{"operation":"document","citation":"PI-92-025","title":"Arizona Corporation Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1992-07-09","effective_on":null,"summary":"PI-92-025 response to Arizona Corporation Commission concerning 192.451.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-025.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-025.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-025","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1992/PI92025.pdf","body":"<<<PAGE 1>>>\n\nMr. Dan H. Weaklend\nChief, Pipeline Safety Utilities Division\nArizona Corporation Commission\n1200 W. Washington Street\nPhoenix, AZ 85007\nDear Mr. Weaklend:\nThank you for your letter of June 5, 1992, suggesting regulatory actions to improve operators'\ncorrosion control programs. Specifically, you suggested we drop the generic specification\napproach found in Appendix D of Part 192, and adopt instead a system-specific approach. Under\nthis alternative, operators would (1) include corrosion control criteria and procedures in their\noperating and maintenance plans, and (2) determine the cause of each corrosion leak and take\ncorrective action.\nBecause corrosion continues to be a major cause of pipeline accidents, we support your desire to\nsee that operators do as much as possible to correct the problem. We are concerned, though, that\ndeleting Appendix D, as suggested, would not solve the problem. Corrosion control is a complex\nscience, the principles of which do not vary from system to system. So we see no good reason to\nallow variations in control criteria. In fact, lack of uniform criteria has been a problem in\nenforcing corrosion control under Part 195, which specifies no corrosion control criteria. Non-\nuniform criteria under Part 192 could further increase the enforcement workload by requiring\ninspectors to verify the legitimacy of criteria operators put in their plans.\nThe Appendix D criteria were based on the National Association of Corrosion Engineers (NACE)\nStandard RP-01-69. NACE recently revised this standard, and we expect it will petition us to\nadopt the revised version. The pipeline industry's use of this new standard should assure\nconsistent and correct corrosion control.\nAs for procedures and leak investigations, these topic are already regulated. Section 192.453\nrequires gas operators to follow procedures in applying corrosion control. Similar requirements\nare in §193.2625 and §195.402(c)(3). Determining the cause of corrosion leaks is covered by\n§§192.617, 193.2515, and 195.402(c). We agree that operators with numerous corrosion leaks\nshould be asked to explain their actions or lack of action, but the rules needed to require\noperators to take proper corrective actions are already in the regulations.\ndal\\192\\451\\92-07-09\n1\n\n<<<PAGE 2>>>\n\nIf you have any further concern, please call Jim Thomas, Director, SouthWest Region at (703)\n750 1746.\nSincerely,\n/signed/\nCesar DeLeon, Director\nOffice of Pipeline Safety\ndal\\192\\451\\92-07-09\n2","truncated":false,"body_characters":2495}