{"operation":"document","citation":"PI-98-0102","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":"1998-07-31","effective_on":null,"summary":"PI-98-0102 response to West Virginia Public Service Commission concerning 192.453, 192.467.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-0102.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-0102.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-0102","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1998/g98_07_31_Hippchen_192.453_nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-98-0102\nJuly 31, 1998\nMr. David A. Hippchen\nGas Pipeline Safety Section\nWest Virginia Public Service Commission\nPO Box 812\nCharleston, WVA 25323\nDear Mr. Hippchen:\nThis responds to your letter of May 6, 1998, regarding the gas pipeline safety standard on electrical isolation in 49 CFR\n192.467(f). Our answers to your inquiries are set out below.\nSection 192.467(f) reads as follows: \"Where a pipeline is located in close proximity to electrical transmission tower\nfootings, ground cables or counterpoise, or in other areas where fault currents or unusual risk of lightning may be\nanticipated, it must be provided with protection against damage due to fault currents or lightning, and protective\nmeasures must also be taken at insulating devices.\"\nQuestion 1. Is close proximity an absolute distance or some minimum distance at which interference with the\npipeline corrosion control system or damage to the pipeline coating can be measured or calculated?\nAnswer. Considering the purpose of § 192.467(f), \"close proximity\" means near enough to the listed structures to\nreasonably expect that a lightning strike on the structure might harm the pipeline's corrosion control system. Close\nproximity is not an absolute or minimum distance, and it could vary depending on site conditions. Under § 192.453, the\ndistance must be determined by a person qualified in pipeline corrosion control methods. Thus, we have not determined\nwhether the distances you listed in situation #2 are within a close proximity of the structures.\nQuestion 2. Can an operator adopt an absolute distance standard to define close proximity?\nAnswer. An absolute distance would be all right as long as a qualified person would reasonably expect that a pipeline\nlocated outside that distance would not likely be harmed.\nQuestion 3. What threshold voltage measurement/calculation is reasonable to determine if protective\nmeasures must be taken?\nAnswer. Section 192.467(1) does not specify a threshold voltage in connection with protective measures. This voltage\nwould be determined by a person qualified in pipeline corrosion control methods.\nQuestion 4. What constitutes an electrical transmission line (and thus, tower) for which this section applies?\nAnswer. Under § 192.467(f), the term \"electrical transmission tower\" is used in its ordinary sense to refer to tall\naboveground steel structures that support cables used to transmit electricity over long distances. The term does not\ninclude poles that support cables used to distribute electricity throughout a community.\nQuestion 5. Can this section be read to include protecting the pipeline from induced currents?\nAnswer. No, protection is required only against fault currents and lightning.\nI trust you find this information helpful. If we can be of any further assistance, please call me at (202)366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nDirector, Office of Technology and Standards\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nPublic Service Commission Of West Virginia\n201 Brooks Street\nP.O. Box 812\nCharleston, West Virginia 25323\nMay 6, 1998\nU. S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh Street, SW\nWashington, DC 20590\nGentlemen:\nSeveral gas transmission pipeline operators have asked our field inspectors for definition or clarification of certain\nprovisions of the Code in regard to external corrosion control, electrical isolation. Specifically, the questions\npertain to Part 192 Section 192.467(f) which provides:\n\" Where a pipeline is located in close proximity to electrical transmission tower footings, ground cables or\ncounterpoise, or in other areas where fault currents or unusual risk of lightning may be anticipated, it must be\nprovided with protection against damage due to fault currents or lightning, and protective measures must also\nbe taken at insulating devices.\"\nSituation 1:\nOne of our situations involves a response by a Columbia Gas Transmission engineer during a routine field inspection, in\nwhich he stated: \"There is no pipeline located in close proximity to electrical transmission tower footings, ground cables\nor counterpoise, or in other areas where fault currents may be anticipated, even though (notwithstanding) in several\ninstances there are electrical transmission lines crossing or running approximately parallel to the Columbia Gas\nTransmission pipeline, and in several situations induced voltages have been recorded.\" No recommended violation was\nforwarded to the Eastern Region for this inspection, and I am not aware of any other inspections in which our pipeline\nsafety personnel have pursued a violation enforcement action regarding this Code section. We are interested in your\nthoughts or interpretations on the following questions so that we may more thoroughly evaluate an operator's\nperformance and compliance with this Code section:\n1. Is close proximity an absolute distance or some minimum distance at which interference with the pipeline corrosion\ncontrol system or damage to the pipeline coating can be measured or calculated?\n2. Can an operator adopt an absolute distance standard to define close proximity?\n3. What threshold voltage measurement/calculation is reasonable to determine if protective measures must be\ntaken?\n4. What constitutes an electrical transmission line (and thus, tower) for which this section applies?\n5. Can this section be read to include protecting the pipeline from induced currents?\n\n<<<PAGE 3>>>\n\nSituation 2:\nThe relative position of a pipeline with respect to the electrical transmission tower footings is as follows:\nSystem Distance from structure\n1. 2300 V Wheeling Electric power line TIE Rt. 55' to pole (structure)\n2. 2300V WE power line TIE Rt. 40' to pole (structure)\n3. Wheatley power line TIE Rt. 123' to power pole (structure)\n4. 66000V WE power line TIE Rt. 200' to steel power tower\n5. 32000V WE power line TIE Rt. 61' to steel power tower\n6. 25000V WE power line TIE Rt. 74' to steel power tower\nHow do you determine, test, or calculate \"close proximity\" for the above examples?\nYour consideration of these issues is greatly appreciated. If you need further information please let me know.\nSincerely,\nDavid A. Hippchen, PE\nTransportation Division\nGas Pipeline Safety Section","truncated":false,"body_characters":6262}