# Memo: Internal — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-78-028
- **title:** Memo: Internal — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1978-11-15
- **effective on:** Not available
- **summary:** PI-78-028 response to Memo: Internal concerning 192.457.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-78-028
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1978/PI78028.pdf
**body:**

<<<PAGE 1>>>

MEMORANDUM
Date: November 15, 1978
SUBJECT: Interpretation of §192.457(b) & (c)
FROM : Associate Director for Pipeline Safety Regulation
TO :Associate Director for Operations and Enforcement
This refers to your memorandum of July 12, 1978, regarding CPF 2315 in which
you ask the following questions:
May an operator reasonable conclude that corrosion in a specific area will
not cause a condition detrimental to public safety, and that it is, therefore,
unnecessary for him to meet the electrical survey requirements of
192.457(b) in those areas and yet remain in compliance with that section of
the regulations? If yes, what is rationale?
Section 192.457(b) requires that certain pipelines be cathodically protected in
areas in which active corrosion is found. "Active corrosion" is defined under
Section 192.457(c) as continuing corrosion which, unless controlled, could result
in a condition that is detrimental to public safety. An operator must determine
areas of active corrosion by electrical survey or where an electrical survey is
impractical, by the study of corrosion and leak history records, by leak detection
survey, or by other methods.
Thus, determinations by an operator that an area of corrosion will not cause a
condition detrimental to public safety (or that "active corrosion" is not present)
must be made on the basis of an electrical survey or where an electrical survey is
impractical on the basis of some other acceptable means of determining active
corrosion.
The determination may not be made arbitrarily so as to avoid the requirement to
run an electrical survey where it is practical to do so. The various factors relevant
to deciding whether an electrical survey is
dal\192\457\78-11-15
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<<<PAGE 2>>>

"impractical" and whether "active corrosion" is present were published in a notice
in the Federal Register on July 15, 1976, a copy of which is attached.
Cesar De Leon
Attachment
dal\192\457\78-11-15
2
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