Sun Pipe Line Company — Pipeline Safety Interpretation

Page 1PI-74-0140 October 7, 1974 Mr. Clarence J. Yablonski Director of Safety Sun Pipe Line Company General Washington Building 216 Goddard Boulevard King of Prussia, PA 19406 Dear Mr. Yablonski: This responds to your letter of June 21, 1974, concerning the practice of marking pipelines installed in a common trench. You state that four pipelines (both liquid and gas pipelines) are in the trench which varies in width from 6 to 10 feet. Currently, markers are installed at each edge o the trench so that a pipeline is no more than 5 feet away from a marker. You ask whether this practice complies with 49 CFR 195.410. Section 195.410(a) requires carriers to place and maintain line markers "over each" buried liquid line at certain locations. From the information you have provided, it is unclear whether a marker is "over each" liquid line. The only pipelines which would be marked as required are the ones at each side of the trench, but you do not state whether these lines carry liquid or gas. Any liquid line which lies in between the pipelines at each side of the trench does not have a marker over it, and consequently, is not marked in accordance with section 195.410(a). Moreover, neither the existing nor the proposed line marking, signs display the word "petroleum" or name the commodity transported, as required by §195.410(a)(2). With respect to the gas pipelines in the trench, placement of the markers as you have described is in accordance with 49 CFR 192.707, presuming the gas pipelines are transmission lines. You should note, however, that this rule is the subject of a notice of proposed rulemaking published in the Federal Register on May 25, 1972, a copy of which is enclosed. As a result of this proceeding, we expect to revise section 192.707 in the near future. If a final rule is adopted as proposed, a line marker would be required over each gas main or transmission line, similarly as required for liquid lines. Also, the words "Warning Gas Pipeline" would be required on each line marking sign. This latter proposed requirement should be of concern to you because neither your current signs nor the signs you intend to purchase bear the word "gas." We appreciate your concern for pipeline safety. Sincerely, SINGNED Joseph C. Caldwell Director Office of Pipeline Safety#

Page 2Sun Pipe Line Company General Washington Building 216 Goddard Boulevard King of Prussia, PA 19406 July 12, 19 74 Mr. Joseph C. Caldwell, Director Office of Pipeline Safety Office of the Secretary of Transportation Washington, D.C. 20590 Dear Sir: I am sorry I neglected to enclose the existing and proposed new line marker signs. Enclosed please find the aforementioned signs. Very truly yours, C. J. Yablonski Director of Safety#

Page 3JUL 3 1974 Mr. Clarence J. Yablonski Director of Safety Sun Pipe Line Company General Washington Building 216 Goddard Boulevard King of Prussia, PA 19406 Dear Mr. Yablonski: This is to acknowledge your letter of June 21, 1974, requesting our opinion regarding your method of marking pipelines. In your letter you say that you are enclosing a copy of the existing line marker signs and the proposed new sign. We did not find that copy enclosed. Upon receipt of the enclosure, we will continue to review the matter and give you a reply as soon as possible. Sincerely, SIGNED Joseph C. Caldwell Director Office of Pipeline Safety#

Page 4Sun Pipe Line Company General Washington Building 216 Goddard Boulevard King of Prussia, PA 19406 June 21, 1974 Office of Pipe Line Safety Department of Transportation Washington, DC 20591 Gentlemen: The SunOlin Chemical Company plans to replace the existing line marker signs which are approximately 4 ¼” by 9" with the new line markers required by Paragraph 195.410. At the present time, we have as many as four different pipe lines laying in one common trench in the State of New Jersey. At the time of construction, the common trench was dug with the width varying from 6 feet to 10 feet. Within this common trench we have both liquid and gas pipelines. These lines are identified by two line markers, one at each edge of the outside pipe line. At no point is a pipe line more than 5 feet away from either pipe line marker. In purchasing our new signs, I would like to know if we may continue with the practice as explained above. I am enclosing a copy of the existing Line marker signs and the proposed new sign, and would appreciate your opinion in this matter. The Sun Pipe Line Company maintains these pipelines for the SunOlin Chemical Company. Very truly yours, Clarence J. Yablonski Director of Safety Sun Pipe Line Company#