{"operation":"document","citation":"PI-74-0140","title":"Sun Pipe Line Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1974-10-07","effective_on":null,"summary":"PI-74-0140 response to Sun Pipe Line Company concerning 195.410.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0140.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0140.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0140","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-10-07_Yablonski_195.410-%20msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-74-0140\nOctober 7, 1974\nMr. Clarence J. Yablonski\nDirector of Safety\nSun Pipe Line Company\nGeneral Washington Building\n216 Goddard Boulevard\nKing of Prussia, PA 19406\nDear Mr. Yablonski:\nThis responds to your letter of June 21, 1974, concerning the practice of marking pipelines installed in a\ncommon trench. You state that four pipelines (both liquid and gas pipelines) are in the trench which varies in\nwidth from 6 to 10 feet. Currently, markers are installed at each edge o the trench so that a pipeline is no\nmore than 5 feet away from a marker. You ask whether this practice complies with 49 CFR 195.410.\nSection 195.410(a) requires carriers to place and maintain line markers \"over each\" buried liquid line at certain\nlocations. From the information you have provided, it is unclear whether a marker is \"over each\" liquid line.\nThe only pipelines which would be marked as required are the ones at each side of the trench, but you do not\nstate whether these lines carry liquid or gas. Any liquid line which lies in between the pipelines at each side of\nthe trench does not have a marker over it, and consequently, is not marked in accordance with section\n195.410(a).\nMoreover, neither the existing nor the proposed line marking, signs display the word \"petroleum\" or name the\ncommodity transported, as required by §195.410(a)(2).\nWith respect to the gas pipelines in the trench, placement of the markers as you have described is in\naccordance with 49 CFR 192.707, presuming the gas pipelines are transmission lines. You should note,\nhowever, that this rule is the subject of a notice of proposed rulemaking published in the Federal Register on\nMay 25, 1972, a copy of which is enclosed. As a result of this proceeding, we expect to revise section 192.707\nin the near future. If a final rule is adopted as proposed, a line marker would be required over each gas main\nor transmission line, similarly as required for liquid lines. Also, the words \"Warning Gas Pipeline\" would be\nrequired on each line marking sign. This latter proposed requirement should be of concern to you because\nneither your current signs nor the signs you intend to purchase bear the word \"gas.\"\nWe appreciate your concern for pipeline safety.\nSincerely,\nSINGNED\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nSun Pipe Line Company\nGeneral Washington Building\n216 Goddard Boulevard\nKing of Prussia, PA 19406\nJuly 12, 19 74\nMr. Joseph C. Caldwell, Director\nOffice of Pipeline Safety\nOffice of the Secretary of Transportation\nWashington, D.C. 20590\nDear Sir:\nI am sorry I neglected to enclose the existing and proposed new line marker signs.\nEnclosed please find the aforementioned signs.\nVery truly yours,\nC. J. Yablonski\nDirector of Safety\n\n<<<PAGE 3>>>\n\nJUL 3 1974\nMr. Clarence J. Yablonski\nDirector of Safety\nSun Pipe Line Company\nGeneral Washington Building\n216 Goddard Boulevard\nKing of Prussia, PA 19406\nDear Mr. Yablonski:\nThis is to acknowledge your letter of June 21, 1974, requesting our opinion regarding your method of marking\npipelines. In your letter you say that you are enclosing a copy of the existing line marker signs and the\nproposed new sign. We did not find that copy enclosed.\nUpon receipt of the enclosure, we will continue to review the matter and give you a reply as soon as possible.\nSincerely,\nSIGNED\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 4>>>\n\nSun Pipe Line Company\nGeneral Washington Building\n216 Goddard Boulevard\nKing of Prussia, PA 19406\nJune 21, 1974\nOffice of Pipe Line Safety\nDepartment of Transportation\nWashington, DC 20591\nGentlemen:\nThe SunOlin Chemical Company plans to replace the existing line marker signs which are approximately 4 ¼”\nby 9\" with the new line markers required by Paragraph 195.410.\nAt the present time, we have as many as four different pipe lines laying in one common trench in the State of\nNew Jersey. At the time of construction, the common trench was dug with the width varying from 6 feet to 10\nfeet. Within this common trench we have both liquid and gas pipelines. These lines are identified by two line\nmarkers, one at each edge of the outside pipe line. At no point is a pipe line more than 5 feet away from either\npipe line marker.\nIn purchasing our new signs, I would like to know if we may continue with the practice as explained above. I\nam enclosing a copy of the existing Line marker signs and the proposed new sign, and would appreciate your\nopinion in this matter.\nThe Sun Pipe Line Company maintains these pipelines for the SunOlin Chemical Company.\nVery truly yours,\nClarence J. Yablonski\nDirector of Safety\nSun Pipe Line Company","truncated":false,"body_characters":4646}