{"operation":"document","citation":"PI-73-010","title":"West Virginia Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-05-09","effective_on":null,"summary":"PI-73-010 response to West Virginia Public Service Commission concerning 192.465.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-010","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/PI73010.pdf","body":"<<<PAGE 1>>>\n\nMay 9, 1973\nMr. T. K. Spalding, Director\nGas Pipeline Safety Division\nState of West Virginia\nPublic Service Commission\nCharleston, West Virginia 25305\nDear Mr. Spalding:\nThis is in answer to the questions asked in your letter of April 17, 1973.\nQuestion 1. Is cathodic protection required on bare transmission or distribution lines laid prior to\nAugust 1, 1971, in areas where corrosion is in progress, as determined by electrical survey or\nexperience, if continuing corrosion would not be detrimental to public safety? Section 192.457(c)\nseems to have been specifically written to exclude such areas.\nAnswer. Section 192.457(b) requires, in pertinent part, that bare transmission or distribution lines\ninstalled before August 1, 1971, must be cathodically protected by a given date in areas in which\nactive corrosion is found. \"Active corrosion\" is defined in §192.457(c) to mean continuing\ncorrosion which, unless controlled, could result in a condition that is detrimental to public safety.\nThe test for applicability of the requirement, therefore, is not whether the corrosion is now\ndetrimental to public safety, but rather whether continuing corrosion could lead to a condition that\nmight later become detrimental. Thus, if the continuing corrosion could at some future time result\nin a condition that is then detrimental to public safety even though today such condition does not\nexist, the pipeline is nevertheless subject to the requirement now rather than at a later time. We\ncannot determine from your description of the given situation that \"active corrosion\" is not\npresent.\nQuestion 2. How often must electrical surveys be made on pipelines protected by the \"hot\nspotting\" method?\nAnswer. Section 192.465(e) requires each operator to reevaluate its unprotected pipelines at\nintervals not exceeding three years. The reevaluation is done by electrical survey where practical.\nA\ndal\\192\\465\\73-05-09\n1\n\n<<<PAGE 2>>>\n\npipeline protected by the \"hot spotting\" method is an unprotected pipeline for purposes of\n§192.465 and therefore subject to the three-year reevaluation requirement. The \"hot spots,\" of\ncourse, are subject to other monitoring requirements.\nIf you have further questions in this regard, please contact us.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\ndal\\192\\465\\73-05-09\n2\n\n<<<PAGE 3>>>\n\nSTATE OF WEST VIRGINIA\nApril 17, 1973\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. Caldwell:\nI will appreciate an answer for the following two\nquestions:\n1. Is cathodic protection required on bare transmission or distribution lines laid\nprior to August 1, 1971 in areas where corrosion is in progress, as determined by electrical survey\nor experience, if continuing corrosion would not be detrimental to public safety?\nSection 192.457(c) seems to have been specifically written to exclude such areas.\n2. How often must electrical surveys be made on pipelines protected by the \"hot\nspotting\" method?\nYours very truly,\nT. K. Spalding, Director\nGas Pipeline Safety Division\ndal\\192\\465\\73-05-09\n3","truncated":false,"body_characters":3118}