{"operation":"document","citation":"PI-80-0105","title":"Pipeline Safety Interpretation PI-80-0105","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1980-11-14","effective_on":null,"summary":"PI-80-0105 concerning 195.412.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0105","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1980/g80-11-14_Bieber_195.412-olox.pdf","body":"<<<PAGE 1>>>\n\nPI-80-0105\nNovember 14, 1980\nMr. Alan Bieber\nMontview Engineering Co.\n78 Town Woods Road\nLyme, Conn. 06371\nDear Mr. Bieber:\nThank you for your letter of September 5, 1980, regarding the use of indirect techniques, such as side-\nscanning sonar, for locating underwater pipelines.\nUnderwater pipeline inspections are required by 49 CFR 195.412(b) to determine the condition of pipelines\ncrossing navigable waterways. The purpose of the inspections is to check for conditions that could endanger\nsafe pipeline operations, such as washouts above or below the pipeline. Although identifying a pipeline's\nalignment or location with respect to the river bottom, which the indirect techniques you have described\nseem capable of doing under favorable conditions, is a condition to examine under Section 195.412(b), it is not\nthe only condition to consider. The inspection method must also be capable of detecting other problems, such\nas below-grade washouts and physical damage to the pipeline or coating. Thus, while the indirect techniques\nwould be of value in making the required inspections, they are not sufficient to furnish all the information\nneeded to comply with Section 195.412(b). For full compliance, they would have to be complemented by\ndirect observational techniques.\nSincerely,\nSIGNED\nMelvin A. Judah\nActing Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nMontview Engineering Co.\n78 Town Woods Road\nLyme, Conn 06371\nSeptember 5, 1980\nMr. Melvin A. Judah\nActing Associate Director\nOffice of Pipeline Safety Regulations\nMaterials Transportation Bureau\nDepartment of Transportation\n400 7th St., S.W.\nWashington, D.C. 20590\nDear Mr. Judah:\nSeveral weeks ago I discussed with Mr. Heverly the techniques which we use for locating and\ndetermining the position and cover for pipeline river crossings, both for initial acceptance and periodic\ninspection. Many of our clients feel that the present method of using a diver to \"walk\" the line is not effective;\nhaving done black-water diving in the past I tend to agree. The diver can't see the pipe and must probe for it;\nand it is very difficult, particularly in swift currents, to accurately plot the diver's position.\nOur clients have asked that we get a determination from you permitting the use of our methods for\nthese inspections. After describing the procedures to Mr. Heverly, he felt there should be no problem in this\nregard, but suggested I formally request this determination from you.\nI have enclosed several copies of a technical brochure describing our methods for your information and\nto aid you in making this determination. I would appreciate hearing from you at your earliest convenience.\nVery truly yours,\nAlan Bieber","truncated":false,"body_characters":2740}