{"operation":"document","citation":"PI-76-080","title":"EXXON Pipeline Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1976-12-22","effective_on":null,"summary":"PI-76-080 response to EXXON Pipeline Company concerning 192.707.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-080.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-080.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-76-080","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1976/PI76080.pdf","body":"<<<PAGE 1>>>\n\nDecember 22, 1976\nMr. Roy R. Die\nVice President-Operations\nEXXON Pipeline Company\nP.O. Box 2220\nHouston, Texas 77001\nDear Mr. Die:\nThis refers to your petition (Docket No. 75-11W), requesting a waiver from compliance with (1)\nthe wording requirements of 49 CFR 192.707(d) for 2,850 existing line marking signs located\nother than at navigable waterways and (2) the color and wording requirements of 49 CFR\n192.707(e) for 60 existing line marking signs at navigable waterways until the signs must be\nreplaced due to deterioration.\nWith regard to the 2,850 existing line marking signs located other than at navigable waterways,\nthe sign wording technically does not meet the requirements of Section 192.707(d) because the\nword \"gas\" is omitted. However, by specifically identifying the gaseous commodity being\ntransported, the signs convey the information intended to be provided under Section 192.707(d).\nSince, undoubtedly, many operators may be in a similar situation, this aspect of your petition is\nconsidered as a request for rulemaking rather than waiver and is hereby granted. We will amend\nSection 192.707(d) to permit line marking signs to identify the commodity being transported as an\nalternative to stating the word \"gas.\"\nWe object, however, to the proposed continued use of 68 signs at navigable waterways beyond\nthe January 1, 1980, deadline for compliance with Section 192.707(e). A primary objective of\nSection 192.707(e) is uniformity of pipeline markers at navigable waterways consistent with the\nUniform State Waterway Marking System set forth in 33 CFR Part 66 [sic]. To grant the\nrequested waiver would not be in accord with this objective. A brief discussion concerning\nexisting line markers and their replacement is included in the preamble to the final line marking\nrule under the heading \"Paragraph (f), existing markers.\" A copy of this preamble and final rule is\nenclosed. As indicated therein the replacement cost of recently installed markers was considered\nin setting the January 1, 1980, deadline, which allows existing markers to be used for almost five\nyears after the effective date\ndal\\192\\707\\76-12-22\n1\n\n<<<PAGE 2>>>\n\nof Section 192.707(e). The situation involving the 68 markers does not at all differ from the\nrationale for setting the January 1, 1980, deadline so as to justify granting a waiver. For these\nreasons, this aspect of your request is denied.\nIn accordance with applicable procedures, a public hearing is not required before reaching this\ndecision.\nSincerely,\nCesar DeLeon\nActing Director\nOffice of Pipeline\nSafety Operations\nEnclosure\ndal\\192\\707\\76-12-22\n2\n\n<<<PAGE 3>>>\n\nSeptember 30, 1976\nRequest for Waiver from\nCompliance with DOT 192.707(f)\nfor existing Gas Pipeline Marker\nDocket No. Pet. 75-11W\nMr. Cesar DeLeon, Acting Director\nOffice of Pipeline Safety Operations\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nIn our letter to your office dated August 15, 1975, we requested a waiver from compliance with\nDOT 192.707(f) requiring replacement of gas pipeline signs installed prior to April 21, 1975, if\nthey do not comply with DOT 192.707(d) or (e) as stated in Amendment 192-20 published in 40\nCFR 13502 March 27, 1975. Our waiver request was based on the fact that our present signs are\nadequate for safety purposes, are in excellent condition and can be expected to last well beyond\nthe required change out date of January 1, 1980.\nWe received your letter dated August 25, 1975, assigning Docket No. Pet. 75-11W and stating\nthat you would notify us of your decision after reviewing our request.\nIf we can furnish additional information which may be helpful in expediting and reaching a\ndecision on this request, please let us know.\nRoy R. Die\ndal\\192\\707\\76-12-22\n3\n\n<<<PAGE 4>>>\n\ndal\\192\\707\\76-12-22\n\n<<<PAGE 5>>>\n\nAugust 15, 1975\nRequest for Waiver from Docket No.\nOPS-18, Amendment 192-20, Line\nMarkers for Mains and Transmission Lines\nDirector\nOffice of Pipeline Safety Operations\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nAmendment 192-20, referenced above, revised DOT 192.707 TRANSMISSION LINES:\nMARKERS, setting forth certain details of wording, letter height and color for gas line markers.\nThe purpose of this letter is to request a waiver from the requirements of amended section\n192.707 as follows:\nü Continued use of all existing Exxon Pipeline Company gas transmission line markers (until\nuseful marker life has expired) which will be with color mode and wording as referenced\nbelow for:\nü Markers at Navigable Waterways - refer to attached Doc. No. B-5404-A entitled\n\"6' x 13' Gas Pipeline Marker for Navigable Waterway Crossing\" and typical\nphotographs Nos. 1 and 2.\nü Markers other than at Navigable Waterways - refer to attached Diag. No. C-\nentitled \"Standard Special Products (Ethylene) Warning Sign\" and typical\nphotographs Nos. 3 and 4.\nIn 1973 Exxon conducted a complete marker changeout program updating the design of all\nmarkers including the then understood requirements of DOT, OSHA, etc. Cost of this program\nwas estimated to $1,150.000. Most of these markers are in excellent condition and can\nreasonable be expected to last well beyond the 1980 changeout date required by DOT 192.707(f).\nUntil March, 1975 the only DOT guidelines for gas transmission line markers were the general\nrequirements of DOT 192.707 which stated that \"Each operator shall install signs or markers\nwhenever necessary to identify the location of a transmission line in order to reduce the possibility\nof damage or interference.\" To comply with this requirements Exxon followed guidelines set out\nin DOT 195, MINIMUM FEDERAL SAFETY STANDARDS FOR LIQUID PIPELINES and\ndeveloped two general types of markers:\ndal\\192\\707\\76-12-22\n5\n\n<<<PAGE 6>>>\n\nü Gas Pipeline Markers for Navigable Waterway Crossings - These rectangular signs\nrange from 3' x 6' to 15' x 24' in size. Contrasting colors of red, yellow and black\nhighlight the wording on the signs and attract the attention of the viewer. A high\nquality long life sign made of acrylic latex coated aluminum was chosen over lesser\nquality signs to reduce frequency of replacement since many of these signs are\nlocated in remote and relatively inaccessible areas where installation costs are very\nexpensive.\nü Gas Pipeline Marker - 12\" diameter - These are used to identify buried or above\nground gas pipeline crossing public roads, railroads or as needed in areas\naccessible to the public. On these pipeline markers Exxon shows the specific\ncommodity being transported; for example \"Ethylene\". Civil authorities and\nfiremen are vitally concerned with knowing the specific commodity that they must\ndeal with in the event of an emergency. In this respect we consider our present\nsigns superior to those showing only \"Warning-gas pipeline\".\nExxon has approximately 68 gas pipeline markers installed at navigable waterway crossings.\nReplacement cost of these markers is estimated at $90,000. In addition Exxon has 8 multiple line\n(liquid and gas) waterway crossing markers which would cost an estimated $30,000 to replace.\nAt locations other than at navigable waterways, Exxon has approximately 2,850 gas pipeline\nmarkers (12\" diameter) which would cost an estimated $17,500 to replace. This represents a total\nof approximately $137,500 for marker changes to meet the new gas regulation (Amendment 192-\n20).\nWe consider that our existing markers will be adequate and completely suitable for safe operation\nof our gas transmission systems and that their replacement prior to the end of useful life would\nnot be justified by cost/benefit considerations. Accordingly, the waiver herein requested is sought\ninsofar as the useful life of our existing markers extends beyond January, 1980. As the useful life\nof each marker expires we will install a new marker as prescribed by Amendment 192-20.\nA decision on our request for a waiver is desired at this time so as to permit adequate long range\nplanning for our marker requirements.\nIn view of the foregoing reasons - cost impact and suitable existing design - we request a waiver\nfrom the requirements of\ndal\\192\\707\\76-12-22\n6\n\n<<<PAGE 7>>>\n\nAmendment 192-20 as here stated. If a waiver is not granted based on the information contained\nherein, we request a hearing and notification when a hearing may be held. Please let us know if\nyou have any questions or if we can furnish additional information you need to reach a decision.\nRoy R. Die\nAttachments\ndal\\192\\707\\76-12-22\n7","truncated":false,"body_characters":8527}