{"operation":"document","citation":"PI-74-009","title":"Richard B. Bender Corrosion Associates — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-02-02","effective_on":null,"summary":"PI-74-009 response to Richard B. Bender Corrosion Associates concerning 192.455, 192.463, 192.467.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-009.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-009.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-009","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/PI74009.pdf","body":"<<<PAGE 1>>>\n\nFebruary 2, 1974\nMr. Richard B. Bender\nRichard B. Bender Corrosion\nAssociates\nP. O. Box 11302\nFort Worth, TX 76110\nDear Mr. Bender:\nIn your letter of January 17, 1974, you asked about corrosion control requirements for steel risers\non plastic service lines.\nSteel risers on plastic services must be coated and cathodically protected as required by Section\n192.455 of Subpart I of the Federal regulations. So as to facilitate cathodic protection, each\nservice riser must be electrically insulated from other house piping such as at the regulatory shut-\noff valve or meter as required by Section 192.467(b). The level of protection must meet one or\nmore of the criteria contained in Section 192.463.\nAlso, the frequency for monitoring the cathodic protection applied to service risers is covered by\nSection 192.465.\nWe trust this clarifies the requirements for corrosion control measures applicable to steel risers on\nplastic services. If you desire any further information, please advise.\nSincerely,\n/signed/\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nDB/dal/192.455\n74-02-02.1\n1\n\n<<<PAGE 2>>>\n\nJanuary 17, 1974\nMr. Joseph Caldwell\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D. C. 20590\nDear Mr. Caldwell:\nWe are concerned with Section 192.463 of the 49 CFR. We have been finding numerous\nsituations where plastic pipe has been used in service lines up to the point just below the house\nregulator or meter, at this point a transition fitting and steel riser (coated steel) is connected\nunderground and rises above ground to the regulator or meter. We have found a number of these\nmetal risers developing corrosion leaks simply because they are not isolated from the house piping\n(which connects the short section of riser to the copper water system underground at the house).\nWe have also found fairly aggressive pitting even when the coated steel riser pipes are isolated but\nnot cathodically protected.\nOur interpretation on these steel gas risers is that they have to be coated, isolated and\nplaced under cathodic protection. Are we correct? Or is the criteria of protection removed from\nthis.\nI have raised this question because a local gas company in one of the towns that we have\nbeen working has informed the plumbers who have been installing these plastic services and steel\nmeter risers \"that insulating fittings and anodes are not necessary on this short section of pipe,\"\nyet it is in one of the most hazardous locations (particularly when under concrete slabs and paved\nparking areas) that which we have to concern ourselves. In many areas a gas leak at this location\nparticularly when it is intermediate pressure upstream from the regulator is more hazardous than a\ngas leak ten, twenty or thirty feet away on a service. I need an answer to this question in a\nmanner that will convince them that the Federal law is as written.\nSincerely,\nRichard B. (Pipe) Bender\nDB/dal/192.455\n74-02-02.1\n2","truncated":false,"body_characters":2951}