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Interpretation Response #PI-89-003 ([Montana-Dakota Utilities Company] [Tony J. Finneman])

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

Interpretation Response Details

Response Publish Date:

Company Name: Montana-Dakota Utilities Company

Individual Name: Tony J. Finneman

Location State: ND Country: US

View the Interpretation Document

Response text:

Mr. Tony J. Finneman

Montana-Dakota Utilities Company

400 North Fourth Street

Bismarck, North Dakota 58501

Dear Mr. Finneman:

You have asked whether an operator who voluntarily places a cathodic protection system on a gas pipeline installed prior to August 1, 1971, with no evidence of active corrosion must provide a level of protection according to the criteria in Appendix D of Part 192. A corrosion mitigation measure that is provided as a general maintenance practice would result in these pipelines being considered "unprotected" for purposes of Section 192.463 and the 3-year reevaluation requirement of §192.465(e). The Appendix D criteria apply to cathodic protection that is provided to comply with regulations in Subpart I or Part 192.

In determining whether the Federal regulations require cathodic protection in the scenario outlined in your letter, you should assure that your program properly addressed all the requirements of the regulations, such as using the definition of active corrosion under §192.457(c). Also, in determining whether the electrical survey required by §192.457(b)(3) and §192.465(e) is impractical, you must consider all factors that relate to the impracticality, including public safety, not just economics. Copies of related interpretations published in OPS Advisory Bulletins are enclosed for guidance in implementing your program.

Sincerely,

Richard L. Beam

Director

Office of Pipeline Safety

Regulation Sections

Section Subject
192.457 External corrosion control: Buried or submerged pipelines installed before August 1, 1971
192.463 External corrosion control: Cathodic protection
192.755 Protecting cast-iron pipelines