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Interpretation Response #PI-76-010 ([Control Incorporated] [Earl L. Kirkpatrick])

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

Interpretation Response Details

Response Publish Date:

Company Name: Control Incorporated

Individual Name: Earl L. Kirkpatrick

Location State: AL Country: US

View the Interpretation Document

Response text:

March 1, 1976

Mr. Earl L. Kirkpatrick
Manager Corrosion Services
Control Incorporated
P.O. Drawer 888
Oneonta, Alabama 35121

Dear Mr. Kirkpatrick:

This refers to your letter of November 25, 1975, in which you ask our opinion whether the
conduct of an electrical survey in each of several situations would be "impractical" within the
meaning of 49 CFR 192.457(b), which reads in part:

"The operator shall determine the areas of active corrosion by electrical survey, or where
electrical survey is impractical, by the study of corrosion and leak history records, by leak
detection survey, or by other means."

Based on the ordinary meaning of the term "impractical," we do not believe that it would be
impractical to conduct electrical surveys in any of the situations as you have described them.


Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections

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