{"operation":"document","citation":"PI-75-001","title":"Wyoming Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-01-09","effective_on":null,"summary":"PI-75-001 response to Wyoming Public Service Commission concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1975/PI75001.pdf","body":"<<<PAGE 1>>>\n\nMr. Richard L. Valent\nWyoming Public Service Commission\nSupreme Court Building\nCheyenne, WY 82002\nDear Mr. Valent:\nThank you for your letter of December 6, 1974, asking several questions concerning the\napplicability of 49 CFR 192.457(b)(1) to two mechanically coupled, bare transmission lines\nconstructed in the 1930's.\nYou ask whether installing anodes when leaks detected on the lines are repaired satisfies section\n192.457(b)(1). This section requires that bare or ineffectively coated transmission lines installed\nbefore August 1, 1971, except for cast or ductile iron lines, be cathodically protected in\naccordance with Subpart I in areas in which active corrosion is found. In addition, section\n192.457(b) requires the operator to determine areas of active corrosion by electrical survey, or if\nimpractical, by studying corrosion or leak history records, by leak detection survey, or by other\nmeans. Thus, the method proposed for compliance with section 192.457(b)(1) would be\nsatisfactory only where it is impractical to find areas of active corrosion by electrical survey and\ninstead leak surveys are utilized, and the cathodic protection installed complies with Subpart I,\nspecifically section 192.463.\nSecondly, you ask if section 192.467(b)(1) is intended primarily for transmission lines traversing\nareas with heavy population. The requirements of section 192.457(b)(1) apply regardless of the\npopulation of the areas in which a transmission line is located.\nFinally, you ask if the company involved may apply to this office for waiver of applicable\nrequirements. Assuming the transmission lines to which you refer are under the jurisdiction of the\nWyoming Public Service Commission, section 3(e) of the Natural Gas Pipeline Safety Act of 1968\nprovides that the Commission, as a certified State agency, may grant waivers from compliance\nwith the Federal gas pipeline safety standards, subject to the approval of the Secretary of\nTransportation. Because of this unique Federal and State relationship, the Commission is the\nproper forum at which the company should present its request for waiver rather than this office.\nWe trust this adequately responds to your inquiry.\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nDecember 6, 1974\nDB\nC:\\WP51\\INTERPRT\\192\\457\\75-01-09\n1\n\n<<<PAGE 2>>>\n\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nTES-30\nDepartment of Transportation\nWashington, D.C. 20590\nRe: Minimum Federal Safety Standards §192.457(b)(1).\nDear Mr. Caldwell:\nSection 192.457(b)(1): Except for cast iron or ductile iron, each of the following buried\nor submerged pipelines installed before August 1, 1971, must, not later than August 1, 1976, be\ncathodically protected in accordance with this subpart in areas in which active corrosion is found:\n(1) Bare or ineffectively coated transmission lines.\nThis requirement for corrosion control will cause many problems for the operator of the\nfollowing:\nA company operates two transmission lines that traverse over one hundred miles in\nprimarily class one location. The two lines are constructed of 10\", 12\" and 14\" bare pipe,\nmechanically coupled, with sections of pipe laid in the 1930's. The two lines crossover\nbetween 10 and 15 times. The lines are located in many different types of soils, cross\nmarshes, streams, rivers, etc.\nThe company has leak surveys, leak repairs, anode locations, pipe replacement\nrecords etc. for these lines.\nIf it is required that this company meet the requirements of Section 192.457(b)(1),\nthis company will probably have to bond all of the mechanical coupling (occurring every\n20 to 30 feet), cross bond all cross overs, install deep well anode beds, and install\nrectifiers.\nThe economics involved here look to be prohibitive. The company would be\nbetter off to construct a new larger line that would replace the existing two.\nWhen this company finds a leak on either of these lines, digs it up, repairs the leak,\ninstalls anodes etc., does this meet the requirements of Section 192.457(b)(1)\nDB\nC:\\WP51\\INTERPRT\\192\\457\\75-01-09\n2\n\n<<<PAGE 3>>>\n\n\"cathodically protect areas of active corrosion\". This means that sections between\nmechanical coupling are essentially cathodically protected without monitoring.\nDuring a two (2) day industrial seminar, I was told that §192.457(b)(1) was\nintended primarily for transmission lines traversing through areas with heavy population.\nIf this is the case, this section should be further defined to clearly state which lines are\nrequired to be cathodically protected. (Based on class location etc.)\nIf the above is not correct, should the company apply to O.P.S. for a waiver of this\nrequirement for this particular case?\nI hope that this letter has given you an insight to this special problem and I hope\nthat you can see the undue burden this section will impose on this company if they are\nrequired to protect these lines.\nAny assistance you can give me will be appreciated. I intend to work closely with\nthis operator in order to help him come into compliance before the 1976 deadline.\nBest regards,\nRichard L. Valent\nEngineer\nDB\nC:\\WP51\\INTERPRT\\192\\457\\75-01-09\n3","truncated":false,"body_characters":5150}