Interpretation Response #PI-72-046 ([Equitable Gas] [Charles M. Rutter, Jr.])

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

Interpretation Response Details

Response Publish Date: 10/13/1972

Company Name: Equitable Gas

Individual Name: Charles M. Rutter, Jr.

Location State: PA Country: US

View the Interpretation Document

Response text:

October 31, 1972

Mr. Charles M. Rutter, Jr.

Equitable Gas

420 Boulevard of the Allies

Pittsburgh, Pennsylvania 15219

Dear Mr. Rutter:

This is in response to your letter of September 29, 1972, in which you described a procedure for preparing a surface to receive a protective coating for the purpose of external corrosion control. You ask if your procedure meets the requirements of Section 192.461(a)(1) and, if so, whether such a procedure is required for appurtenances that are to be installed below ground and are to be hand coated at the time of installation.

As we understand your procedure, the properly prepared surface is obtained by grit blast cleaning (or equal) down to the parent structure of the metal, followed by application of a primer that is approved or recommended by the coating manufacturer. From the information presented, this procedure appears to meet the requirements of Section 192.461(a)(1).

With respect to your question on the application of such a procedure to underground appurtenances, there is no requirement that Section 192.461(a)(1) be met solely in this manner. The regulation is stated as a performance type standard and the method of compliance is left to the operator. Because of the odd shapes of pipeline appurtenances and the penetrating effect of some coatings and primers, the decision as to what constitutes a "properly prepared surface" in a particular case is left to the operator.

Your continued interest in the pipeline safety program is appreciated.

Sincerely,

Joseph C. Caldwell

Director

Office of Pipeline Safety

Regulation Sections