{"operation":"document","citation":"PI-73-0117","title":"Cape Cod Gas Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1973-09-19","effective_on":null,"summary":"PI-73-0117 response to Cape Cod Gas Company concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0117.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0117.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0117","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/g73-09-19_Weber_192.457-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-73-0117\nSeptember 19, 1973\nDavid E. Weber, P.E.\nGas Engineer and Safety Director\nCape Cod Gas Company\nP.O. Box 1360\nHyannis, MA 02601\nDear Mr. Weber:\nThis is in response to your letter of August 27, 1973, in which you opine that the definition and interpretation of\n§192.457 (c), 49 CFR is ambiguous.\nThe purpose of this subsection was to require that cathodic protection be required where continuing active corrosion\ncould result in a condition that is detrimental to public safety. This requirements, therefore, would exclude those areas\nof corrosion where other corrective action would be taken, thereby providing and exception to the cathodic protection\nbecause the active corrosion was not continuing or detrimental to public safety.\nYou indicate that you feel that we should make every effort to revise the section qualitatively and quantitatively. The\nFederal gas pipeline safety regulations have been developed, as far as practicable, as performance standards rather than\ndesign and construction specifications. They prescribe an adequate level of safety in terms of results, leaving industry\nfree to develop and use improved technological means of meeting the requirements.\nFrom comments and information gathered in developing the corrosion regulations, the Office of Pipeline Safety (OPS)\nwas not able to ascertain a definitive qualitative or quantitative measurement of corrosion that could be used in\ndetermining the degree of detriment to public safety in all instances of continuing corrosion. The regulations as\ndeveloped provide a performance yardstick for the gas operator to determine if the continuing corrosion in his system\nwill be hazardous to the public.\nWe trust that this has answered your particular question. If we can be of further assistance, please let us know.\nSincerely,\nSigned\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nCape Cod Gas Company\nWhites Path\nSo. Yarmouth, Mass.\nP. O. Box 1360\nHyannis, Mass. 02601\nAugust 27, 1973\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D. C. 20590\nDear Mr. Caldwell:\nIn reviewing OPS Advisory Bulletin No. 73-7 of July 1973, it is my judgment that the definition and interpretation of\n49 CFR Section 192.457 (c) is still ambiguous.\nIt is probable that of the minimum standards Subpart I - Requirements for Corrosion Control are the most definitive.\nHowever, to coin a colloquialism Section 192.457 (c) is a \"cop-out\"; and the Department should make every effort to\nrevise the section qualitatively and quantitatively.\nIt is obvious that not only Subpart I but the entire standard has been promulgated to prevent “a condition that is\ndetrimental to public safety\".\nSincerely,\nDavid E. Weber, P.E.\nGas Engineer and Safety Director","truncated":false,"body_characters":2793}