{"operation":"document","citation":"PI-75-051","title":"Natural Gas Pipeline Company of America — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-10-21","effective_on":null,"summary":"PI-75-051 response to Natural Gas Pipeline Company of America concerning 192.491.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-051.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-051.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-75-051","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1975/PI75051.pdf","body":"<<<PAGE 1>>>\n\nOctober 21, 1975\nMr. R. C. Brady\nSupervisor, Data Systems & Procedures\nNatural Gas Pipeline Company of America\n122 South Michigan Avenue\nChicago, Illinois 60603\nDear Mr. Brady:\nThis is in reply to your recent letter which was received by this office on September 5, 1975,\nregarding microfilming of various records of corrosion control.\nSection 192.491 of the Federal gas pipeline safety standards requires that for as long as the\npipeline remains in service, each operator shall maintain records commencing July 31, 1972, in\nsufficient detail to demonstrate the adequacy of corrosion control measures or that a corrosive\ncondition does not exist. This section does not prohibit the use of microfilming to preserve the\nrecords nor does it require that the original documents be retained after being put on film. The\nregulations do not require the certification of the microfilm process.\nThank you for your interest in pipeline safety.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\192\\491\\75-10-21\n1\n\n<<<PAGE 2>>>\n\nSeptember 24, 1970\nMr. Charles M. Rutter\n111 South Commons\nPittsburgh, Pennsylvania 15212\nDear Charles:\nIn reply to your letter of July 27, 1970, Department of Transportation's jurisdiction would stop at\nthe downstream side of the customer's meter, if the meter is next to the customer's house.\nHowever, since our jurisdiction covers the distribution of gas, it is difficult to say just where it\nwould stop if the meter should be at the property or curb line. Our General Counsel is currently\nstudying this problem to determine just where our jurisdiction should end. As stated at Harco's\nSeminar, the gas company is really the only one that is in a position to know whether or not the\nservice line from a meter at the property line to a house is protected. Obviously, the property\nowner ordinarily does not have the know-how or measuring equipment to check the corrosion\ncondition of his service line.\nAs an example of the recognition of the seriousness of this situation, Tulsa, Oklahoma, has a city\nordinance whereby a service line belonging to the customer has to be coated, electrically isolated\nat the house and separately cathodically protected. The work is done by a licensed plumber who\nhas to make the installation in accordance with this city ordinance. However, it is the gas\ncompany, Oklahoma Natural Gas Company, that routinely checks the customer's service line and\nif the company finds that the service line is not protected, it reports its finding to the city\ninspector. You amy wish to get in touch with Orville W. Everett, Chief Corrosion Engineer for\nOklahoma Natural Gas Company, for further details.\nSo as to clarify paragraph 192.491, Control of Interference Currents, what would you think of\nadding a couple of sentences to paragraph (b) along the following lines:\n\"Joint interference testing either individually or through local electrolysis committees,\nmust be made to determine if adjacent underground metallic structures are subjected to adverse\ninterference currents. If adverse interference is found, appropriate measures must be taken to\nminimize such interference; yet maintain protection on the operator's structure in compliance with\nthe protective criteria contained in paragraph 6.3 of the 1969 edition of NACE Standard RP-01-\n69.\"\nAutomatic potential control (APC) rectifiers, that is, solid state silicon controlled rectifiers (SCR),\nhave immediate response (1/2 cycle) and are especially good in areas where a pipeline is subjected\ndal\\192\\491\\75-10-21\n2\n\n<<<PAGE 3>>>\n\nto rapid stray current fluctuations. If I remember correctly, the way to estimate the cost of APC\nrectifiers is 1.25 x base price of standard rectifier unit + $300. You may wish to get in touch with\nTom P. Wilkinson, Marketing Manager, Good-All Electric, Incorporated, 201 S. Spruce Street,\nOgallala, Nebraska 69153, for information on APC type rectifiers.\nSincerely,\nLance F. Heverly\nAssistant Chief, Technical Div.\nOffice of Pipeline Safety\ndal\\192\\491\\75-10-21\n3\n\n<<<PAGE 4>>>\n\nEQUITABLE GAS COMPANY\nJuly 27, 1970\nMr. Lance F. Heverly\nAssistant Chief\nTechnical Division\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D.C. 20590\nDear Lance:\nAt the Harco Seminar held on June 23, 1970, at Cleveland, Ohio, it was stated that the gas\nservicing companies would be responsible for applying and maintaining cathodic protection to gas\nservice lines, including those lengths of such service lines not installed and/or owned by the\nservicing companies. Please advise if this statement is still true and if the statement also includes\nother buried gas lines such as \"house lines\" that are installed and owned by the customer and are\ndefined as such lines extending beyond the gas meter?\nSince both the National Association of Corrosion Engineers Standard RP-01-69 and the\noffice of Pipeline Safety's proposed Requirements for Corrosion Control (Notice 70-8: Docket\nNo. OPS-5) do not satisfactorily discuss or define the effects of stray direct currents imposed\nupon gas pipe lines, will the Office of Pipeline Safety accept the controlled removal of such\ncurrents from effected pipe lines as a method of affording cathodic protection to these lines\nwherein such protection is being afforded only when such currents are being removed from the\nlines? As you know, there are locations where large amounts of such currents influence pipe lines\nwherein the requirement to provide continuous cathodic protection to such lines could be\ntechnically impossible, as related to the present manners and devices used today to provide\ncontinuous cathodic protection measures to pipe structures located in certain stray direct current\narea.\nVery truly yours,\nC. M. Rutter\n111 South Commons\nPgh., Pa. 15212\ndal\\192\\491\\75-10-21\n4","truncated":false,"body_characters":5798}