{"operation":"document","citation":"PI-83-005","title":"ADB 83-2 — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1983-03-31","effective_on":null,"summary":"PI-83-005 response to ADB 83-2 concerning 192.461, 192.463.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/PI83005.pdf","body":"<<<PAGE 1>>>\n\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\n49 CFR Part 192\n(Interpretations 83-1, 83-2)\nTransportation of Natural and Other Gas\nby Pipeline; Corrosion Control Monitoring\nAGENCY: Materials Transportation Bureau (MTB)\nACTION: Interpretation\nSUMMARY: Operators of gas pipelines are required by 49 CFR §192.465 to monitor their\npipelines for corrosion control purposes. Questions have risen in the enforcement of this\nregulation about its application to (1) cathodic protection that has been voluntarily installed, and\n(2) pipelines in remote areas. Agency interpretations provide that (1) pipelines with voluntarily\ninstalled cathodic protection are subject to the 3-year re-evaluation requirements but not the\nannual monitoring rule, and (2) electrical surveys are not required for pipelines in remote areas if\nit can reasonably be concluded that corrosion-caused leaks in those areas would not be\ndetrimental to public safety.\nEFFECTIVE DATE: (Insert date of publication in the Federal Register)\nFOR FURTHER INFORMATION CONTACT: L.M. Furrow, 202-426-2392.\nSUPPLEMENTARY INFORMATION:\nInterpretation 83-1\nSection: 192.465(a)\nSubject: Monitoring cathodic protection that is voluntarily installed.\nFacts: None.\nQuestion: In Amendment 192-35 (44 FR 75384, December 20, 1979), which permitted short\nsections of cathodically protected transmission lines to be tested on a sampling basis, the\nMaterials Transportation Bureau stated that the \"regulation applies to pipelines that are separately\nprotected by the 'hot spot' method.\" Does this mean that anodes an operator voluntarily installs\nwhenever a pipeline is uncovered are subject to the testing requirements of §192.465(a)?\nDB\nC:\\WP51\\INTERPRT\\192\\457\\83-03-31\n1\n\n<<<PAGE 2>>>\n\nInterpretation: Section 192.465(a) requires, in part, that each pipeline that is under cathodic\nprotection must be tested \"to determine whether the cathodic protection meets the requirements\nof §192.463.\" In §192.463, paragraph(a) prescribes the level of cathodic protection that each\ncathodic protection system \"required by this subpart\" (Subpart I of Part 192) must provide. The\nreference to the requirements of §192.463, which, consistent with §192.463(a), only apply to\ncathodic protection systems that are required by Subpart I, strongly implies that the testing\nrequirements of §192.465(a) only apply to pipelines on which cathodic protection is required by\nSubpart I. There does not appear to be any contrary intent from our reading of the history of\n§192.465(a) and Subpart I. Further, to apply the testing requirements to voluntarily installed\nanodes (or cathodic protection that is not required by Subpart I) would tend to discourage\nvoluntary practices that are in the interest of public safety. Pipelines on which anodes have been\nvoluntarily installed would, however, be subject to the 3-year re-evaluation requirements of\n§192.465(e) which by logical extension of the above reasoning, apply to pipelines that are not\ncathodically protected as required by Subpart I.\nInterpretation 83-2\nSection: 192.457(c) and 192.465(e)\nSubject: Electrical surveys in remote areas.\nFacts: None\nQuestion: In the case of cathodically unprotected pipelines located in remote areas, must an\nelectrical survey be performed, where practical, as part of the 3-year re-evaluation required by\n§192.465(e), even though circumstances indicate that any corrosion found by the survey would\nnot be expected to endanger public safety?\nInterpretation: The purpose of §192.465(e) is to require that cathodic protection be installed\nwhere \"active corrosion\" exists on unprotected pipelines. The term \"active corrosion\" is defined\nin §192.457(c) to mean \"continuing corrosion which, unless controlled, could result in a condition\nthat is detrimental to public safety.\" As this definition implies, there are segments of pipelines on\nwhich continuing corrosion would not endanger public safety. Indeed, the preamble to\nAmendment 192-4, which established §§192.457(c) and 192.465(e), makes it clear this\nimplication is intended by the definition of \"active corrosion.\" Such segments might be found in\nremote locations or other places where because of the pipeline's distance from people, it is not\nreasonable to foresee that corrosion or, worse, a corrosion-caused leak would be detrimental to\npublic safety. Similarly, corrosion determined to be progressing so slowly that leakage would not\nresult before the next 3-year re-evaluation would not be detrimental to public safety.\nBecause §192.457(b) as well as §192.465(e) requires the use of electrical surveys in determining\nthe existence of active corrosion, the Office of Pipeline Safety Operations stated in a 1976\ninterpretation (41 FR 29128) that an electrical survey is the first step in finding active corrosion.\nAs a result, operators have had to conduct surveys on pipelines located in remote areas even\nthough corrosion-caused leaks in those locations would not be considered detrimental to public\nsafety.\nDB\nC:\\WP51\\INTERPRT\\192\\457\\83-03-31\n2\n\n<<<PAGE 3>>>\n\nWe believe that to blindly run electrical surveys in areas where existing and reasonably foreseeable\ncircumstances show that corrosion-caused leaks would not be detrimental to public safety is\ninconsistent with the \"active corrosion\" definition. Therefore, we will no longer apply the 1976\ninterpretation on this subject. Instead, in complying with the 3-year re-evaluation required by\n§192.465(e), operators may, first, consider all factors relevant to determining whether a\ncorrosion-caused leak occurring within the 3 years before the next re-evaluation would be\ndetrimental to public safety. Then, in areas where it is reasonable to foresee that such leaks would\nbe detrimental to public safety, §192.465(e) requires that electrical surveys be run, if practical, to\nlook for continuing corrosion and that cathodic protection be applied where continuing corrosion\nis found.\n(49 USC 1672 and 1804; 49 CFR 1.53, Appendix A to Part 1, and Appendix A to Part 106)\nIssued in Washington, D.C. on_______________________________.\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDB\nC:\\WP51\\INTERPRT\\192\\457\\83-03-31\n3","truncated":false,"body_characters":6228}