{"operation":"document","citation":"PI-72-011","title":"Wisconsin Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1972-03-03","effective_on":null,"summary":"PI-72-011 response to Wisconsin Public Service Commission concerning 192.465.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-011","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1972/PI72011.pdf","body":"<<<PAGE 1>>>\n\nMarch 3, 1972\nMr. R. E. Purucker\nChief Engineer\nWisconsin Public Service Commission\nMill Farms State Office Building\nMadison, Wisconsin 53702\nDear Mr. Purucker:\nThis will acknowledge receipt of your letter of January 5, 1972, and the accompanying letter of\nDecember 15, 1971, from the Wisconsin Utilities Association.\nThe request by the Wisconsin Utilities Association that an alternative to the provisions of\nParagraph 192.465(a) be made available to utilities operating within the jurisdiction of the\nWisconsin Public Service Commission would be in the nature of a change to the Federal safety\nstandards for your State. A change to the Federal safety standards can be made only by the Office\nof Pipeline Safety. This does not preclude the Wisconsin Public Service Commission from\nadopting for intrastate pipeline systems additional, or more stringent standards, which are not\nincompatible with the Federal standards.\nWe have considered the alternative to Paragraph 192.465(a) that the Wisconsin Utilities\nAssociation proposed and feel that it would be detrimental to public safety. We feel that\nParagraph 192.465(a) is concerned with measures that should be taken to prevent leaks while the\nalternative proposed would only detect leaks instead of preventing them.\nWe hope that this answers your question. If we can be of further assistance, please let us know.\nSincerely,\nJoseph C. Caldwell\nActing Director\nOffice of Pipeline Safety\ndal\\192\\465\\72-03-03\n1\n\n<<<PAGE 2>>>\n\nState of Wisconsin \\ PUBLIC SERVICE COMMISSION\nJanuary 5, 1972\nOffice of Pipeline Safety\nDepartment of Transportation\n400 Sixth Street SW\nWashington, D.C. 20590\nGentlemen:\nEnclosed in duplicate is a request by representatives of Wisconsin distribution utilities\nregarding section 192.465(a) of the Minimum Federal Safety Standard. We have adopted as a\nstate standard the existing wording of section 192.465(a) but because the request of the utilities is\ngeneral in nature there is a question as to whether or not this Commission, as a state regulatory\nbody operating under a 5(a) certificate, has the necessary authority to grant or deny such a\nrequest. If it is your position that this Commission does have the necessary authority to deal with\nthe request, please so inform us. If it is your position that this Commission does not have the\nnecessary authority, we would like to add the following comments.\nWe feel the position of the Wisconsin utilities is well-founded and support the request. At\nthis time, however, we would not support a general change of the rule to apply to the industry as\na whole but only as such a change would pertain to the distribution utilities operating in the state\nof Wisconsin. Our support is based primarily on our leak survey requirements (PSC 192.723;\ncopy attached to utilities' letter), which in almost all cases are carried out by the use of mobile\nflame ionization leak detection units. Most of the surveys performed are done with operator-\nowned equipment. In some cases the operators are actually covering their systems more often\nthan that required by our rules. In addition, we are requiring under section PSC 192.457(d) (copy\nattached to utilities' letter) all operators to cathodically protect all effectively coated steel\ndistribution pipelines by August 1, 1975. This requirement will apply to short sections. Under\nsuch circumstances because of the applicability of the present wording of section 192.465(a) our\noperators would be required to survey many more short sections of main than would presently be\nrequired.\ndal\\192\\465\\72-03-03\n2\n\n<<<PAGE 3>>>\n\nWe feel the request is reasonable, will not reduce pipeline safety, and will be in the best\ninterests of the public.\nVery truly yours,\nR.E. Purucker\nChief Engineer\nEnclosures\ndal\\192\\465\\72-03-03\n3\n\n<<<PAGE 4>>>\n\nWISCONSIN UTILITIES ASSOCIATION\nWisconsin Gas Company\n626 E. Wisconsin Avenue\nMilwaukee, Wisconsin 53201\n414 276-6720, extension 608\nDecember 15, 1971\nAIR MAIL\nDirector\nOffice of Pipeline Safety Department of Transportation\n400 Sixth Street SW\nWashington, D.C. 20590\nDear Sir:\nThe Gas Codes Task Force responsible to the Executive Committee of the Wisconsin Utilities\nAssociation has carefully reviewed the provision of sub-part I of Part 192 Minimum Federal\nSafety Standards, and offers the following comments and request relative to Section 192.465(a)\nregarding requirements for monitoring the level of cathodic protection.\nThe requirement of testing at least 10% of isolated protected structures with a different 10%\nchecked each succeeding year, the entire system thereby being covered in a ten-year period, is one\nwhich will impose an undue operating cost upon our customers that is not commensurate with the\npotential benefits to be achieved. We invite your consideration of the status of (1) short main\nsections, and (2) isolated steel service risers in systems operated by utilities subject to the\njurisdiction of the Public Service Commission of Wisconsin as follows:\n(1) Short Main Sections\nWe recognize the desirability of testing to determine the adequacy of protection on\nsections of piping falling within the scope of this paragraph. We feel, however,\nthat the practicality of monitoring the level of cathodic protection on the thousands\nof short sections of mains, many of which are used for transition sections between\nplastic and metal or between plastic systems and as jumper connections and loops,\nis not commensurate with the need. We are convinced that these short sections of\npipe which have been coated and cathodically protected will remain under such\ndal\\192\\465\\72-03-03\n4\n\n<<<PAGE 5>>>\n\nprotection. To maintain either test wire stations, install such stations where not\nnow existing, or to contact the pipe from the surface through a barhole on the\npremise that such surveillance would possibly reveal a structure which had lost\nprotection and in which a leak could conceivably develop, would be more\nexpensive and cause more disruption to public and private property than is\nwarranted.\nYou are undoubtedly aware that the Public Service Commission of Wisconsin,\nhaving adopted and administered a gas safety code since 1952, has incorporated its\nrequirements as Chapter PSC 135 of the Wisconsin Administrative Code. On\ndecember 13, 1971, the Commission held a public hearing in Madison, Wisconsin\nfor the purpose of adopting a new Chapter PSC 135 which would include the\nFederal Minimum Safety Standards and such other additional requirements deemed\nappropriate. One of these additional requirements, which had previously been in\neffect as paragraph 852.2 will be retained in the consolidated code and will be\nredesignated as PSC 192.723 (d).\nThe provisions of paragraph PSC 192.723 (d) (copy attached) are significant to\nthis discussion in that these extensive requirements for leakage surveys provide a\nrealistic and effective means of detecting any potentially hazardous situation\nresulting from the loss of cathodic protection in isolated structures. The mobile\nflame ionization and infrared units cited in PSC 192.723 (d) exhibit exceptional\nsensitivity, capable as they are of detecting and indicating the presence of as little\nas 100 parts per million (.01%) of gas in air in the case of the infrared and 5 parts\nper million (.0005%) in the case of the flame ionization instruments. These levels\nof sensitivity are 1/400 and 1/8,000 respectively, of the lowest concentrations at\nwhich an explosive mixture of gas in air would exist.\nWe are convinced that, with the availability of these detection units, the systematic\nsurveys of mains that are required by the Wisconsin code provide a more\ncomprehensive and more frequent coverage of short main sections than does the\nsampling approach required by 192.465(a). In the unlikely event that the\ncombination of remote possibilities leading to a leak in a cathodically protected\nstructure actually did occur, the situation would be recognized much more\npromptly as a result of annual leakage surveys than as a result of the 10%\nmonitoring provision.\nFurther, one of the additional requirements that the Wisconsin Public Service\nCommission will incorporate in its current code writing action will make it\nmandatory that all existing coated steel mains and services be brought under\ncathodic protection, whether or not active corrosion is taking place. A copy of the\nproposed language (PSC 192.457(d)) is attached.\ndal\\192\\465\\72-03-03\n5\n\n<<<PAGE 6>>>\n\n(2) Isolated Steel Service Risers\nUnder the provisions of Chapter PSC 134.30(1) (copy attached) it is necessary\nthat each gas utility schedule a service crew to enter the premises of customers at\nleast once every twelve years to remove, inspect, and adjust or repair the\ncustomer's gas meter. It would be reasonable, in our estimation, to schedule a\ncrew to perform the inspection of isolated steel service risers coincident with the\nmeter replacement cycle. Conversely, there being no basis to assume that a ten-\nyear cycle is related to benefits measurably superior to a twelve-year cycle, it\nwould be unnecessarily expensive and inefficient to conduct the service riser\ninspection cycle independent of the meter inspection cycle.\nFurthermore, these services are subject to the leakage surveys as described in PSC\n192.723(d).\nOn the basis of the foregoing, we request that an alternative to the provisions of paragraph\n192.465(a) be made available to utilities operating within the jurisdiction of the Wisconsin Public\nService Commission, as follows:\nIn the case of electrically isolated sections of steel main piping less than twenty-five (25)\nfeet in length used as transition sections between metallic and/or plastic systems, where\nsuch piping has been coated and cathodically protected, utilities may as a substitute tot he\nprovisions of 192.465(a) perform a leakage survey in accordance with the provisions of\nPSC 135 paragraph PSC 192.723(d). In the case of electrically isolated steel services\nwhere such piping has been coated and\ncathodically protected, the interval of testing the level of cathodic protection shall be the\nsame as the interval between meter tests as prescribed in Section PSC 134.30.\nYours very truly,\ndal\\192\\465\\72-03-03\n6\n\n<<<PAGE 7>>>\n\nR. H. Holder, P.E.\nChairman\nGas Codes Task Force\nEnclosure - 3\ndal\\192\\465\\72-03-03\n7\n\n<<<PAGE 8>>>\n\n192.457 EXTERNAL CORROSION CONTROL: BURIED OR SUBMERGED\nPIPELINES INSTALLED BEFORE AUGUST 1, 1971.\n(a) Except for buried piping at compressor, regulator, and measuring stations, each buried\nor submerged transmission line installed before August 1, 1971, that has an effective external\ncoating must, not later than August 1, 1974, be cathodically protected along the entire area that is\neffectively coated, in accordance with this subpart. For the purposes of this subpart, a pipeline\ndoes not have an effective external coating if its cathodic protection current requirements are\nsubstantially the same as if it were bare. The operator shall make tests to determine the cathodic\nprotection current requirements.\n(b) Except for cast iron or ductile iron, each of the following buried or submerged\npipelines installed before August 1, 1971, must, not later than August 1, 1976, be cathodically\nprotected in accordance with this subpart in areas in which active corrosion is found:\n(1) Bare of ineffectively coated transmission lines.\n(2) Bare or coated pipes at compressor, regulator, and measuring stations.\n(3) Bare or coated distribution lines. The operator shall determine the areas of active\ncorrosion by electrical survey, or where electrical survey is impractical, by the study of corrosion\nand leak history records, by leak detection survey, or by other means.\n(c) For the purpose of this subpart, active corrosion means continuing corrosion which,\nunless controlled, could result in a condition that is detrimental to public safety.\nPSC 192.457(d) Notwithstanding the provisions of 192.457(b) (regarding active\ncorrosion), effectively coated steel distribution pipelines must, not later than . . . (The\nremainder of this page did not print and the typist has no idea what was on it.)\ndal\\192\\465\\72-03-03\n8\n\n<<<PAGE 9>>>\n\n(b) Mains in places or on structures where anticipated physical movement or external\nloading could cause failure or leakage must be patrolled at intervals not exceeding 3 months.\nPSC 192.722 Distribution Mains: Markers.\nWhen distribution mains are located outside urban areas, their location shall be marked\n(recognizable to the public) at each fence line, road crossing, railroad crossing, river, lake,\nstream, or drainage ditch crossing and wherever it is considered necessary to identify the\nlocation of a pipeline to reduce the possibility of damage or interference.\n192.723 DISTRIBUTION SYSTEMS: LEAKAGE SURVEYS AND PROCEDURES.\n(a) Each operator of a distribution system shall provide for periodic leakage surveys in its\noperating and maintenance plan.\n(b) The type and scope of the leakage control program must be determined by the nature\nof the operations and the local conditions, but it must meet the following minimum requirements:\n(1) A gas detector survey must be conducted in business districts, including tests of the\natmosphere in gas, electric, telephone, sewer and water system manholes, at cracks in pavement\nand sidewalks, and at other locations providing an opportunity for finding gas leaks, at intervals\nnot exceeding 1 year.\n(2) Leakage surveys of the distribution system outside of the principal business areas must\nbe made as frequently as necessary, but at intervals not exceeding 5 years . . . (The remainder of\nthis page did not print and the typist has no idea what was on it.)\ndal\\192\\465\\72-03-03\n9\n\n<<<PAGE 10>>>\n\n(b) In each principal business district a building survey shall be conducted once a year.\nThe piping from the service entrance to the meter outlet and metering and regulating equipment\nshall be tested for gas leakage in those buildings that have gas service.\n(c) A survey of all buildings used for public gatherings such as schools, churches,\nhospitals, and theaters shall be conducted once each year. The piping from the service entrance\nto the meter outlet and metering and regulating equipment shall be tested for gas leakage.\n(d) In residential areas, in addition to a survey of public buildings the vegetation shall\nbe checked. At least 3 barhole tests shall be made in each block; at least one street opening\nshall be checked if one exists in each block or at each intersection; and on streets where system\nis operating at a pressure of more than 10 p.s.i.g., all street openings shall be checked. (See\n192.723(b) (1) above for types of street openings.) The utility may substitute for the barhole\ntests a ground surface survey with a hand-operated, continuous-sampling instrument capable of\ndetecting combustible gas in air concentrations of 100 parts per million. The utility may\nsubstitute for all the tests required by this section (PSC 192.723(d)) a survey by mobile flame\nionization or infrared gas detecting units, provided that a method be included to check\nindividual services. The tests required by this section (PSC 192.723(d)) shall be made each\nyear.\n(e) Along lines in rural areas, the vegetation shall be checked annually.\n(f) When a leak compliant is received and the odor og [sic] gas indicates that there is a\nleak in or near the premises, a search shall be carried to conclusion until such leak is found.\nPSC 192.724 FURTHER LEAKAGE SURVEY AFTER REPAIR OF LEAK . . . (The remainder\nof this page did not print and the typist has no idea what was on it.)\ndal\\192\\465\\72-03-03\n10\n\n<<<PAGE 11>>>\n\n(3) Rotary meters shall be tested at two loads with the minimum load at 10% of rating by\nthe use of a portable or volumetric meter or other approved proving devices, or be given a\ndifferential test. In the latter case an original test record shall be set up immediately after\ninstallation; further differential test results shall be recorded and compared with the original test\nrecord.\n(4) A test of an orifice meter shall consists of tests of the recording gauges, and the\nremoval, inspection and measurement of the orifice.\n(5) Temperature-compensated gas displacement meters when tested shall be proved to a\nbase temperature of 60 degrees Fahrenheit.\n(6) Turbine-type meters shall be tested at two loads with the minimum load at 10% of\nrating by the use of a portable or volumetric meter or other approved proving the devices, or be\ngiven a turbine blade, rotor and gear assembly spin test, either by manual or velocity rotation.\nBefore a particular type turbine meter can be used, the manufacturer must file with and be\naccepted by the Commission a minimum coasting time which will satisfactorily indicate the\noperating condition of the internal metering mechanism. For the spin test method a test record\nshall be set up; and the original and subsequent spin test results shall be recorded and compared\nwith the specified minimum coasting time as filed with the Commission for that type meter.\nHistory: Cr. Register, February; 1959, No. 38, eff. 3-1-59; am. (3), Register, November,\n1962, No. 83, eff. 12-1-62; cr. (5), Register, January, 1965, No. 109, eff. 2-1-65; cr. (6),\nRegister, April, 1969, no. 160, eff. 5-1-69.\nPSC 134.29 Installation test. No meter shall be used to meter gas consumption for billing\npurposes unless it was tested and found correct, as defined in Wis. Adm. Code section PSC\n134.27 not longer than 15 months previous to its use. The first test on a meter or a retest after a\nmajor overhaul shall include a check of the registering device and linkages.\nHistory: Cr. Register, February, 1959, No. 38, eff. 3-1-59; am. Register, April, 1969, No.\n160. eff. 5-1-69.\nPSC 134.30 Periodic testing and maintenance. Each utility shall test its meters according\nto the following schedule except as provided in Wis. Adm. Code section PSC 134.26(1). Where\npressure regulators, volume corrective devices, or other measuring devices are used on the service\nor used in conjunction with the meters, they shall be tested on the same schedule as the meters.\n(1) All diaphragm meters that are measuring dry gas and have nonabsorptive type\ndiaphragms or were rediaphragmed since the introduction of dry gas shall be due for removal\ndal\\192\\465\\72-03-03\n11\n\n<<<PAGE 12>>>\n\nfrom service, tested, adjusted, repaired if necessary, and retested if reused, every 144 months if\nthe meter capacity is 2,400 cubic feet per hour or less at 1/2-inch water column and every 48\nmonths if the capacity is greater than 2,400 cubic feet. Meters shall be tested during the calendar\nyear in which said 144th or 48th month falls.\ndal\\192\\465\\72-03-03\n12","truncated":false,"body_characters":18640}