{"operation":"document","citation":"PI-76-019","title":"West Virginia Public Service Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-04-15","effective_on":null,"summary":"PI-76-019 response to West Virginia Public Service Commission concerning 192.457.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-019.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-019.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-019","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76019.pdf","body":"<<<PAGE 1>>>\n\nMr. T. K. Spalding, Director\nGas Pipeline Safety Division\nWest Virginia Public Service Commission\nCharleston, West Virginia 25305\nDear Mr. Spalding:\nThis refers to your letter of March 8, 1976, discussing problems in enforcing the Federal Gas\npipeline safety standards against small operators in West Virginia.\nThe first problem concerns the requirement of Section 192.457(b) that certain pipelines be\ncathodically protected \"in areas in which active corrosion is found.\" Section 192.457(c) defines\n\"active corrosion\" as \"continuing corrosion which, unless controlled, could result in a condition\nthat is detrimental to public safety.\" The office of Pipeline Safety interpreted the requirement to\napply \"if the continuing corrosion could at some future time result in a condition that is then\ndetrimental to public safety, even though today such condition does not exist.\"\nThe purpose of that interpretation was to explain that an operator must consider whether hazards\nare likely to arise in the future due to continuing corrosion rather than just consider the immediate\ncircumstances. We believe that it would be incorrect to conclude that the interpretation results in\na requirement \"to stop corrosion per se\" or that \"all pipelines regardless of location must be\ncathodically protected.\" On the contrary, as you say \"stopping corrosion where public safety is\ninvolved,\" with an eye toward the likely future hazard presented by that corrosion, more\nappropriately states the meaning of the regulation.\nDetermining whether cathodic protection is mandatory under Section 192.457(b) is a two step\nprocess. First, an operator must find areas of continuing corrosion by electrical survey or other\nallowable methods. If continuing corrosion cannot be found by proper application of those\nmethods, cathodic protection is not required. Secondly, where continuing corrosion is found, the\noperator must determine whether a condition detrimental to public safety could result therefrom,\ntaking into account the short and long range effect of the corrosion on the pipeline, the pipeline's\nproximity to people, and all other factors relevant to public safety. If after consideration of all\nrelevant factors, it can reasonably be concluded that a condition detrimental to public safety\nwould not be likely to result, cathodic protection is not required. If a pipeline remains\nunprotected, Section 192.465(e) requires that it be re-evaluated every 3 years for the existence of\n\"active corrosion.\"\nDB\nC:\\WP51\\INTERPRT\\192\\457\\76-04-15\n1\n\n<<<PAGE 2>>>\n\nThe second problem concerns the requirement for cathodically protecting a pipeline which is\nlocated so that the bottom portion is buried and the top portion extends above the ground level.\nYou give various reasons why cathodic protection should not be required which apply to leaks\noccurring on aboveground pipelines. We believe, however, that subjecting a partially buried\npipeline to the same cathodic protection requirements applicable to a fully buried pipeline is\njustifiable. The same electrochemical agents which cause corrosion on underground pipelines are\nequally active with respect to a partially buried pipeline.\nFinally, you suggest that upon request by the Fifty-Two Gas Company for a waiver from\ncompliance with the requirement for periodic testing of odorant level, and after investigation and\napproval by the Commission, that we should grant the waiver for a specific time period. The\nlimited information which your letter includes as to the natural odor of the gas does not in our\nopinion justify the granting of a waiver from the periodic testing requirement. Should the\nCommission decide that a waiver is appropriate, we will of course review the matter in\naccordance with the procedures set forth in Sec. 3(e) of the Natural Gas Pipeline Safety Act of\n1968.\nWe trust that we have satisfactorily responded to your inquiry.\nSincerely,\nCesar DeLeon\nActing Director\nOffice Of Pipeline\nSafety Operations\nDB\nC:\\WP51\\INTERPRT\\192\\457\\76-04-15\n2","truncated":false,"body_characters":4010}