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Interpretation Response #PI-05-0102 ([City of Mesa] [Mr. Gerald Paulus])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: City of Mesa

Individual Name: Mr. Gerald Paulus

Location State: AZ Country: US

View the Interpretation Document

Response text:

PI-05-0102

November 9, 2005

Mr. Gerald Paulus
Gas Division Director
City of Mesa
640 N. Mesa Drive
Mesa, AZ 85211-1466

Dear Mr. Paulus:

In your letter dated August 10, 2004, you requested an interpretation of 49 CFR 192.465(a) External corrosion control: Monitoring, regarding steel service risers insta1lled on plastic service lines.

Section 192.465(a) states that each pipeline that is under cathodic protection must be tested at least once each calendar year, but with intervals not exceeding 15 months, to determine whether the cathodic protection meets the requirements of § 192.463. However, if tests at those intervals are impractical for separately protected short sections of mains or transmission lines, not in excess of 100 feet (30 meters), or separately protected service lines, these pipelines may be surveyed on a sampling basis. At least 10 percent of these protected structures distributed over the entire system must be surveyed each calendar year, with a different 10 percent checked each subsequent year, so that the entire system is tested in each 1O-year period.

You asked for an interpretation of the term "separately protected service lines." The term, "separately protected service lines" refers to a buried or submerged service line that is electrically isolated and cathodically protected from other metallic structures.

You also asked if separate steel service risers are "separately protected service lines" when they are electrically interconnected by a tracer wire and protected by a common current source or distributed anodes. Separate steel service risers that are electrically interconnected and cathodically protected by a common source are not separately protected lines. Therefore, §192.463(a) requires an operator to monitor such pipelines at least once each calendar year, but with intervals not exceeding 15 months, to determine whether the cathodic protection meets the requirements of §192.463.

The regulations do not address the specific pipe material, e.g. tracer wire, that an operator may select to achieve an electrically interconnected pipeline system; however, operators are expected to rely on sound engineering design and select materials that allow them to determine whether the cathodic protection meets the requirements of §192.463.

If you have additional questions, please feel free to contact James Reynolds of my staff at (202) 366-2786.

Sincerely,

Florence L. Hamn
Director of Regulations
Office of Pipeline Safety

Regulation Sections

Section Subject
192.463 External corrosion control: Cathodic protection