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DOCKETS UNIT <br />PAGE FOURTEEN <br />MARCH 24, 1987 <br />exists to document the fact that a risk to the public or <br />environment does not exist. <br />10. Proposal: <br />Require existing hazardous liquid pipelines to be coated or <br />cathodically protected to prevent corrosion. (52780) <br />Response: <br />To not require that existing uncoated pipelines be coated and <br />cathodically protected places the public and the environment <br />at great risk unnecessarily. There is no effective techno- <br />logy currently available that can accurately pinpoint active <br />corrosion nor is cathodic protection a fool -proof means to <br />prevent active corrosion from growing and causing detrimental <br />effects upon the structural integrity of a pipe. Even the <br />use of combined coating and cathodic protection is no <br />guarantee but two lines of defense that are aggressively <br />monitored and maintained are better than an ineffective <br />defense against corrosion which is what coating or cathodic <br />protection alone would be. <br />Questions: <br />(a) What would be the added cost of requiring full <br />cathodic protection on existing pipelines that are <br />ineffectively coated or bare? <br />Response: <br />The City is not in a position to determine costs for <br />implementing this proposal. <br />(b) Would this investment pay for itself in terms of <br />preventing corrosion caused accidents? <br />Response: <br />To answer a question with a question, what would be the <br />cost to the industry and the regulator both in actual <br />damages and goodwill if an accident or accidents were to <br />occur resulting in injury(ies), death(s) or environ- <br />mental damage and it was learned that no efforts were <br />undertaken to prevent corrosion? In our opinion any <br />expense to prevent those terrible possibilities is <br />prudent and reasonable. <br />(c) what alternatives to the present or proposed require- <br />ments are there to prevent corrosion -caused leaks on <br />existing pipelines? <br />