Virginia State Corporation Commission — Pipeline Safety Interpretation

Page 1March 3, 1976 Mr. John M. Baumgardner Engineer Virginia State Corporation Commission Division of Public Utilities Box 1197 Richmond, VA 23209 Dear Mr. Baumgardner: In your February 2, 1976, letter to the Office of Pipeline Safety Operations you ask: "Would 192.465 requiring tests on separately protected service lines once every 10 years include meter risers where metal is the gas carrier when used with a plastic service line?" If the gas is carried in metal piping that extends below the ground surface, Subpart I - Requirements for Corrosion Control must be complied with. This would require operators of such piping to monitor these short sections as required in 192.465(a). Thank you for your interest in pipeline safety. Sincerely, Cesar DeLeon Acting Director Office of Pipeline Safety Operations DB/dal/192.465 76-03-03 1#

Page 2COMMONWEALTH OF VIRGINIA February 2, 1976 Mr. Cesar DeLeon Acting Director Office of Pipeline Safety Operations Department of Transportation Materials Trans. Bureau 400 7th Street, S. W. Washington, D. C. Dear Mr. DeLeon: Would 192.465 requiring tests on separately protected service lines once every 10 years include meter risers where metal is the gas carrier when used with a plastic service line? Some operators contend that the riser is considered a fitting, and this requirement would not apply. By the definition of "pipeline" I felt that a meter riser would have to be tested once every 10 years, and discussed this with Frank Fulton. However, I would like this interpretation in writing. Yours truly, John M. Baumgardner Engineer DB/dal/192.465 76-03-03 2#