KENTUCKY UTILITIES CO — Integrity Assurance Notification

ASSUMED TOUGHNESSLouisville Gas and Electric Company (LG&E, Operator ID 11824) operates approximately 348 miles of transmission pipeline in Kentucky. Its sister company, Kentucky Utilities Company (KU, Operator ID 30054), operates approximately 11 miles of transmission pipeline in Kentucky. I am writing to you in accordance with §192.18 to request the use of other alternative accepted industry test methods to determine fracture toughness value for evaluating cracks and crack-like defects in pipeline steel by LG&E and KU. The other alternative test methods are J-R curve testing and Crack Tip Opening Displacement (CTOD) testing conducted in accordance with ASTM E1820 or ISO 12135 or ISO 15653 (refs. [1,2,3]). Both J-R curve and CTOD tests are direct methods of determining the fracture toughness of pipeline steels and are appropriate for evaluation of cracks and crack-like defects. These test methods comply with §192.607(c)(3) and §192.607(c)(4).#