{"operation":"document","citation":"PI-76-010","title":"Control Incorporated — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-03-01","effective_on":null,"summary":"PI-76-010 response to Control Incorporated concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-010","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76010.pdf","body":"<<<PAGE 1>>>\n\nMarch 1, 1976\nMr. Earl L. Kirkpatrick\nManager Corrosion Services\nControl Incorporated\nP.O. Drawer 888\nOneonta, Alabama 35121\nDear Mr. Kirkpatrick:\nThis refers to your letter of November 25, 1975, in which you ask our opinion whether the\nconduct of an electrical survey in each of several situations would be \"impractical\" within the\nmeaning of 49 CFR 192.457(b), which reads in part:\n\"The operator shall determine the areas of active corrosion by electrical survey, or where\nelectrical survey is impractical, by the study of corrosion and leak history records, by leak\ndetection survey, or by other means.\"\nBased on the ordinary meaning of the term \"impractical,\" we do not believe that it would be\nimpractical to conduct electrical surveys in any of the situations as you have described them.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\192\\457\\76-03-01\n1\n\n<<<PAGE 2>>>\n\nControl INCORPORATED\nNovember 25, 1975\nMr. Caesar B. DeLeon\nActing Director\nOffice of Pipeline Safety Operations\nDepartment of Transportation\nMaterials Transportation Bureau\n2100 Second Street, S.W.\nWashington, D.C. 20590\nDear Mr. DeLeon:\nPlease advise us if in your opinion the following procedure is acceptable under Part 192,\nSubPart I of the Pipeline Safety Act.\nUsing a Comprehensive Corrosion/History as a recordkeeping system in areas where an\nelectrical survey is considered to be impractical by the person in responsible charge of the\ncorrosion control program. Some examples of situations whereby electrical surveys may be\nconsidered to be impractical are:\n1. Short repair sections on cast iron or ductile iron mains where the repairs, made prior to\nAugust 1, 1971, were made with dissimilar fittings or pipe, either coated or bare and not insulated\nfrom the exiting system.\n2. Gas mains and services laid in the same ditch with metallic water systems and in more\nor less continual contact.\n3. Short piping sections, either service lines or short main sections, not insulated from\ncast iron or ductile iron mains. This would normally include copper, black iron, or galvanized\niron pipe, either bare or coated.\n4. Uncoated services insulated from coated mains at the taping tee creating numerous\nisolated piping sections.\ndal\\192\\457\\76-03-01\n2","truncated":false,"body_characters":2276}