{"operation":"document","citation":"PI-76-0107","title":"Pipeline Safety Interpretation PI-76-0107","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-07-15","effective_on":null,"summary":"PI-76-0107 concerning 192.707.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0107.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0107.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-0107","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/g76-07-15_Hanson_192.707-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-76-0107\nJuly 15, 1976\nMr. E. S. Hanson\nSenior Vice President\nCities Service Gas Company\nFirst national Center\nOklahoma City, Oklahoma 73102\nDear Mr. Hansom\nIn your letter of May 14, 1976, to Mr. Marshall W. Taylor, II, Chief, Central Region, you ask whether 49 CFR 192.707(c)\nrequires line markers at regulator stations.\nSection 192.707 (c) provides:\n“Pipelines Aboveground. Line markers must be placed and maintained along each section of a main and\ntransmission line that is located aboveground in an area accessible to the public.”\nSince under section 192.3 a “regular station” is included within the meaning of the terms “transmission line” and\n“main,” any aboveground regulator station must be marked if it is located in an area accessible to the public. For the\npurpose of section 192.707(c), an area is accessible to the public if entrance into the area is not physically controlled by\nthe operator or if the area may be entered without difficulty.\nWith regard to your question about marking a farm tap meter and regulator installation, a farm tap which serves a single\ncustomer is classified as a “service Line” under 49 CFR part 192 and would therefore not be subject to the marking\nrequirement of section 192.707(c). Where a farm tap serves more than one customer, a portion of it would be classified\nas either a “main” or “transmission line” and subject to the marking requirement if located above ground.\nWe trust this satisfactorily responds to your inquiry.\nSincerely,\nCesar DeLeon\nActing Director Office of Pipeline Safety Operations\n\n<<<PAGE 2>>>\n\nUnited States Government\nDepartment of Transportation\nMaterials Transportation Bureau\nJune 10, 1976\nTo: Chief, Regulations Division, MTP-30\nThru: Chief, Operations Division, MTP-50\nFROM: Chief, Central Region\nSUBJECT: Request for interpretation\nCities Service Gas Company has requested an interpretation pertaining to marker requirements for\naboveground pipelines in their information letter of May 14, 1976. The request is contained in item 3\nof the letter.\nClarification is requested for 192.707(c) Pipelines aboveground, which states that \"Line markers must\nbe placed and maintained along each section of a main and transmission line that is located\naboveground in an area accessible to the public.\"\nWe respectfully submit for consideration aspects of this requirement which have been discussed with\noperators in the course of our inspections. This discussion is included to indicate the positions we have\ntaken in the past.\n1. Marking of metering and regulating stations.\nWe have contended that metering and regulating stations are required to be marked to meet\nthe aboveground piping marking requirement. We also contend that valve settings require markers for\nidentification. We do consider, however, that if a road crossing marker is located in the near vicinity of\nsuch aboveground facilities, an additional marker is not required.\n2. Accessibility to the public.\nThe question of what is accessible to the public has also been discussed. Some feel that the\npresence of a fence around the piping, at a regulating station for instance, renders the piping inaccessible\nto the public, and negates the marker requirement. The regulation states, however, that if the pipe is in\nan area accessible to the public it must be marked. It does not refer to the accessibility of the piping\nalone. The area in which the piping is located should not be construed to mean that small space often\nenclosed by the operator's fence.\nWe have also recommended that markers be located at aboveground piping such as spans, in\nremote areas. Remote areas are not necessarily inaccessible to the public.\n3. Farm taps.\nCities Service has suggested that requiring markers at metering and regulating stations might also require\nmarking of farm tap piping facilities. This office has not recommended the marking of farm tap facilities. Farm\ntap piping would not fall under the classification of a main or transmission line.\nWe would appreciate it if the items aforementioned could be included - in your interpretation for Cities\nService. If they cannot, since the operator's request does not specifically confront these situations, please\nadvise us as to the validity of our assumptions to enable us to maintain uniformity in our compliance\nprogram throughout the five regions.\nMarshall W. Taylor, II, MTF -50-CE\n\n<<<PAGE 3>>>\n\nCities service Gas Company\nFirst National Center\nOklahoma City, OK 73102\nMay 14, 1976\nMr. Marshall W. Taylor, II\nChief, Central Region\nOffice of Pipeline Safety Operations\n911 Walnut Street\nKansas City, Missouri 64106\nDear Mr. Taylor:\nPursuant to your request in letter dated April 16, 1976, for compliance information with Title\n49 of the Code of Federal Regulations, Part 192, following is Cities Service Gas Company's\nstatus of records, inspection, and policy,\n1. Testing of Relief Devices on the Air System at Saginaw Compressor Station.\nIt is Cities' policy to test relief valves installed on its compressor station air systems annually. The fact that\nthe air system relief valves at Saginaw were not tested was an oversight. Such inspection and testing have\nbeen completed and a copy of inspection record is attached.\n2. Testing of Relief Devices at Regulator Stations\nInstructions issued by Cities to its responsible field personnel stated that relief devices must be\ntested annually. These instructions were interpreted by some employees to mean once each\ncalendar year. Accordingly, test records indicated appropriate tests in 1974 and 1975 but the\ntime interval exceeded one year. Revised Instructions are being prepared stating \"relief\ndevices must be tested at intervals not exceeding twelve months.\"\n3. Marking of Transmission Pipelines\nSpecific instructions are being prepared emphasizing that all transmission line spans should be\nmarked. These instructions will be issued to all pipeline divisions to supplement current\ninstructions. The seven spans mentioned in the inspection report have been marked.\nIn regard to identifying signs at regulator stations, Cities does not interpret § 192.707 to require\npipeline markers at every above ground appurtenance. The marker regulation was amended\nspecifically to prevent damage to buried transmission lines and mains by excavation-related\nactivities. Nearly four pages of discussion and comments were issued in conjunction with the revised\nmarker regulation dated April 12, 1975. These comments center on protecting buried, unseen\ntransmission lines and mains with the exception of § 192.707(c), which refers to above ground\ntransmission lines and mains. For these reasons we do not feel that § 192.707 was intended to\nrequire identifying signs at regulator stations. We„ therefore, respectfully request an official\ninterpretation of the regulation.\nIn formulating such interpretation, consideration should be given to the overall ramifications of carrying\nout a marker or identification program encompassing all appurtenances. For example would a farm tap\nmeter and regulator installation require marking or identification?\n4. Transmission Valve Inspections\nDuring 1972 and 1973, a number of supervisory personnel changes occurred at our Miami,\nOklahoma pipeline division. Apparently, due to lack of continuity of supervisory responsible\n\n<<<PAGE 4>>>\n\npersonnel, Cities' policy of inspecting transmission valves was not carried out during this period;\ntherefore, we cannot verify such inspections. From 1974 to date, documentation records show\nthe program has been carried out in full compliance with the regulations.\n5. Atmospheric Corrosion Monitoring of Above Ground Piping\nAttached is the form we developed to monitor atmospheric corrosion, together with instructions\npertaining to its use. Such data was issued to meet compliance and documentation requirements of §\n192.481. It appears that field supervisors generally misinterpreted these instructions to apply only to\nabove ground pipelines such as spans or transmission lines mounted on bridges. Your inspection report\nhas called to our attention that more explicit instructions need to be prepared and issued with respect to\nmonitoring of atmospheric corrosion. These instructions are now being prepared.\n6. Calculation of Relief Valve Capacities\nWhen Cities adopted its program to comply with § 192.743, it was felt that appropriate\ndocumentation of relief device capacities should be maintained in the Oklahoma City office\nwhere such calculations are conducted. With this concept, field personnel only test set pressures\nof relieving devices. For example calculation of capacity of relief valves installed on the Stones\nCorner TBS and Silvercreek Addition TBS are attached for your review.\nIt is intended that the foregoing provides all of the information requested in your letter of April 16,\n1976. Cities Service Gas Company is vitally interested in carrying out safe operations of its pipeline\nsystem and is endeavoring to comply with all applicable DOT regulations. We appreciate the concern\nand courtesy extended to our field personnel by your compliance inspector; moreover, we are fully\ncognizant of the joint effort required of industry and government to carry out safe pipeline\noperations and wish to assure you of our full cooperation.\nYours very truly,\nE. S. Hanson, Senior Vice President\nGas Transmission Division","truncated":false,"body_characters":9334}