EXXON Pipeline Company — Pipeline Safety Interpretation

Page 1December 22, 1976 Mr. Roy R. Die Vice President-Operations EXXON Pipeline Company P.O. Box 2220 Houston, Texas 77001 Dear Mr. Die: This refers to your petition (Docket No. 75-11W), requesting a waiver from compliance with (1) the wording requirements of 49 CFR 192.707(d) for 2,850 existing line marking signs located other than at navigable waterways and (2) the color and wording requirements of 49 CFR 192.707(e) for 60 existing line marking signs at navigable waterways until the signs must be replaced due to deterioration. With regard to the 2,850 existing line marking signs located other than at navigable waterways, the sign wording technically does not meet the requirements of Section 192.707(d) because the word "gas" is omitted. However, by specifically identifying the gaseous commodity being transported, the signs convey the information intended to be provided under Section 192.707(d). Since, undoubtedly, many operators may be in a similar situation, this aspect of your petition is considered as a request for rulemaking rather than waiver and is hereby granted. We will amend Section 192.707(d) to permit line marking signs to identify the commodity being transported as an alternative to stating the word "gas." We object, however, to the proposed continued use of 68 signs at navigable waterways beyond the January 1, 1980, deadline for compliance with Section 192.707(e). A primary objective of Section 192.707(e) is uniformity of pipeline markers at navigable waterways consistent with the Uniform State Waterway Marking System set forth in 33 CFR Part 66 [sic]. To grant the requested waiver would not be in accord with this objective. A brief discussion concerning existing line markers and their replacement is included in the preamble to the final line marking rule under the heading "Paragraph (f), existing markers." A copy of this preamble and final rule is enclosed. As indicated therein the replacement cost of recently installed markers was considered in setting the January 1, 1980, deadline, which allows existing markers to be used for almost five years after the effective date dal\192\707\76-12-22 1#

Page 2of Section 192.707(e). The situation involving the 68 markers does not at all differ from the rationale for setting the January 1, 1980, deadline so as to justify granting a waiver. For these reasons, this aspect of your request is denied. In accordance with applicable procedures, a public hearing is not required before reaching this decision. Sincerely, Cesar DeLeon Acting Director Office of Pipeline Safety Operations Enclosure dal\192\707\76-12-22 2#

Page 3September 30, 1976 Request for Waiver from Compliance with DOT 192.707(f) for existing Gas Pipeline Marker Docket No. Pet. 75-11W Mr. Cesar DeLeon, Acting Director Office of Pipeline Safety Operations Materials Transportation Bureau Department of Transportation Washington, D.C. 20590 In our letter to your office dated August 15, 1975, we requested a waiver from compliance with DOT 192.707(f) requiring replacement of gas pipeline signs installed prior to April 21, 1975, if they do not comply with DOT 192.707(d) or (e) as stated in Amendment 192-20 published in 40 CFR 13502 March 27, 1975. Our waiver request was based on the fact that our present signs are adequate for safety purposes, are in excellent condition and can be expected to last well beyond the required change out date of January 1, 1980. We received your letter dated August 25, 1975, assigning Docket No. Pet. 75-11W and stating that you would notify us of your decision after reviewing our request. If we can furnish additional information which may be helpful in expediting and reaching a decision on this request, please let us know. Roy R. Die dal\192\707\76-12-22 3#

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Page 5August 15, 1975 Request for Waiver from Docket No. OPS-18, Amendment 192-20, Line Markers for Mains and Transmission Lines Director Office of Pipeline Safety Operations Materials Transportation Bureau Department of Transportation Washington, D.C. 20590 Amendment 192-20, referenced above, revised DOT 192.707 TRANSMISSION LINES: MARKERS, setting forth certain details of wording, letter height and color for gas line markers. The purpose of this letter is to request a waiver from the requirements of amended section 192.707 as follows: ü Continued use of all existing Exxon Pipeline Company gas transmission line markers (until useful marker life has expired) which will be with color mode and wording as referenced below for: ü Markers at Navigable Waterways - refer to attached Doc. No. B-5404-A entitled "6' x 13' Gas Pipeline Marker for Navigable Waterway Crossing" and typical photographs Nos. 1 and 2. ü Markers other than at Navigable Waterways - refer to attached Diag. No. C- entitled "Standard Special Products (Ethylene) Warning Sign" and typical photographs Nos. 3 and 4. In 1973 Exxon conducted a complete marker changeout program updating the design of all markers including the then understood requirements of DOT, OSHA, etc. Cost of this program was estimated to $1,150.000. Most of these markers are in excellent condition and can reasonable be expected to last well beyond the 1980 changeout date required by DOT 192.707(f). Until March, 1975 the only DOT guidelines for gas transmission line markers were the general requirements of DOT 192.707 which stated that "Each operator shall install signs or markers whenever necessary to identify the location of a transmission line in order to reduce the possibility of damage or interference." To comply with this requirements Exxon followed guidelines set out in DOT 195, MINIMUM FEDERAL SAFETY STANDARDS FOR LIQUID PIPELINES and developed two general types of markers: dal\192\707\76-12-22 5#

Page 6ü Gas Pipeline Markers for Navigable Waterway Crossings - These rectangular signs range from 3' x 6' to 15' x 24' in size. Contrasting colors of red, yellow and black highlight the wording on the signs and attract the attention of the viewer. A high quality long life sign made of acrylic latex coated aluminum was chosen over lesser quality signs to reduce frequency of replacement since many of these signs are located in remote and relatively inaccessible areas where installation costs are very expensive. ü Gas Pipeline Marker - 12" diameter - These are used to identify buried or above ground gas pipeline crossing public roads, railroads or as needed in areas accessible to the public. On these pipeline markers Exxon shows the specific commodity being transported; for example "Ethylene". Civil authorities and firemen are vitally concerned with knowing the specific commodity that they must deal with in the event of an emergency. In this respect we consider our present signs superior to those showing only "Warning-gas pipeline". Exxon has approximately 68 gas pipeline markers installed at navigable waterway crossings. Replacement cost of these markers is estimated at $90,000. In addition Exxon has 8 multiple line (liquid and gas) waterway crossing markers which would cost an estimated $30,000 to replace. At locations other than at navigable waterways, Exxon has approximately 2,850 gas pipeline markers (12" diameter) which would cost an estimated $17,500 to replace. This represents a total of approximately $137,500 for marker changes to meet the new gas regulation (Amendment 192- 20). We consider that our existing markers will be adequate and completely suitable for safe operation of our gas transmission systems and that their replacement prior to the end of useful life would not be justified by cost/benefit considerations. Accordingly, the waiver herein requested is sought insofar as the useful life of our existing markers extends beyond January, 1980. As the useful life of each marker expires we will install a new marker as prescribed by Amendment 192-20. A decision on our request for a waiver is desired at this time so as to permit adequate long range planning for our marker requirements. In view of the foregoing reasons - cost impact and suitable existing design - we request a waiver from the requirements of dal\192\707\76-12-22 6#

Page 7Amendment 192-20 as here stated. If a waiver is not granted based on the information contained herein, we request a hearing and notification when a hearing may be held. Please let us know if you have any questions or if we can furnish additional information you need to reach a decision. Roy R. Die Attachments dal\192\707\76-12-22 7#