to indicate the adequacy of cathodic protection at a particular location can be obtained\nfrom exposed pipe and appurtenances, it is unnecessary to install test leads at that point.\nTherefore, taking readings directly from exposed pipe that is physically accessible is not a\nviolation of § 19S.S67(a). However, collecting cathodic protection readings directly from the\npipe has the potential to compromise the protective coatings on the pipe, subjecting that exposed\npipe to atmospheric corrosion. It is also important to recognize that test leads may be necessary\nfor certain portions of buried pipeline facilities, even though they are in close proximity to\nexposed pipe.\nI hope that this information is helpful to you. If I can further assist you with this or any other\npipeline safety regulatory matter, please contact me at (202) 366-4046.\nSincerely,\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, provides written clarification of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nExxonMobil Pipeline Company\n800 Bell Street - IPL-EMB-603B)\nHouston, Texas 77002\n713656 0227 Telephone\n713656 8232 Facsimile\nK. G. (Kevan) McCrae\nManager\nSafety, Health And Environment Department\nEJf(onMobii\nPipeline\nJanuary 30, 2009\nOffice of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nU. S. Department of Transportation\nEast Building, 2nd Floor\nMailstop: E24-455\n1200 New Jersey Avenue, SE\nWashington, D. C. 20590\nRe: Request for Interpretation\n49 CFR 195.567\nDear Sir:\nExxonMobil Pipeline Company (EMPCo) requests an interpretation of 49 CFR\n195.567(a), in response to a PHMSA Eastern Region Warning Letter dated July 28,\n2008.\nThe subject Warning Letter was issued subsequent to an April 2008 inspection of Mobil\nPipeline Company's Portland to Bangor, Maine pipeline system. It states that the\nPHMSA inspector observed probable violations of the referenced section of the\nHazardous Liquid Pipeline regulations during a field audit when\" ... ExxonMobii attached\nvoltmeter test lead to a flaw in coating of exposed piping to conduct pipe to soil tests to\nmonitor the effectiveness of the cathodic protection. The pipeline is subject to the\ncriteria in the regulation, necessitating the need for test leads since December 27,2004.\"\nThe correspondence additionally identifies 3 mainline valve locations where test leads\nwere absent.\nEMPCo respectfully disagrees with the foregoing interpretation of 49 CFR 195.567. The\nregulation states:\n195.567 Which pipelines must have test leads and what must I do to install and maintain\nthe leads?\n(a) General. Except for offshore pipelines, each buried or submerged pipeline or segment\nof pipeline under cathodic protection required by this subpart must have electrical test\nleads for external corrosion control. However, this requirement does not apply until\nDecember 27,2004 to pipelines or pipeline se9ments on which test leads were not\nrequired by regulations in effect before January 28, 2002.\nAn ExxonMobil Subsidiary\n\n<<<PAGE 4>>>\n\nIt is EMPCo's opinion that test leads are necessary when a pipeline and its\nappurtenances are not physically accessible to take cathodic protection readings.\nEMPCo's pipeline facilities are equipped with test leads where the pipelines and\nappurtenances are buried and inaccessible. EMPCo additionally takes cathodic\nprotection readings on accessible sites along the entire pipeline length; this can be at\npump stations, valve sites, manifolds, etc. EMPCo's cathodic protection survey\nprocedures are consistent with the preceding procedures and are documented in its\nFacilities Inspection and Maintenance Manual, Cathodic Protection Program:\nu ..• test points are defined as locations where cathodic\nprotection readings are taken. These locations may include\ntest lead wires, aboveground valves, valves in vaults, and\nother contact points on the structure. 11\nThe Portland to Bangor pipeline is 124.7 miles long and includes 95 total test points. Of\nthe total, 17 pipe to soil readings are taken directly off the pipeline or its appurtenances,\nwith the remaining 78 points read at test lead stations. EMPCo concludes the survey\nand its procedures comply with 49 CFR 195.567(a) and includes the following supportive\ninformation:\n• EMPCo solicited input from other pipeline operators and all confirmed similar\npractices, i.e., taking direct readings where facilities are accessible on both gas\nand hazardous liquid pipelines. EMPCo submits this is 'standard industry\npractice'.\n• EMPCo's previous and recent experiences with PHMSA have not identified its\ncathodic protection survey procedures as inadequate:\na. PHMSA conducted a 5 year review of EMPCo's Operating and\nMaintenance procedures during April 2007, including a thorough review\nof corrosion control procedures/programs and found no exception to\ncathodic protection survey procedures.\nb. Numerous field audits have included cathodic protection readings\nwitnessed by DOT/State inspectors. No inspector has articulated an\nobjection to taking direct readings on a hazardous liquid pipeline until the\nsubject audit in April 2008.\n• The PHMSA regulations governing natural gas pipeline corrosion control\nmonitoring recognize contact points other than test leads as legitimate\nmeasurement locations:\nPart 192 Transportation of Natural and Other Gas By Pipeline, Subpart I\nRequirements for Corrosion Control, Section 192.469 External Corrosion\nControl: Test Stations\nEach pipeline under cathodic protection required by this subpart must\nhave sufficient test stations or other contact points for electrical\nmeasurement to determine the adequacy of cathodic protection.\n\n<<<PAGE 5>>>\n\nEMPCo submits that there is no difference in this case between a natural gas\npipeline and a hazardous liquid pipeline; contact points (direct readings) can be\nutilized when pipeline facilities are accessible in addition to electrical readings\ntaken at test leads/stations.\n• EMPCo obtained a written opinion (copy attached) from CC Technologies, Inc,\nwhose principals are recognized subject matter experts in pipeline corrosion.\nCC Technologies, Inc.'s letter states, \"Based upon our review of the PHMSA\nwarning letter, an extensive review of the CP history and operating details of the\nEMPCo Portland Bangor Pipeline System, a review of EMPCo's Procedures and\nPractices, a review of applicable NACE Standards, standard industry practice,\nand published literature, we offer the following opinion regarding DOT's\nallegation of the need for test leads at each test point:\nThere is no fundamental technical basis nor regulatory basis for PHMSA to\nconclude that the use of aboveground pipeline appurtenances for contact points\nis inappropriate ..... \"\nIt is EMPCo's intent to conduct safe operations as a prudent operator. In our judgment,\nEMPCo's corrosion control annual measurement procedures are consistent with\nPHMSA's intent and regulations, and contribute to the overall safety and integrity of its\nfacilities. We would appreciate PHMSA's response and explanation pertaining to this\nimportant interpretation.\nIf you have questions or require additional information, please contact Cathey Casey at\n713-656-6913.\nK. G. (Kevan) McCrae\nSafety, Health, Environment Manager\nAttachment\n\n<<<PAGE 6>>>\n\n(I CC Technologies\na DNV company\nExxonMobil Pipeline Company (EMPCo)\nAttention: K.G. (Kevan) McCrae\nSafety, Health, Environment Manager\n800 Bell Street - (PL-EMB-603B)\nHouston, TX 77002\nCC TECHNOLOGIES INC.\n5777 Frantz Road\nDublin, Ohio 43017-1386, U.SA\nTel: (614)761-1214\nFax: (614)761-1633\n~ww ,gnv.CmIl\nwww.cctechnologies.com\nYour ref.:\nWarning Letter CPF I -2008-5003W\nOUf ref.:\n84084891\nDate:\nJanuary 29,2009\nTopic: Independent Opinion Letter for EMPCo - Allegation regarding test leads\nDear Mr. McCrae:\nThis document offers a written opinion on a PHMSA-alleged probable violation following an\naudit in the week of April 8, 2008, and listed in Warning Letter CPF 1-2008-5003W, dated\nJuly 28, 2008 from the U.S. Department of Transportation (DOT) - Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) to ExxonMobil Pipeline Company (EMPCo).\nReference is made to Pipeline Safety Regulations, Title 49, Code of Federal Regulations,\nPart 195 - Transportation of Hazardous Liquids by Pipeline, Subpart H - Corrosion Control.\nThe following text includes the paragraphs cited in the warning letter, gives background\ninformation available for the pipeline, cites references, provides opinions as to what is\nconsidered common industry practice, and offers an independent opinion regarding the validity\nofPHMSA's concerns.\n1. §195.567 Which pipelines must have test leads and what must I do to install\nand maintain the leads?\n(a) General. Except for offshore pipelines, each buried or submerged\npipeline or segment of pipeline under cathodic protection required by this\nsubpart must have electrical test leads for external corrosion control.\nHowever, this requirement does not apply until December 27, 2004 to\npipelines or pipeline segments on which test leads were not required by\nregulations in effect before January 28, 2002.\nDOT Allegation: During the field review of the pipeline, ExxonMobil attached the\nvoltmeter test lead to a flaw in the coating of exposed piping to conduct pipe-to-\nsoil tests to monitor the effectiveness of the cathodic protection. The pipeline is\nsubject to the criteria in the regulation, necessitating the need for test leads since\nDecember 27,2004.\nCC Technologies: The purpose of the described test is to establish if the cathodic protection (CP)\nsystem is functional, and the method of establishing electrical contact is a matter of convenience.\n\n<<<PAGE 7>>>\n\nIndependent Opinion Letter for EMPCo - DOT Allegation regarding test leads Page 2 of 5\nJanuary 29,2009 Project 84084891\nThe essence of making a pipe-to-soil potential measurement is to form a continuous electrical\ncircuit that includes the sample (pipe) to be measured, the electrolyte (soil), a reference\nelectrode, and a volt meter. As long as electrical continuity to the pipe is assured, the location of\nthe electrical contact should not affect the reading.\nThe following excerpts from standard corrosion texts are provided to show that common industry\npractice includes taking potential readings by contacting the closest, easily accessible point of\nelectrical conductivity, simply as a matter of convenience. Taking such potential readings is not\nin contradiction with a general requirement of having test leads for overall cathodic protection\nmonitoring for inaccessible areas such as buried structures. Obtaining a reading by making\nelectrical contact at a convenient aboveground location, such as a valve, is quite common.\nThe likely intent of the regulations is to prevent damage to the pipeline coating, by having\npermanent test leads installed. As described more than 20 years ago by John Morgan (1987)\n[Ref. 1], in his text book Cathodic Protection, it was common practice at that time to drive a steel\nprobe into the ground to contact a buried pipe. To achieve electrical contact, coating damage\nwas unavoidable. The following is an excerpt from Morgan's book: \"Many stroctures that are\ncathodically protected are inaccessible or difficult of access for the measurement of protection\npotentials. Perhaps the most common structure to which it is difficult to make an electrical\nconnection is a buried pipeline. The technique often adopted is to use a steel probe with a sharp\nhardened tip and to drive this through the ground to contact the pipe; where the pipe is laid near\nto the surface in soft ground and its position is accurately marked, this technique is successful.\nUnder other conditions it is preferable to attach permanent cathode leads to the pipe and to\nbring these to the surface at marker posts. The leads are usually welded or brazed to a pad or\nstud on the pipeline and this junction and the electric cable are insulated. More than one lead\nmay be brought to the surface and these may be connected to either end of a calibrated section of\nthe line so that current flow in the pipeline may be determined. Similarly, the connections\nbetween a sacrificial anode and the strocture can be brought to the surface so that the anode\ncurrent can be measured. It is usual to use an 'elephants's foot, ' concrete pillar or similar\ndevice both to hold these connections and to indicate the location of the structure. The majority\nof other stroctures will be accessible so that electrical connections can be made to them.\" The\npoint of highlighting this section of text is to show that in the past, pipeline coating damage was\nunavoidable, unless permanent test leads were installed. In EMPCo' s pipeline, the aboveground\nvalves are easily accessible appurtenances that do not have that risk of pipeline coating damage,\nand thus are suitable for making electrical contact for a pipe-to-soil potential test.\nAllen and Barnes, in Pipeline Rules of Thumb Handbook (2005) [Ref. 2], chapter on Advances\nin Pipeline Protection - Specialized Corrosion Surveys for Buried Pipelines: Methods\nExperience wrote: \"The performance of the cathodic protection system is usually assessed by\nregular monitoring of pipe-to-soil potentials at selected intervals along the pipeline. .... Under\nmost circumstances, such measurements at selected locations will provide an acceptable\nindication of the overall level of corrosion protection being achieved on the pipeline. These\nmeasurement locations, ... are generally selected for ease of access ... \"\n49CFR195 includes by reference Standard Practice NACE SP0502 (2002) [Ref. 3]. Paragraph\nA4.5.1 on Typical Methodology for Close-Interval Potential Surveys reads \"An insulated wire is\nCC TECHNOLOGIES, INC. II\nMANAGING RISK '~¢tJa\n\n<<<PAGE 8>>>\n\nIndependent Opinion Letter for EMPCo - DOT Allegation regarding test leads Page 3 of 5\nJanuary 29,2009 Project 84084891\nelectrically connected to a test station, valve, or other electrically continuous pipeline\nappurtenance and one terminal of the voltmeter. The other terminal of the voltmeter is attached\nto the reference electrode to be used for the potential measurements. \"\nThe Appalachian Underground Corrosion Short Course - Advanced Course (2008) curriculum -\nChapter 1, Pipe-To-Soil Potential Surveys and Analysis [Ref. 4J echoes NACE SP0502: \"The\nconnection to the structure under test can be a valve, riser pipe, test station, etc., any point\nelectrically continuous with that portion of pipe being evaluated. \"\nSimilarly, Peabody's text book on Control of Pipeline Corrosion (2001) [Ref. 5J lists as one of\nthe items of information typical to be accumulated before starting a field survey: \"* Location\nand construction details of all corrosion test points that have been installed along the line. If no\ntest points have been installed for corrosion test purposes, determine locations where contact\ncan be made with the pipeline for test purposes (other than by driving contact bars down the\npipe).\" The author does not mention the need for test leads to establish electrical contact to the\npipeline.\nMohitpour et ai. in their text book on Pipeline Operation & Maintenance (2005) [Ref. 6J describe\nthe installation procedures for test leads pipelines below finished grade. They write: \"Test leads\nprovide a quick and easy metallic connection for measuring potentials on buried structures such\nas pipelines, casing, and flanges. They also provide a location where the cathodic protection\ncurrent can be measured and controlled if desired. At pipeline crossings they provide a metallic\nconnection to both pipelines to measure potentials or existing inteifering currents.\" The text\ncontains no mention of completing test lead electrical connections above grade.\nA second textbook by Mohitpour et aI., on Pipeline Design & Construction (2007) [Ref. 7]\nchapter on Pipeline Protection - Cathodic Protection Monitoring, describes the test to be done at\n\"some type of metallic connection.\" The referenced paragraph reads: \" ... corrosion technicians\nuse special instruments to monitor cathodic protection. This is carried out by measuring the\npipe-to-soil potential difference using a high-input impedance potentiometer with a reference\ncell (usually a saturated copper/copper sulfate reference cell) and some type of metallic\nconnection to the pipeline - a test lead.\" This text does not appear to preclude making a\nconnection to an accessible electric connection point, such as an aboveground valve.\nVon Baeckmann et al. in Handbook of Cathodic Corrosion Protection [Ref. 8] describe Test\nPoints, by writing: \"In general, NYY-O cable is used with a minimum copper cross-section of\n2 x 2.5 mm. The cable is connected to the pipeline by a suitable process, and the connections\ncarefully coated. The cable is usually connected to aboveground test points and covered with\nhoods, tiles or a cable ribbon.\" In this text, it is implied that the pipeline is completely\nunderground, and thus test leads to aboveground test points are needed. In the following\nparagraphs, then, the authors explain how to install the ends of the test leads either aboveground\nor belowground, as follows: \"Aboveground test points are usually installed in marker posts with\na closable flap. The measuring cable is attached to a plastic plate with terminals.\" and\n\"Belowground test points should be installed in built-up areas only in exceptional\ncircumstances. In this case watertight, flush-mounted test stations are installed under a street-\nlevel covering and can be kept dry only by the most careful construction.\" Note that these latter\nCC TECHNOLOGfES, INC. II\nMANAGING RISK GUN\n\n<<<PAGE 9>>>\n\nIndependent Opinion Letter for EMPCo - DOT Allegation regarding test leads Page 4 of 5\nJanuary 29,2009 Project 84084891\nsentences do not refer to aboveground accessible appurtenances, which do not require test leads\nto make electrical contact for measuring pipe/soil potentials.\nAs stated earlier, the location of electrical contact (allowing for voltage drop considerations)\nshould not affect the reading, and the above-referenced texts do not indicate otherwise.\nDOT Allegation: The inspector observed the lack of test leads during the field review at the\nmainline valve stations Meadow Lane (MP 116.6), Winter Port (MP 110.9) and at Litchfield\n(MP 52.52).\nCC Technologies: CC Technologies reviewed EMPCo-provided data for the EMPCo Portland to\nBangor pipeline, including length of line, total number and locations of test points, number and\nlocation of test leads, number and location of other test points, rectifier and anode bed locations,\nand annual survey results for the period, 1990 through 2008. The CP data show consistent\nreadings for the locations with and without lead wires.\nThe absence of test leads at specific locations should only be of concern if a lead was specified\nfor that location. The locations identified by the auditor were at three of the valves, and those are\nnot specified to have leads because electrical contact can be made aboveground. EMPCo' s\nFIMMS [Ref. 9] manuals on Cathodic Protection and Close-interval Surveys, include the\nfollowing statement: \"For the purposes of this document, test points are defined as locations\nwhere cathodic protection readings are taken. These locations may include test lead wires,\naboveground valves, valves in vaults, and other contact points on the structure. \"\nFollowing this definition of test points, a corrosion technician is allowed to take the pipe-to-soil\npotentials at locations that do not have test leads.\nOPINION\nBased upon our review of the PHMSA warning letter, an extensive review of the CP history and\noperating details of the EMPCo Portland Bangor Pipeline System, a review of EMPCo's\nProcedures and Practices, a review of applicable NACE Standards, standard industry practice,\nand published literature, we offer the following opinion regarding DOT's allegation of the need\nfor test leads at each test point:\nThere is no fundamental technical basis nor regulatory basis for PHMSA to conclude that the use\nof aboveground pipeline appurtenances for contact points is inappropriate. A pipe-to-electrolyte\npotential measurement requires a contact point or point of connection to the pipeline for one part\nof the measurement circuit. Any metallic point of sufficient electrical continuity with the\npipeline can serve this purpose. Metallic contact points have been successfully used by the\nauthors of this letter on regulated and unregulated structures to evaluate corrosion activity and to\nassess the efficacy of cathodic protection for over 34 years in practice as corrosion engineers.\nThis practice can be documented for at least 50 years prior to that. It is common industry\npractice to assess cathodic protection in booster pump stations, terminals, tank farms and\nrefineries where there are abundant aboveground piping contact points and negligible or no wire\ntest leads without ever compromising the integrity of the measurement in any way.\nCC TECHNOLOGIES, INC. II\nMANAGING RISK GWlii\n\n<<<PAGE 10>>>\n\nIndependent Opinion Letter for EMPCo - DOT Allegation regarding test leads Page 5 of 5\nJanuary 29,2009 Project 84084891\nThe regulatory requirement for test leads attached to an underground pipeline is intended to\nensure that where there are insufficient aboveground contact points, test leads are installed to\nfacilitate gathering the measurements and data to establish the overall level of protection\nafforded the pipeline under investigation. We conclude that tests can be conducted with no test\nleads, at points where electrical contact can be readily made, without compromising the\nmeasurements from which to determine the efficacy of the cathodic protection system.\nThus, CC Technologies finds no basis for PHMSA's warning.\nRespectfully,\nKevin C. Garrity, P.E.\nHead of Section\nMichiel P. Brongers, P.E.\nSr. Project Manager\nREFERENCES\n1. John Morgan, \"Cathodic Protection\", 2nd edition, Chapter 10 - Instruments for Cathodic\nProtection, pp. 481-482, Monitoring - Test Points, NACE, 1987.\n2. Pipeline Rules of Thumb Handbook, 6th edition, Edited by E. W. McAllister, Chapter\n\"Advances in Pipeline Protection - Specialized Corrosion Surveys for Buried Pipelines:\nMethods Experience\", authors: M. D. Allen and N. R. Barnes, p. 239, Gulf Professional\nPublishing, Butterworth-Heinemann, 2005.\n3. NACE SP0502-2008 (formerly RP0502-2002), \"Standard Practice - Pipeline External\nCorrosion Direct Assessment Methodology\", NACE International, Houston, TX, Item\nNo. 21097.\n4. Curriculum Text to \"Appalachian Underground Corrosion Short Course (AUCSC) -\nAdvanced Course\", Education and Training for Corrosion Control, Chapter 1 - Pipe-To-\nSoil Potential Surveys and Analysis, page 1-2, West Virginia University, Morgantown,\nWV, Revision 2008.\n5. A.W. Peabody, \"Control of Pipeline Corrosion\", 2nd edition, Edited by R.L. Bianchetti,\nChapter 5 - Survey Methods and Evaluation Techniques, p. 66, NACE, 2001.\n6. M. Mohitpour, 1. Szabo, and T. Van Hardeveld, \"Pipeline Operation & Maintenance - A\nPractical Approach\", Chapter 4 - Pipeline System Maintenance - 4.6.2.2. Cathodic\nProtection, p. 192, ASME Press, 2005.\n7. M. Mohitpour, H. Golshan, and A. Murray, \"Pipeline Design & Construction - A\nPractical Approach\", Third Edition, Chapter 10 - Pipeline Protection - Cathodic\nProtection Monitoring, p. 535, ASME Press, 2007.\n8. W. Von Baeckmann, W. Schwenk, and W. Prinz, Handbook of Cathodic Corrosion\nProtection, 3rd Edition, Chapter 10 - Pipelines, 10.3.2 Test Points, p. 276, 1997.\n9. ExxonMobil Pipeline Company FIMMS Manual, Facilities Inspection & Maintenance\nManagement System, Corrosion Programs - Chapter 2. Cathodic Protection and\nChapter 3. Close Interval Surveys.\nCC TECH~OLOGIES, INC.\nMANAGING RISK","truncated":false,"body_characters":27160}