{"operation":"document","citation":"PI-76-028","title":"Detectable Subsurface Tape Institute — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-05-27","effective_on":null,"summary":"PI-76-028 response to Detectable Subsurface Tape Institute concerning 192.321.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-028.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-028.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-028","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76028.pdf","body":"<<<PAGE 1>>>\n\nMay 27, 1976\nMr. Paul A. Potter\nDetectable Subsurface Tape Institute\nP.O. Box 12\nDeerfield, Illinois 60015\nDear Mr. Potter:\nYour letter of April 22, 1976, petitioning to amend 49 CFR 192.321(e) to include a definition of\nthe term \"other means\" is assigned Docket No. 76-6.\nSection 192.321(e) requires that unencased plastic pipe have an electrically conductive wire or\n\"other means\" of locating the pipe underground, and you suggest that the \"other means\" include a\ndetectable tracer tape which can be located from the surface by a pipe/cable locator.\nSection 192.321(e) is written in performance type language rather than specification terms. In\ngeneral, performance regulations state an objective requirement but leave the specific means of\ncompliance to the selection of the operator. Thus, with regard to locating plastic pipe, there may\nconceivably be many means other than detectable tracer tape, and it would be impractical to\ninclude detailed specifications for each means within Section 192.321(e). Therefore, it would not\nbe appropriate to amend §192.321(e) as you have suggested to make specific provision for\ndetectable tracer tape even though it appears to meet the present standard. Accordingly, the\npetition is denied.\nWe appreciate your interest in this matter.\nSincerely,\n\\signed\\\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\ndal\\192\\321\\76-05-27\n1\n\n<<<PAGE 2>>>\n\nApril 22, 1976\nMr. Cesar DeLeon\nActing Director\nOffice of Pipeline Safety Operations\nMaterials Transportation Bureau\nDepartment of Transportation\n2100 Second Street, S.W.\nWashington, D.C. 20590\nSUBJECT: Petition For Amendment of Title 49 CFR Part 192, Section 192.321(e) Per Rule\nMaking Procedures in Part 102, Section 102.31\nDear Mr. DeLeon:\nAs an interested party on behalf of manufacturers and utilities installing detachable tracer tape\nover plastic gas lines, we petition you to issue an amendment to Section 192.321(e) which reads\nas follows:\n\"Plastic pipe that is not encased must have an electrically conductive wire or other means of\nlocating the pipe while it is underground.\"\nWe petition the Acting Director to add the following amending sentence to Section 192.321(e) as\nfollows: \"Other means\" may be construed to include a detectable tracer tape which can be located\nfrom the surface by a pipe/cable locator.\nWe request this amendment for the following reasons.\n1. means.\"\nThe amending sentence will clarify the confusion in the interpretation of the phrase \"Other\n2. The amending sentence will codify and acknowledge the present installation practices of\ngas companies now using detectable tape in their systems in many cases to conform to Section\n192.321(e).\ndal\\192\\321\\76-05-27\n2\n\n<<<PAGE 3>>>\n\n3. Gas companies installing detectable tape have found its use to be an advantage over\ninsulated wire because of its greater visibility, flat shape, orange color and in many cases easier to\nlocate inductively than wire. Material cost is a factor too.\n4. Some gas companies install detectable tracer tape because of its warning feature to help\nprevent excavator damage or to comply with local laws such as the one issued June 18, 1973 by\nthe Fairfax County Board of Supervisors, Fairfax, Virginia.\n5. To be consistent with Specifications written by other governmental agencies such as the\nGeneral Services Administration in its Public Buildings Service Guide Specifications, Volume 4,\nPages 1501-14, Paragraph 18, Subparagraph 18.1.1 as amended October, 1973 which reads as\nfollows:\n\"Where non-metallic piping location is to be identified, an electrically conductive wire or other\nmeans of locating the underground pipe by electronic pipe detector shall be provided. \"Other\nmeans\" may be construed to include a detectable tape which can be located from the surface by a\ndetector. Where detectable tape is employed, tape shall be not less than two inches in width by\n0.0055 inch thick with a tensile strength of 50 pounds; this type of tape may be used for other\npiping in lieu of the 6 inch wide tape specified above.\"\nWe hereby request that the Acting Director of the Office of Pipeline Safety Operations issue the\nrecommended amendment in accordance with Section 102.31.\nRespectfully Submitted,\n\\signed\\\nPaul A. Potter\nDETECTABLE SUBSURFACE TAPE INSTITUTE\ndal\\192\\321\\76-05-27\n3\n\n<<<PAGE 4>>>\n\nDetectable SubSurface Tape\nInstitute\nEXHIBITS FOR PETITION\nTO AMEND TITLE 49 CFR\nPart 192, Section 192.321(e)\nPer Rule Making Procedures in\nPart 102, Section 102.31\nA. Installation of Detectable Marking Tape\nSections 211.31 and 211.32\nB. Recommended Practice for Marking Liquid\nPetroleum Pipeline Facilities, by\nAmerican Petroleum Institute, Washington, D.C.\nC. Louisiana Department of Highways Policy and\nSpecification Requirements for Location of Non- Conductive Underground Utility Pipe Lines.\nElectrically\nD. Fairfax, Virginia, County Code Governing Excavation and Utility Line\nInstallation.\nE. Typical Warning Tape Installation, LOVaca Gathering Co.\nF. Installing Services Instructions of Philadelphia Electric or Coated Steel Pipe.\nCompany for Plastic\ndal\\192\\321\\76-05-27\n4\n\n<<<PAGE 5>>>\n\nATTACHMENT\nEXHIBIT A: INSTALLATION OF DETECTABLE MARKING TAPE\nEXHIBIT B\ndal\\192\\321\\76-05-27\n5\n\n<<<PAGE 6>>>\n\nRECOMMENDED PRACTICE FOR MARKING\nLIQUID PETROLEUM PIPELINE FACILITIES\nISSUED BY\nAMERICAN PETROLEUM INSTITUTE\nDIVISION OF TRANSPORTATION\n1801 K STREET, N.W.\nWASHINGTON, D.C. 20006\nFOR SALE BY\nAMERICAN PETROLEUM INSTITUTE\nPUBLICATION SECTION\n1801 K STREET, N.W.\nWASHINGTON, D.C. 20006\n2.8 DETERMINING THE\nLOCATIONS FOR PIPELINE\nMARKERS\nThe use of conventional Pipeline\nWarning signs is not recommended in heavily\ndeveloped urban areas such as downtown\nbusiness centers where placement is\nimpracticable, or would not serve the\npurpose for which markers are intended, or\nwhen the local government maintains current\nsubstructure records. In such areas the car-\ndal\\192\\321\\76-05-27\n6\n\n<<<PAGE 7>>>\n\nriers may elect to indicate the presence of a\npipeline by means of stenciled markings, cast\nmonuments, plaques, signs, or other devices\ninstalled in curbs, sidewalks, streets, building\nfacades or wherever else practicable.\na. Pipeline Markers should be located at\neach public road crossing, at each railroad\ncrossing and in sufficient number along the\nremainder of each buried line so that its loca-\ntion is accurately known. The latter may be\naccomplished by placing markers at fence\nlines, property lines right-of-\nway boundaries and in open areas wherever\nthe party exerting control over the surface\nuse of the right-of-way will permit such\ninstallation.\nb. Pipeline Warning Signs should be\ninstalled at locations where the pipeline is\nabove ground and is accessible to the public.\nAerial cross- ings on any type of structure\neither publicly or privately owned should be\nconsidered for this purpose as being accessi-\nble to the public. Pipeline Warning Signs\nshould be placed on each side of a traversed\nwaterway or any impoundment which is an\nactive source of water supply.\nc. Navigable Waterway Pipeline Warning\nSigns should be placed on each side of all\ncrossings of navigable waterways. Such\ninstallation should also in- clude a Standard\nPipeline Warn-\ning Sign, for each buried pipe- line crossing,\nwhich should be installed above the normal\nhigh water line. Special Pipeline Warning\nSigns should be used at non-navigable\nwaterways where there are activities or\noperations that could damage the pipeline.\n(See Drawing No.3)\ndal\\192\\321\\76-05-27\n3.0 OTHER PIPELINE MARKING\nPRACTICE\n3.1 AERIAL PATROL MARKERS\nAerial Patrol Markers may be used\nalong the route of the pipelines to aid in their\npatrol by aircraft. Drawing No. 4 is an\nexample of an appropriate Aerial Marker\ninstallation.\n3.2 PAINTING AND BANDING SIGN\nSUPPORTS\nThe selection of colors and the\nmarking of sign supports should be\ndetermined by the carrier.\n3.3 LINE MARKING PLACED\nUNDERGROUND\nIt may sometime be desirable to\ninstall a buried marker tape during\nconstruction of a pipeline as a supplement to\nother marking practices. If installed, such a\ntape should be brightly colored and warn in\nprint of the presence of a pipeline.\n3.4 PIPELINE FACILITIES SIGNS\nFence or rail guarded facilities or\nappurtenances, such as pumping stations,\nterminals, delivery facilities, tank farms,\nvalves, metering or pipeline junction\nmanifolds, should be marked with appropri-\nate signs. Drawing No.5 is an example of\nsuch a sign. Carriers should maintain these\nsigns around those facilities which are visible\nor accessible to the public. These signs\nshould contain the name of the carrier and an\nemergency telephone number. The signs\nmay also contain other data, such as the type\n7\n\n<<<PAGE 8>>>\n\nor name of the facility, a mailing address,\ninstructions, prohibitions and warnings.\n4.0 MAINTENANCE\nThe maintenance of markers and\nsigns should be a part of the carrier's regular\nmaintenance procedures. Signs, along with\ntheir supporting structures, should be\nmaintained in their original state of effec-\ntiveness. Damaged or defaced signs should\nbe replaced. Markers should not be\nobscured by vegetation. Markers whose ef-\nfectiveness has been compromised by\nconstruction or development should be\nrelocated to restore effective marking.\nEXHIBIT C\nSTATE OF LOUISIANA\nDEPARTMENT OF HIGHWAYS\nP.O. BOX 44245, CAPITOL STATION\nBATON ROUGE, LA. 70804\nAugust 21, 1973\nDEPARTMENTAL POLICY AND\nSPECIFICATION REQUIREMENTS FOR\nLOCATION OF NON-ELECTRICALLY\nCONDUCTIVE UNDERGROUND UTILITY\nPIPE LINES\n_\nMEMORANDUM TO: MR. DEMPSEY D. WHITE\nCHIEF CONSTRUCTION AND MAINTENANCE ENGINEER\nMR. GRADY CARLISLE\nTRAFFIC AND PLANNING ENGINEER\nThe Department's present policy, as stated in a memorandum to District Engineers dated\n3/9/71, that requires the installation of approved detection wire or tape on all non-electrically\nconductive underground utility pipe lines remains in effect. This policy applies to all utility\nagreements and permits that authorize utility installations within the highway right of way. The\npolicy is stated as follows:\ndal\\192\\321\\76-05-27\n8\n\n<<<PAGE 9>>>\n\n\"Any non-metallic or non-conductive (electric current) underground facility must be\ninstalled with a non-corrosive metallic wire or tape placed directly over and on the center\nof the facility for its entire length within highway right of way. This applies to both\nparallel installations and crossings. Wire or tape must be connected to all fixtures and\nappurtenances.\"\nSpecific requirements and specifications for the detection wire or tape are as follows:\n1. The detection wire shall be neoprene insulated copper wire with wire diameter not\nsmaller than No. 14 wire or stainless steel wire with the diameter not smaller than .041\" diameter.\n2. The metallic detection tape that may be used are those on the approved products list\nthat is maintained by the Department's Materials Section. Tape that is not on the approved\nproducts list must be submitted to the Materials Section for approval prior to use.\ndal\\192\\321\\76-05-27\n9\n\n<<<PAGE 10>>>\n\n3. The approved wire or tape selected shall be used throughout the project.\n4. The wire or tape must be centered directly on top and attached to the pipe at least\nevery fifty (50) feet of pipe length by approved methods. Wire or tape must be connected to all\nfixtures and appurtenances.\n5. The utility companies may use, at their discretion, supplementary plastic warning tape\nof a non-metallic nature; however, this warning tape cannot replace the metallic system placed on\nthe pipe line.\n6. Utility companies applying for permits or entering into agreements with the\nDepartment, that will require a detection system, must include sufficient specifications and data so\nit can be determined if these policy and specification requirements will be met.\n\\signed\\\nA.B. RATCLIFF, JR.\nCHIEF ENGINEER\ndal\\192\\321\\76-05-27\n10\n\n<<<PAGE 11>>>\n\nEXHIBIT D\nThe Fairfax County Board of Supervisors, Fairfax, Virginia _\nenacted on June 18, 1973 the following Code:\nCODE GOVERNING EXCAVATION AND UTILITY LINE INSTALLATION\nARTICLE III. THE OPERATOR\nSection 12. Excavation.\n(d) When trenches excavated for the installation of gas pipelines are backfilled, a\ncontinuous tape shall be installed after tamping 18 inches above all direct burial plastic\nmains and 12 inches above services, stubs and stub extensions. The tape shall be not less\nthan three (3) inches wide, brilliant in color and imprinted with words clearly defining the\nutility line as \"GAS\". The tape shall be impregnated with metal so that locating equipment\ncan readily pick it up. The remainder of the backfill may then be placed.\nAttachment\nExhibit E & F\ndal\\192\\321\\76-05-27\n11","truncated":false,"body_characters":12613}