Kentucky Public Service Commission — Pipeline Safety Interpretation

Page 1PI-92-0107 October 13, 1992 Mr. E. Scott Smith Gas Pipeline Safety Branch Kentucky Public Service Commission Post Office Box 615 Frankfort, KY 40602 Dear Mr. Smith: Your letter of July 10, 1992, requests an opinion concerning the applicability of 49 CFR 192.465 to jurisdictional sections of a buried gathering line. You asked whether the term "in its entirety", as cited in 49 CFR 192.455(a)(2), limits the applicability of § 192.465 to pipelines that are cathodically protected over their full length. We agree with your interpretation that § 192.465 requires the cathodically protected jurisdictional sections to be tested once each calendar year, even if the remainder of the gathering line is not protected. The phrase "in its entirety," as cited in 49 CFR 192.455(a)(2), embraces only pipelines or sections of pipeline that are subject to 49 CFR Part 192. A line does not have to be cathodically protected from end to end if part of the line is non-jurisdictional; only the jurisdictional portion requires cathodic protection. Thus, jurisdictional sections of gathering line that must be protected under § 192.455(a)(2) must be tested in accordance with 49 CFR 192.465. We trust that this responds satisfactorily to your request. Sincerely, Original Sign By Cesar De Leon Director, Regulatory Programs Office of Pipeline Safety#

Page 2COMMONWEALTH OF KENTUCKY PUBLIC SERVICE COMMISSION 730 SCHENKEL LANE POST OFFICE BOX 615 FRANKFORT, KY. 40602 July 10, 1992 Mr. Cesar De Leon Director, Regulatory Programs Office of Pipeline Safety 400 7th Street, S.W., Room 8417 Washington, D.C. 20590 Dear Cesar: Please provide us an interpretation of how the wording "in its entirety" is applied in the case described in our attached correspondence with Ashland Exploration, Inc. We feel that a buried gathering line in a Class 3 area is required to be cathodically protected and that the pipeline under cathodic protection must be tested once each calendar year, but with intervals not exceeding 15 months to determine whether the cathodic protection meets the requirements of 192.463 per 192.465. Ashland Exploration contends that this requirement applies to a pipeline in its entirety whether it is in Class 3 or not and that the pipeline is only required to be monitored every 3 years. Your early response will be greatly appreciated since Ashland needs to know the resolution of this question before entering into a contract for cathodic protection in the very near future as indicated in its response. Thank you for your help in this matter. Sincerely, E. Scott Smith, Manager Gas Pipeline Safety Branch#