{"operation":"document","citation":"PI-76-016","title":"Corrosion Associates — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-04-08","effective_on":null,"summary":"PI-76-016 response to Corrosion Associates concerning 192.455, 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-016.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-016.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-016","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76016.pdf","body":"<<<PAGE 1>>>\n\nApril 8, 1976\nMr. Richard B. Bender\nCorrosion Associates\nP.O. Box 11302\nFort Worth, Texas 76110\nDear Mr. Bender:\nIn your letter of March 31, 1976, you ask whether the exemptions\ncontained in Section 192.455 apply to pipelines which are subject\nto the requirements of Section 192.457. We presume the question\narises from the wording of Section 192.457 which provides that\ncertain pipelines must be cathodically protected \"in accordance\nwith this subpart.\"\nBy its terms, Section 192.455 specifically applies to pipelines\ninstalled after July 31, 1971. Likewise, Section 192.457\nspecifically applies to pipelines installed before August 1, 1971.\nThis distinction in the scope of the two sections indicates that\nthe exemptions under Section 192.455 are intended to apply only to\npipelines installed after July 31, 1971.\nIn Section 192.457, the phrase \"in accordance with this subpart\" is\nnot intended to reference the exemptions from the cathodic\nprotection requirement of Section 192.455. This is particularly\ntrue in light of the analogous usage of the phrase in Section\n192.455 where exemptions are otherwise set forth. Rather, in both\nsections the phrase is grammatically used to describe the\nrequirement for cathodic protection. The phrase indicates that\nother regulations in Subpart I, namely Section 192.463, govern the\nprotection which must be provided.\nSincerely,\n\\signed\\\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\195\\260\\76-04-08\n1\n\n<<<PAGE 2>>>\n\nMarch 31, 1976\nMr. Cesar DeLeon\nActing Director\nOffice of Pipeline Safety\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. DeLeon:\nAs an independent Corrosion Consultant, I need some assistance in\ninterpreting a situation that has been presented to me by the\nregional Federal Housing Authority, Dallas, Texas.\nThe question concerns Section 192.455 and Section 192.457. They\nfeel that they can interpret these two sections which will allow\nthem exempt status from cathodic protection on an apartment project\nthat is 20 years old. Can they apply the section dealing with\nsystems installed after 1971 to a system that was installed prior\nto 1971? As we interpreted the law to them, they cannot do this.\nIn the past when we asked for help, it was inferred that only the\nowner or the operator can get answers. However, as a consultant\nworking with your rules and regulations; and dealing with apartment\nproject owners who can't even spell cathodic protection, we are\nworking with you and need your help.\nI do not like to be placed in a position where we would have to\nsign a document stating that cathodic protection is not needed on\nan apartment project when in fact we have interpreted your\nregulations that it be protected. Perhaps a letter or an answer in\nthe monthly news OPSO Advisory Bulletin would benefit everyone in\nthe industry, including H.U.D.\nI am caught between two major Federal Bureaus (DOT and HUD.) I\nknow the horror of a gas explosion, and I know what can be done\nwith cathodic protection. I will not sign a document that is not\ntrue. Please assist me in this matter.\nSincerely yours,\nRICHARD B. BENDER CORROSION ASSOCIATES\n\\signed\\\nR.B. (pipe) Bender\nNACE Certification No. 14\ndal\\195\\260\\76-04-08\n2\n\n<<<PAGE 3>>>\n\nMr. Richard B. Bender\nCorrosion Associates\nP.O. Box 11302\nFort Worth, Texas 76110\nDear Mr. Bender:\nIn your letter of March 31, 1976, you ask whether the exemptions\ncontained in Section 192.455 apply to pipelines which were\ninstalled in an apartment project 20 years ago.\nBy its terms, Section 192.455 specifically applies to pipelines\ninstalled after July 31, 1971. Likewise, Section 192.457\nspecifically applies to pipelines installed before August 1, 1971.\nThis distinction in the scope of the two sections indicates that\nthe exemptions under Section 192.455 are intended to apply only to\npipelines installed after July 31, 1971, and not to pipelines 20\nyears old.\nWe trust this satisfactorily responds to your inquiry.\nSincerely,\n\\signed\\\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\195\\260\\76-04-08\n3\n\n<<<PAGE 4>>>\n\nJuly 14, 1975\nMr. Joseph Caldwell, Director\nOffice of Pipeline Safety\nDepartment of Transportation\n2100 2nd Street, SW\nWashington, D.C. 20590\nDear Mr. Caldwell:\nThank you for your letter of July 7, 1975 relative to the\nControl, Inc. Corrosion Control Program.\nBased on the preamble to Subpart I and the broad meaning of\nthe word \"impractical\", we have interpreted 192.457(b) to mean that\nan electrical survey is not mandatory and that operators could use\nleak surveys and/or records to determine areas of active corrosion.\nWe have so advised the utilities in Tennessee as can be seen from\nmy letter dated July 26, 1974.\nElectrical survey procedures are not specific an d results can\nbe indefinite and inconclusive, as is well stated in the enclosed\nparagraph 8-02 or Air Force Manual 88-9, Chapter 4; and other than\nin appendix D, Part 192 provides no specific criteria relative to\nsoil resistivity or bacteria. I discussed this at length with\nLance Heverly in 1972 and it is because of the above reasons we\nsubsequently deleted 192.455(b) in Tennessee. It has been our\nopinion that leak surveys and/or records provide a more accurate\nand concrete indication of active corrosion.\nWith the 1976 deadline approaching we need to know whether to\nredirect our utilities or amend Part 192 in Tennessee to state\nspecifically that leak surveys and/or records can be used as a\nmethod of determining areas of active corrosion, if such an\namendment would not weaken the regulation. Your advice will be\nappreciated.\nSincerely,\n\\signed\\\nJohn Searcy, Engineer\nEngineering Division\ndal\\195\\260\\76-04-08\n4\n\n<<<PAGE 5>>>\n\nJuly 26, 1974\nTO: ALL GAS UTILITIES\nFROM:John Searcy\nEngineering Division\nThe Tennessee Public Service Commission, Engineering Division, is\nthe authority enforcing the gas pipeline safety regulations for\ntransmission and distribution in Tennessee. These regulations are\nsusceptible to comments and interpretations by those other than\nauthorized representatives of the Commission, and such comments and\ninterpretations may be contrary to the intent of the regulations.\nParticularly susceptible are the regulations relating to leak\nsurveys, corrosion control, and other operations which may involve\nthe services of outside contractors, consultants, and/or suppliers.\nErroneous or misleading interpretations of, or statements\nconcerning, regulations can cost you money unnecessarily in that\nservices may be performed over and above that required by the\nregulations. Always contact me or the Gas Safety Inspector\nassigned to your area when you have questions concerning, or are in\ndoubt about, the regulations. Do not abide by any statement\nconcerning the regulations other than those made by representatives\nof the Commission unless you first verify with the Commission any\nstatement you have heard concerning the regulations.\nOutlining briefly the leak survey and corrosion control\nrequirements, buried or submerged distribution pipelines installed\nprior to August 1, 1971, require cathodic protection by August 1,\n1976, unless it can be shown that a corrosive environment does not\nexist. This may be shown, for example, by an analysis of corrosion\nrelated leak history. Pipelines unprotected because of such a\nshowing must be re-evaluated every three (3) years to determine\nwhether or not the environment has changed.\nPipelines installed after July 31, 1971, must be coated, and within\none (1) year after construction, cathodically protected, regardless\nof whether or not a corrosive environment exists.\nProbably the most well know cathodic protection criterion is the\n-.85 volt potential. However, there are other criteria in Appendix\nD of the Federal Minimum Safety Standards. Any of the criterion\nmay be met.\nThere are also atmospheric corrosion control requirements for above\ndal\\195\\260\\76-04-08\n5\n\n<<<PAGE 6>>>\n\nground pipelines.\nConcerning leak surveys, business districts require a survey every\nyear, and other areas require a survey every five (5) years.\n8-02 FIELD TEST METHODS. It is important that corrosion field\nsurvey work be performed by experienced personnel. There is no\nother engineering field in which so many meaningless measurements\nor misinterpretations of results are likely to occur than when\ninexperienced personnel are called upon to do field survey work.\nCorrosion testing is widely diversified involving many different\ntechniques, some of which are highly specialized. Tests may\nrequire durations of a few minutes to a year or more, and\nmeasurements may vary over wide limits. For example, potential\nmeasurements can vary from a few millivolts to hundreds of volts,\nand the currents involved may be a few milliamperes or hundreds of\namperes. The size of a structure bears no relation to the type of\ntest required. A small complex structure may involve many\nintricate measurements. Often the available data are fragmentary,\nand the conditions that cannot be measured are of greater\nsignificance than those that are obtainable. Consequently,\njudgment and experience in field-testing techniques are of great\nvalue. Due to the many factors involved, a corrosion investigation\nmay include visual inspection, study of geographical areas, study\nof records, chemical analyses, electrical measurements, and\nsometimes biological studies. The proper combination of tests to\nuse depends largely upon the data available and local conditions.\nHere again, the necessity for experienced personnel is evident.\nCorrosion survey reports should indicate not only the results of\nthe tests, but also the reasons why particular tests were used or\nwhy they were excluded. Brief descriptions of some of the standard\ntest practices are now presented.\na. Soil Resistivity Measurements . The voltage drop principle\nis used to determine the resistivity of soils and water. The\nelectrolyte resistivity plays a big part in the rate of corrosion.\nHowever, it must be pointed out that no single test can be taken\nas an absolute determination of corrosivity. Variations in\nelectrolyte resistivity are often the critical factor. For the\ndesign of cathodic protection systems, a knowledge of the soil\nresistivity values in a given area . . . (The remainder of this\npage did not print and the typist has no idea what was in that\narea!)\nSUBPART I- REQUIREMENTS FOR CORROSION CONTROL\n?192.457(C) Active Corrosion\ndal\\195\\260\\76-04-08\n6\n\n<<<PAGE 7>>>\n\n1. 2. What is a condition where you have continuing corrosion that\nis not detrimental to public safety?\nDoes this mean that if you have corrosion way out in the\ncountry in a place where no one lives, that no cathodic\nprotection is required if the pipe was installed before 1971?\n3. How about in a city if a pipe is 300 yards from a place where\npeople would congregate or live.\n?192.463(d)\n1. a. Each operator shall take prompt remedial action to correct any\ndeficiencies indicated by monitoring.\nWhat time period does the word prompt cover?\n?192.455(f)\n1. As far as enforcement of Part (f) of this regulation:\na. If an operator wants to install an insulated fitting\nprotected by alloyage, must this operator comply with\neach part of (f) (1, 2, &3)? If not, is the operator\nthen in violation?\nb. An operator can use these fittings according to item (1)\nif he can show by tests, investigation, or experience\nthat adequate corrosion control is provided by alloyage.\n1. Does this mean that an operator must be keeping\nsome type of record to prove that from past\nexperience the alloy used in the fitting has not\nhad a corrosion problem. In other words, have\nrecords showing that brass or stainless steel after\nbeing in service for a period of years and\nexperienced no corrosion problem.\n2. Would the operator have to prove this for all soil\nresistivities?\n3. Would it be adequate for an operator with no\nrecords of tests or investigations just to say they\nhave experienced no corrosion problem with the\ndal\\195\\260\\76-04-08\n7\n\n<<<PAGE 8>>>\n\n2. c. d. alloyage used in the fitting, therefore, it is\nmeeting ?192.455(1)?\n4. Who makes the final determination as to what types\nof alloyage are adequate; the operator, OPSR, OOE,\nthe respective region?\nMust an operator test the manufacturers's design to see\nif corrosion pitting would cause fitting to leak? Could\nhe just review manufacturer's data?\nMust an operator still keep track of the location of\nmetal alloy fittings if the operator claims that he has\nadequately proven that there is no corrosion problem in\nall soil resistivity with respect to the alloy being\nused.\nThe small municipalities would have a hard time showing by\ntests and investigations that an alloy is adequate. Is it OK\nfor these municipalities to depend on test results from other\ngas companies with respect to alloys used in these fittings as\nlong as they keep track of where they are putting them?\ndal\\195\\260\\76-04-08\n8\n\n<<<PAGE 9>>>\n\nOctober 16, 1979\nMr. R. E. Speckmann, Manager\nRegulations and Maintenance Standards\nShell Pipe Line Corporation\nP.O. Box 2648\nHouston, TX 77001\nDear Mr. Speckmann:\nYour letter of June 19, 1979, requesting a finding under 49 CFR\n195.260(e) that valves are not justified at certain water crossings\nin your planned installation of the 48-inch diameter LOCAP crude\noil pipeline between the Louisiana Offshore Oil Port (LOOP)\nterminal at Clovelly, Louisiana, and the existing input terminal to\nthe Capline system at St. James, Louisiana.\nIn your letter, you stated that the LOCAP pipeline begins at LOOP's\nClovelly, Louisiana, underground storage dome in Section 32, T18S,\nR22E, LaFourche Parish, and extends in a northerly direction across\nmarshes, numerous bayous, swamps, the Intracoastal Waterway, and\nsome farmland to the Capline Pipeline St. James Terminal located in\nSection 56, T12S, R16E, St. James Parish, Louisiana. Conditions\nalong the LOCAP pipeline route are such that approximately 85\npercent of the pipeline will be installed in marsh and swamp areas\nusing weight coating for stability. The pipeline will be welded\ntogether and floated in a ditch excavated through these areas. The\npipeline will be submerged, and the floatation ditch will be\nbackfield to cover the pipeline. Brackish and fresh water will\nexist at various times of the year over most of the length of the\nnew pipeline.\nYou indicated that precise compliance with ?195.260(e) would result\nin the placement of what the Shell Pipe Line Corporation (SPLC)\nconsiders to be an impractical number of valves. Instead you\nproposed to place valves at initiating and delivery terminals, near\nHighway 3199 and near Highway 20, and on each side of the\nIntracoastal Waterway. The valves at the initiating and delivery\nterminals and on each side of the Intracoastal Waterway will be\nremotely operable from the Capline St. James Control Center.\nFurther, you also proposed to install two means to detect leaks, as\ndiscussed hereafter.\nIn the evaluation of your request, this Office considered the\nfollowing factors as relevant to whether justification exists for\nnot installing valves as required:\n1. Effectiveness of Proposed Leak Detection and Shutdown System\nWe found your plans for automated leak detection with alarms and\ndal\\195\\260\\76-04-08\n9\n\n<<<PAGE 10>>>\n\nremotely controlled block valves and shutdown pumps at Clovelly\nStation to be an effective, integrated set of alternative measures\nwhich will assure a level of safety far exceeding that attainable\nby literal adherence to ?195.260(e). Your first method, a dynamic\ncomputer model of the pipeline, will provide rapid response to\nsuddenly occurring leaks. i believe this model will read\ntelemetered pressures and flow rates from Clovelly and St. James.\nUtilizing hydraulic surge theory, the model will calculate and\ncompare calculated and telemetered hydraulic variables.\nComputerized computations will ascertain the divergence between\nreal and calculated values and send appropriate alarms to the oil\nmovements controller if a leak is indicated.\nThe proposed second method of leak detection by comparison of input\nand delivery volumes will be read into a computer line balance\nprogram and compared at periodic intervals. If a discrepancy\nexists between the adjusted input and output volumes exceeding a\npreset limit, the proposed leak detection alarm will be signalled\nto the oil movements controller, who will be able to shut down the\npumps at Clovelly Station and isolate the pipeline by means of\nremotely controlled block valves at initiating and delivery\nterminals and on each side of the Intracoastal Waterway. Your\nproposed leak detection and shutdown appear to be safe and surpass\nthe safety provided if shutdown capabilities were limited to\nmanually controlled valves placed as required by ?195.260(e). Even\nif these remotely controlled valves failed to close in the event of\na pipeline rupture, the response time required to manually close\nthem should be no greater than the response time necessary to close\nany manually operated valves under ?195.260(e).\n2. Crossings\nThreat to the Integrity of the Pipeline at the Planned Water\nThe waterways to be crossed other than the Intracoastal Waterway\nare all less than 10 feet deep and most are less than 7 feet deep.\nFlow rates are so low that erosion of the pipeline cover is highly\nunlikely. Marine traffic consists of light, shallow draft boats\nand an occasional flat-bottomed barge, none of which can be\nexpected to damage the pipeline within its 5-foot, filled trench by\ndirect contact or dragging anchor. For these reasons, we conclude\nthat the probability of pipeline rupture at these water crossings\nis not appreciably greater than that for the remainder of the\npipeline.\n3. Drainage from Line after Shutdown\nPlacement of valves on either side of the water crossing is to\nlimit line drainage into the waterway after shutdown in the event\nof rupture at a crossing. In your proposed valving plan locations,\nDrawing No. SK-0146 showing pipeline water crossings, even though a\ndal\\195\\260\\76-04-08\n10\n\n<<<PAGE 11>>>\n\nvalve is not near a crossing, very little oil is expected to escape\nfrom any line rupture that might occur at the crossing after\nshutdown occurs and all dynamic effects cease. The maximum grade\nelevation variation along the pipeline is limited to approximately\n15 feet. The elevation at Clovelly Dome is 0 feet to -1 foot, and\nat the St. James Terminal, the elevation is approximately +14 feet\nat the delivery manifold. Eighty percent of the pipeline will be\ninstalled in marsh and swamp areas using weight coating for\nstability. It is reasonable to postulate for practical purposes\nthat the line will lie mostly beneath the water level and that\nafter shutdown, water pressure will confine most of the line fill\nto the pipeline except for small amounts displaced by the\ndifferential in density between oil and water.\nTherefore, in consideration of the above information and\nconclusions, the Materials Transportation Bureau finds that valves\nand a leak detection system installed and operated as proposed in\nyour letter of June 19, 1979, will provide an acceptable level of\npublic safety and that placement of valves on each side of every\nwater crossing, other than the Intracoastal Waterway, along the\nLOCAP pipeline is not justified.\nSincerely,\n\\signed\\\nCesar DeLeon\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\ndal\\195\\260\\76-04-08\n11\n\n<<<PAGE 12>>>\n\nShell Pipe Line Corporation\nJune 19, 1979\nMr. Cesar De Leon, Associate Director\nfor Pipeline Safety Regulation\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nDear Mr. De Leon:\nShell Pipe Line will construct LOCAP Pipeline, a 48-inch diameter\ncrude oil pipeline between the Louisiana Offshore Oil Port (LOOP)\nterminal at Clovelly, Louisiana, and the existing input terminal to\nthe Capline system at St. James, Louisiana, Capline, in turn,\ndelivers crude oil into the American mid-continent area.\nThe LOCAP pipeline segment was originally a part of the LOOP permit\napplications and approvals. Recently the owners of LOCAP Pipeline\n(Texaco, Inc., Marathon Pipe Line Company, Ashland Oil, Inc., and\nShell Pipe Line Corporation) selected Shell Pipe Line Corporation\nto construct and operate it.\nAs shown on the attached sketch, the LOCAP line begins at LOOPS's\nClovelly, Louisiana, underground storage dome in Section 32, T18S,\nR22E, LaFourche Parish, and extends in a northerly direction across\nmarshes, numerous bayous, swamps, the Intracoastal Canal, and some\nfarmland to the Capline Pipeline St. James Terminal located in\nSection 56, T12S, R16E, St. James Parish, Louisiana.\nConditions along the LOCAP pipeline route are such that\napproximately 85 percent of the pipeline will be installed in marsh\nand swamp areas using weight coating for stability. The pipeline\nwill be welded together and floated in a ditch excavated through\nthese areas. The pipeline will be submerged, and the floatation\nditch will be backfilled to cover the pipeline. Brackish and fresh\nwater will exist at various times of the year over most of the\nlength of the new pipeline.\nAs in the case of LOOP Pipe Line System, extensive wetlands exist\nalong most of the LOCAP pipeline route. Since approximately 18\nbayous and submerged land areas will be crossed where the width of\ndal\\195\\260\\76-04-08\n12\n\n<<<PAGE 13>>>\n\nthe crossing exceeds 100 feet (reference attached SK-046 (sic) for\ncrossing locations), we believe, as in the case of LOOP pipeline,\nstrict adherence to 49 CFR 195.206(c), \"Transportation of Liquids\nby Pipeline\", is neither practicable nor justifiable in this\nparticular case. Due to the existence of a combination of water\nand marsh or swamp along the proposed 48-inch pipeline, block\nvalves at all locations required by DOT regulations would not\nimprove line safety nor appreciably reduce pollution should a\nfailure occur.\nAccordingly, we propose to install block valves at both sides of\nthe Intracoastal Waterway, near Louisiana Highway 3199, near\nHighway 20, and at the initiating and delivery terminals. As shown\non the attached sketch, valves located at terminals and the\nIntracoastal Waterway will be remotely operable from the Capline\nSt. James Control Center. Maximum valve spacing will be\napproximately 16? miles. The recommended locations are accessible\nand serve a useful purpose should damage occur to the new pipeline.\nInstallation of valves in the above manner takes into consideration\nnumerous related pipeline control factors including the following:\nA. Leak Detection and Shutdown System\nLine integrity features will be included in the\nsupervisory control system to monitor the pipeline for\nleaks and provide rapid shutdown of the pipeline by the\noil movements controller in the event a leak is\ndetected. Two methods of monitoring for leaks will be\nincluded in the line integrity features. The first\nmethod, a dynamic computer model of the pipeline, will\nprovide rapid response to suddenly occurring leaks. The\nmodel will read telemetered pressures and flow rates\nfrom Clovelly and St. James. Utilizing hydraulic surge\ntheory, the model will calculate and compare calculated\nand telemetered hydraulic variables. Shell Pipe Line's\ncomputer program will ascertain the divergence between\nreal and calculated values and send appropriate alarms\nto the oil movements controller if a leak is indicated.\nThe second method of leak detection functions by\ncomparison of input and delivery volumes. Input and\ndelivery volumes from custody transfer quality meters at\nClovelly and St. James will be gathered each supervisory\nscan and will be read into a computer line balance\nprogram and compared at periodic intervals. At each\ncomparison, line fill between the measurement points\nwill be calculated by the computer and compared with the\nline fill calculation at the previous interval. Any\nchange in line fill between the two intervals will be\ndal\\195\\260\\76-04-08\n13\n\n<<<PAGE 14>>>\n\nB. included in the line balance comparison. When a\ndiscrepancy exists between the adjusted input and output\nvolumes exceeding a preset limit, a leak detection alarm\nwill be presented to the oil movements controller.\nUpon indication of a leak detection alarm, the oi l\nmovements controller will be able to shut down the pumps\nat Clovelly Station and isolate the pipeline by means of\nremotely controlled block valves at initiating and\ndelivery terminals and on each side of the Intracoastal\nCanal - Clovelly Station to East Bank of Intracoastal\nCanal, East Bank to West Bank of Intracoastal Canal, and\nWest Bank of Intracoastal Canal to St. James Terminal.\nPressure transmitters will allow monitoring of the\npressure in each of the three line sections for\nindications of leakage.\nPipeline Integrity at Planned Water Crossings (Excluding\nC. the Intracoastal Waterway)\nThe waterways to be crossed are all less than 10 feet\ndeep. The waterway flow rates are such that erosion of\nthe pipeline cover is highly unlikely. Marine traffic\nconsists of light, shallow draft boats and an occasional\nflat-bottomed barge, none of which can be expected to\ndamage the pipeline within its 5-foot backfilled trench\nby direct contact or dragging anchor. A significant\ndegree of protection from exterior mechanical damage\nwill be provided by the steel reinforced concrete weight\ncoating approximately five inches thick and surrounding\nthe pipe. It may, therefore, be concluded that the\nprobability of pipeline rupture at these water crossings\nis not greater than that for the remainder of the\npipeline.\nDrainage from Line after Shutdown\nUnder the proposed valving plan, even though a valve may\nnot be near a point of rupture, very little oil is\nexpected to escape from any rupture after shutdown\noccurs and all dynamic effects cease. Because the\nmaximum grade elevation variation along the pipeline is\nlimited to approximately 15 feet (Clovelly Dome is 0\nfeet to -1 feet, St. James Terminal is approximately +14\nfeet at the delivery manifold) and because much of the\nline lies beneath the water level, the line fill should\nbe confined to the pipeline by water pressure except for\nsmall amounts displaced by the differential in density\nbetween oil and water.\nIn consideration of the above, your concurrence with\ndal\\195\\260\\76-04-08\n14\n\n<<<PAGE 15>>>\n\nLOCAP pipeline valve placement at water and road crossings as\nrecommended is requested in lieu of requirements established under\nthe provisions of 195.260(e) Part 195, Transportation of Liquids by\nPipeline, DOT - Pipeline Safety Regulations.\nVery truly yours,\n\\signed\\\nR. E. Speckmann, Manager\nRegulations and Maintenance Standards\nAttachments:\n1. Sketch No. SD-13712 showing line location.\n2. Drawing SK-0146 showing pipeline, water crossing, and\nproposed valve locations.\ndal\\195\\260\\76-04-08\n15","truncated":false,"body_characters":26707}