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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-75-001 ([Wyoming Public Service Commission] [Richard L. Valent])

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

Interpretation Response Details

Response Publish Date:

Company Name: Wyoming Public Service Commission

Individual Name: Richard L. Valent

Location State: WY Country: US

View the Interpretation Document

Response text:

Mr. Richard L. Valent
Wyoming Public Service Commission
Supreme Court Building
Cheyenne, WY 82002

Dear Mr. Valent:

Thank you for your letter of December 6, 1974, asking several questions concerning the
applicability of 49 CFR 192.457(b)(1) to two mechanically coupled, bare transmission lines
constructed in the 1930's.

You ask whether installing anodes when leaks detected on the lines are repaired satisfies section
192.457(b)(1). This section requires that bare or ineffectively coated transmission lines installed
before August 1, 1971, except for cast or ductile iron lines, be cathodically protected in
accordance with Subpart I in areas in which active corrosion is found. In addition, section
192.457(b) requires the operator to determine areas of active corrosion by electrical survey, or if
impractical, by studying corrosion or leak history records, by leak detection survey, or by other
means. Thus, the method proposed for compliance with section 192.457(b)(1) would be
satisfactory only where it is impractical to find areas of active corrosion by electrical survey and
instead leak surveys are utilized, and the cathodic protection installed complies with Subpart I,
specifically section 192.463.

Secondly, you ask if section 192.467(b)(1) is intended primarily for transmission lines traversing
areas with heavy population. The requirements of section 192.457(b)(1) apply regardless of the
population of the areas in which a transmission line is located.

Finally, you ask if the company involved may apply to this office for waiver of applicable
requirements. Assuming the transmission lines to which you refer are under the jurisdiction of the
Wyoming Public Service Commission, section 3(e) of the Natural Gas Pipeline Safety Act of 1968
provides that the Commission, as a certified State agency, may grant waivers from compliance
with the Federal gas pipeline safety standards, subject to the approval of the Secretary of
Transportation. Because of this unique Federal and State relationship, the Commission is the
proper forum at which the company should present its request for waiver rather than this office.

We trust this adequately responds to your inquiry.

Sincerely,

Joseph C. Caldwell
Director
Office of Pipeline Safety

Regulation Sections

Section Subject
192.457 External corrosion control: Buried or submerged pipelines installed before August 1, 1971