{"operation":"document","citation":"PI-72-046","title":"Equitable Gas — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1972-10-13","effective_on":null,"summary":"PI-72-046 response to Equitable Gas concerning 192.461.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-046.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-046.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-72-046","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1972/PI72046.pdf","body":"<<<PAGE 1>>>\n\nOctober 31, 1972\nMr. Charles M. Rutter, Jr.\nEquitable Gas\n420 Boulevard of the Allies\nPittsburgh, Pennsylvania 15219\nDear Mr. Rutter:\nThis is in response to your letter of September 29, 1972, in which you described a procedure for\npreparing a surface to receive a protective coating for the purpose of external corrosion control.\nYou ask if your procedure meets the require-\nments of Section 192.461(a)(1) and, if so, whether such a proce-\ndure is required for appurtenances that are to be installed below ground and are to be hand coated\nat the time of installation.\nAs we understand your procedure, the properly prepared surface is obtained by grit blast cleaning\n(or equal) down to the parent structure of the metal, followed by application of a primer that is\napproved or recommended by the coating manufacturer. From the information presented, this\nprocedure appears to meet the requirements of Section 192.461(a)(1).\nWith respect to your question on the application of such a procedure to underground\nappurtenances, there is no requirement that Section 192.461(a)(1) be met solely in this manner.\nThe regulation is stated as a performance type standard and the method of compliance is left to\nthe operator. Because of the odd shapes of pipeline appurtenances and the penetrating effect of\nsome coatings and primers, the decision as to what constitutes a \"properly prepared surface\" in a\nparticular case is left to the operator.\nYour continued interest in the pipeline safety program is appreciated.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\461\\72-10-31\n1\n\n<<<PAGE 2>>>\n\nSeptember 29, 1972\nMr. Lance F. Heverly\nAssistant Chief\nTechnical Division\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D.C. 20590\nDear Lance:\nAs stated in the D.O.T. Requirements for Corrosion Control in Section 192.461(1)\nExternal corrosion control: protective coatings, it is required that protective coatings must be\napplied on a properly prepared surface. It is my interpretation or belief that the criteria for a\nproperly prepared surface is that obtained by grit blast cleaning (or equal) to parent metal of the\nstructure to be coated. Further preparation of the surface would be to apply a primer, if required,\nthat is manufactured and required by the manufacture of the coating to be used, or an equal\nprimer that is approved by the coating manufacturer.\nDoes this describe a properly prepared surface for the application of insulating coatings?\nIf this is a proper description and as you know so as to facilitate and/or to assure proper surface\npreparation of steel pipe such pipe is normally purchased without oils, lacquers, varnishes, paints,\netc., applied to the pipe surfaces, when such pipe is to coated for below ground installation.\nIn your opinion, should this also be a requisite for the use of appurtenances that are to be\ninstalled below ground and are to be hand coated at the time of installation, thereby eliminating\npaints, enamels, and specially aluminum paints that are normally and regularly applied to\nappurtenances such as valves by certain valve manufacturers?\nSincerely,\nCharles M. Rutter, Jr.\ndal\\192\\461\\72-10-31\n2\n\n<<<PAGE 3>>>\n\nSuperintendent - Corrosion\ndal\\192\\461\\72-10-31\n3","truncated":false,"body_characters":3258}