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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-19-0009

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

Interpretation Response Details

Response Publish Date:

Company Name: Elecsys Corporation

Individual Name: Mr. Jamey Hilleary

Location State: KS Country: US

View the Interpretation Document

Response text:

Mr. Jamey Hilleary
Elecsys Corporation
846 N Mart-Way Ct.
Olathe, KS 66061

Dear Mr. Hilleary:

In a July 9, 2019, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Parts 192 and 195. Specifically, you requested an interpretation on remote monitoring systems to satisfy the cathodic protection monitoring requirements under Subpart I of Part 192 and Subpart H of Part 195.

You stated Elecsys produces and sells remote monitoring systems for test point station, critical bond and rectifier monitoring requirements that provide data on voltage and current measurements related to cathodic protection of pipelines. You stated the remote monitoring systems can provide cathodic protection monitoring consistently by transmitting measurement data in real-time to operators by means of a secure interface to web-based applications that enable identification of any protection system failure without delay.

You stated that there is some uncertainty about whether remote monitoring systems do satisfy the Parts 192 and 195 cathodic protection monitoring requirements. Therefore, you asked clarification and interpretive assistance with regards to remote monitoring systems and the cathodic protection monitoring requirements under §§ 192.465 et seq. and 195.563 et seq.

The purpose of both Subpart I of Part 192 and Subpart H of Part 195 is to prescribe minimum requirements for protecting steel pipelines against corrosion. The rule does not prescribe a means of inspection. Therefore, an operator must have procedures that define the technology to be utilized and must conduct its inspections utilizing technology or means it chooses if the testing method used accurately monitors the cathodic protection levels and provides information on the protection criteria that it is monitoring is at least equivalent to the Subpart I of Part 192 or Subpart H of Part 195 corrosion protection level requirements.

If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.

Sincerely,

John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.465 External corrosion control: Monitoring
195.563 Which pipelines must have cathodic protection?