Interpretation Response #PI-76-064
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
September 20, 1976
Ms. Victoria Bandi
Union Real Estate Company
428 Forbes Avenue
Pittsburgh, Pennsylvania 15219
Dear Ms. Bandi:
This is in reply to the questions posed in your letter of August 31, 1976.
Question 1: Is an underground gas line from the curb to an existing apartment building required to be tested by a cathodic engineer?
Answer: Presuming that the gas line is used in the distribution of gas subject to the jurisdiction of the Federal gas pipeline safety standards in 49 CFR Part 192, it must be tested in accordance with Section 192.465. Also, if the line was installed before August 1, 1971, Section 192.457(b) requires that the line be electrically surveyed for active corrosion. Section 192.453 requires that the survey and tests be performed or directed by a person qualified by experience or training in corrosion control methods. The term "cathodic engineer" is not used in the Federal standards.
Question 2: If so, whose responsibility would it be to make such test; the supplying gas company or the owner of the apartment building?
Answer: The "operator" of the line as defined is Section 192.3 would be responsible for making the test. Since your letter does not contain information about the disposition of the gas transported in the pipeline, who owns the pipeline, and the location of all meters involved, we are unable to tell which person is the "operator."
Question 3: If such test is required, when is such test to be made?
Answer: The various time requirements as appropriate are set out in the applicable safety standards.
We have enclosed a copy of the Natural Gas Pipeline Safety Act of 1968 and the Federal standards.
Office of Pipeline