{"operation":"document","citation":"PI-75-037","title":"Manager Corrosion Services — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-07-23","effective_on":null,"summary":"PI-75-037 response to Manager Corrosion Services concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-037.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-037.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-037","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1975/PI75037.pdf","body":"<<<PAGE 1>>>\n\nJuly 23, 1975\nMr. Earl L. Kirkpatrick\nManager Corrosion Services\nControl Incorporated\nP.O. Box 701\nOneonta, Alabama 35121\nDear Mr. Kirkpatrick:\nIn response to your letters of June 20 and July 2, 1975, concerning your company's program to\ndetermine areas of active corrosion in lieu of electrical survey, a copy of our response to Mr.\nSearcy dated July 7, 1975, is enclosed.\nWe believe the July 7 letter should clarify answers to your questions about Federal requirements\napplicable to the use of your program.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline Safety\nOperations\nEnclosure\ndal\\192\\457\\75-07-23\n1\n\n<<<PAGE 2>>>\n\nControl INCORPORATED\nJuly 2, 1975\nMr. Joseph Caldwell\nDepartment of Transportation\nOffice of Pipeline Safety\n2100 2nd Street, SW\nWashington, D.C. 20590\nDear Mr. Caldwell:\nRe: John Searcy's letter to you dated June 26, 1975\nMy letter, dated June 20, 1975\nWe forwarded a copy of my letter to you dated June 20, 1975, to each of the State Public\nService Commissions referred to in this letter so that they would be informed of our submittal to\nyour office. We must apologize for the poor choice of the word \"approval\" in paragraph two of\nmy letter to you.\nMr. R. E. Wood and the writer visited Mr. Searcy in his office on June 14, 1975, to\ndiscuss our program and to obtain his assurance that it would comply with the Federal and State\ncodes of the State of Tennessee, in his opinion. During the meeting, we received no negative\nreaction to our proposal. Subsequently, we received his letter dated June 15, 1973. From this,\nwe assumed that our program was satisfactory in the State of Tennessee.\nCopies of all seven state letters were hand carried to Mr. J. C. Thomas on June 19, 1975.\nIf you wish us to forward you copies of these letters or provide you with any additional\ninformation, please contact me at your earliest convenience.\nSincerely yours,\nCONTROL INCORPORATED\nEarl L. Kirkpatrick\nManager Corrosion Services\ndal\\192\\457\\75-07-23\n2\n\n<<<PAGE 3>>>\n\nControl INCORPORATED\nJune 20, 1975\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. Caldwell:\nI am enclosing three copies of an outline of our \"Bare Line Leakage and Corrosion\nControl Program\" for your review and consideration. We propose to use this system in lieu of a\ndetailed electrical survey to determine areas of active corrosion that will require cathodic\nprotection, for systems installed prior to August 1, 1971. We feel that this program is more\ncomprehensive than the electrical survey called for in the code and will go further to assure public\nsafety. Should you agree that this program will meet the code intent and requirements we would\nappreciate receiving a letter stating that at your earliest convenience.\nTo date, we have received tentative approval of our program from the states of: Alabama,\nFlorida, Georgia, Kentucky, Mississippi, South Carolina, and Tennessee. In some systems we\nhave been operating this program for two years or more. Should you have any questions\nregarding the scope of our intent or program, please do not hesitate to contact me immediately.\nSincerely yours,\nCONTROL INCORPORATED\nEarl L. Kirkpatrick\nManager Corrosion Services\nEnclosures: 2\ndal\\192\\457\\75-07-23\n3\n\n<<<PAGE 4>>>\n\nJuly 7, 1975\nMr. John Searcy\nEngineering Division\nTennessee Public Service Commission\nCordell Hull Building\nNashville, Tennessee 37219\nDear Mr. Searcy:\nThis refers to your letter of June 26, 1975, enclosing (1) a copy of a letter to this Office from Earl\nKirkpatrick of Control Incorporated concerning the use of its \"Bare Line Leakage and Corrosion\nControl Program\" in lieu of an electrical survey to determine areas of active corrosion; and (2) a\ncopy of your June 15, 1975, letter to R. E. Wood of Control, discussing, among other things,\ncompliance with 49 CFR 192.457(b).\nSection 1923.457(b) requires in part:\nThe operator shall determine the areas of active corrosion by electrical survey, or\nwhere electrical survey is impractical, by the study of corrosion and leak history\nrecords, by leak detection survey, or by other means.\nIn your June 15 letter, you state that \"A procedure which would determine areas of corrosion by\nleak detection survey would be in compliance with Section 192.457(b).\" We are concerned that\nthis statement is misleading. A more precise interpretation of the requirement is that a procedure\nwhich determines areas of active corrosion by leak detection survey would comply with Section\n192.457(b) only where determination by electrical survey is impractical. We believe this\ndistinction is significant not only from a legal and safety standpoint, but from a compliance\nstandpoint in view of Control's apparent efforts to market its program as an alternative to the\nelectrical survey method.\nWe intend to so advise Mr. Kirkpatrick when we formally receive his letter. Meanwhile, we\nsuggest that to clarify the situation you amend your advice given to Mr. Wood in accordance with\nour interpretation.\ndal\\192\\457\\75-07-23\n4\n\n<<<PAGE 5>>>\n\nSincerely,\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\nTENNESSEE PUBLIC SERVICE COMMISSION\nJune 26, 1975\nMr. Joseph Caldwell\nDepartment of Transportation\nOffice of Pipeline Safety\n2100 2nd Street, SW\nWashington, D.C. 20590\nDear Mr. Caldwell:\nEnclosed is a letter of June 20, 1975 to you from Mr. Earl Kirkpatrick of Control\nIncorporated. In the second paragraph of the letter he states that they have received \"tentative\napproval\" of their \"Bare Line Leakage and Corrosion Control Program\" from Tennessee. We do\nnot \"approve\" and have not approved their program. The enclosed letter dated June 15, 1973\nconcerns the compliance of a general procedure with Part 192, and is not to be misconstrued as\nan approval of any specific program.\nSincerely,\nJohn Searcy, Engineer\nEngineering Division\ndal\\192\\457\\75-07-23\n5\n\n<<<PAGE 6>>>\n\nEnclosures\ndal\\192\\457\\75-07-23","truncated":false,"body_characters":5937}