Manager Corrosion Services — Pipeline Safety Interpretation

Page 1July 23, 1975 Mr. Earl L. Kirkpatrick Manager Corrosion Services Control Incorporated P.O. Box 701 Oneonta, Alabama 35121 Dear Mr. Kirkpatrick: In response to your letters of June 20 and July 2, 1975, concerning your company's program to determine areas of active corrosion in lieu of electrical survey, a copy of our response to Mr. Searcy dated July 7, 1975, is enclosed. We believe the July 7 letter should clarify answers to your questions about Federal requirements applicable to the use of your program. Sincerely, Cesar DeLeon Acting Director Office of Pipeline Safety Operations Enclosure dal\192\457\75-07-23 1#

Page 2Control INCORPORATED July 2, 1975 Mr. Joseph Caldwell Department of Transportation Office of Pipeline Safety 2100 2nd Street, SW Washington, D.C. 20590 Dear Mr. Caldwell: Re: John Searcy's letter to you dated June 26, 1975 My letter, dated June 20, 1975 We forwarded a copy of my letter to you dated June 20, 1975, to each of the State Public Service Commissions referred to in this letter so that they would be informed of our submittal to your office. We must apologize for the poor choice of the word "approval" in paragraph two of my letter to you. Mr. R. E. Wood and the writer visited Mr. Searcy in his office on June 14, 1975, to discuss our program and to obtain his assurance that it would comply with the Federal and State codes of the State of Tennessee, in his opinion. During the meeting, we received no negative reaction to our proposal. Subsequently, we received his letter dated June 15, 1973. From this, we assumed that our program was satisfactory in the State of Tennessee. Copies of all seven state letters were hand carried to Mr. J. C. Thomas on June 19, 1975. If you wish us to forward you copies of these letters or provide you with any additional information, please contact me at your earliest convenience. Sincerely yours, CONTROL INCORPORATED Earl L. Kirkpatrick Manager Corrosion Services dal\192\457\75-07-23 2#

Page 3Control INCORPORATED June 20, 1975 Mr. Joseph C. Caldwell, Director Office of Pipeline Safety Department of Transportation Washington, D.C. 20590 Dear Mr. Caldwell: I am enclosing three copies of an outline of our "Bare Line Leakage and Corrosion Control Program" for your review and consideration. We propose to use this system in lieu of a detailed electrical survey to determine areas of active corrosion that will require cathodic protection, for systems installed prior to August 1, 1971. We feel that this program is more comprehensive than the electrical survey called for in the code and will go further to assure public safety. Should you agree that this program will meet the code intent and requirements we would appreciate receiving a letter stating that at your earliest convenience. To date, we have received tentative approval of our program from the states of: Alabama, Florida, Georgia, Kentucky, Mississippi, South Carolina, and Tennessee. In some systems we have been operating this program for two years or more. Should you have any questions regarding the scope of our intent or program, please do not hesitate to contact me immediately. Sincerely yours, CONTROL INCORPORATED Earl L. Kirkpatrick Manager Corrosion Services Enclosures: 2 dal\192\457\75-07-23 3#

Page 4July 7, 1975 Mr. John Searcy Engineering Division Tennessee Public Service Commission Cordell Hull Building Nashville, Tennessee 37219 Dear Mr. Searcy: This refers to your letter of June 26, 1975, enclosing (1) a copy of a letter to this Office from Earl Kirkpatrick of Control Incorporated concerning the use of its "Bare Line Leakage and Corrosion Control Program" in lieu of an electrical survey to determine areas of active corrosion; and (2) a copy of your June 15, 1975, letter to R. E. Wood of Control, discussing, among other things, compliance with 49 CFR 192.457(b). Section 1923.457(b) requires in part: The operator shall determine the areas of active corrosion by electrical survey, or where electrical survey is impractical, by the study of corrosion and leak history records, by leak detection survey, or by other means. In your June 15 letter, you state that "A procedure which would determine areas of corrosion by leak detection survey would be in compliance with Section 192.457(b)." We are concerned that this statement is misleading. A more precise interpretation of the requirement is that a procedure which determines areas of active corrosion by leak detection survey would comply with Section 192.457(b) only where determination by electrical survey is impractical. We believe this distinction is significant not only from a legal and safety standpoint, but from a compliance standpoint in view of Control's apparent efforts to market its program as an alternative to the electrical survey method. We intend to so advise Mr. Kirkpatrick when we formally receive his letter. Meanwhile, we suggest that to clarify the situation you amend your advice given to Mr. Wood in accordance with our interpretation. dal\192\457\75-07-23 4#

Page 5Sincerely, Joseph C. Caldwell Director Office of Pipeline Safety TENNESSEE PUBLIC SERVICE COMMISSION June 26, 1975 Mr. Joseph Caldwell Department of Transportation Office of Pipeline Safety 2100 2nd Street, SW Washington, D.C. 20590 Dear Mr. Caldwell: Enclosed is a letter of June 20, 1975 to you from Mr. Earl Kirkpatrick of Control Incorporated. In the second paragraph of the letter he states that they have received "tentative approval" of their "Bare Line Leakage and Corrosion Control Program" from Tennessee. We do not "approve" and have not approved their program. The enclosed letter dated June 15, 1973 concerns the compliance of a general procedure with Part 192, and is not to be misconstrued as an approval of any specific program. Sincerely, John Searcy, Engineer Engineering Division dal\192\457\75-07-23 5#

Page 6Enclosures dal\192\457\75-07-23#