# Public Service Commission — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-81-019
- **title:** Public Service Commission — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1981-10-27
- **effective on:** Not available
- **summary:** PI-81-019 response to Public Service Commission concerning 192.459.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-019.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-019.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-81-019
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1981/PI81019.pdf
**body:**

<<<PAGE 1>>>

October 27, 1981
Mr. Cody Stuart
Manager, Gas & Service Safety
Public Service Commission
P.O. Box C-400
Markham & Victory Streets
Little Rock, Arkansas 72203
Dear Mr. Stuart:
Your letter of August 21, 1981, proposing a change in 49 CFR 192.459 has been forwarded by
Mr. Aubry for our response.
We share your concern that operators participating in "one-call" systems should not be required in
every instance to continually monitor a contractor during all phases of construction. This issue,
or the extent to which an operator should have to monitor a contractor's activity to prevent or
check for damage to a pipeline, is under consideration in our current rulemaking proceeding on
damage prevention programs (Docket PS-59, 44 FR 65792). We expect that a final rule on this
matter will be issued soon.
The interpretation to which you refer is not consistent with the meaning of section 192.459. This
section requires operators to visually inspect a pipeline for corrosion whenever the operator has
knowledge that the pipeline is exposed. In most cases, the information an operator receives under
a "one-call" system about a proposed excavation would not give the operator knowledge that a
pipeline is or will be exposed by the excavation. Under these circumstances, an inspection to
detect corrosion would not be required by section 192.459.
At the same time, even if an operator were to learn through participation in a "one-call" system
that a buried pipeline is or will be exposed, the operator's obligation under section 192.459 is only
to inspect for external corrosion and take any remedial actions required, not to continually check
the pipeline for equipment damage.
Since the operator to which you refer has misinterpreted the provisions of section 192.459 and the
issue of monitoring for
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<<<PAGE 2>>>

damage prevention purposes will be decided in Docket PS-59, we do not believe there is a need
to amend section 192.459 as you have suggested.
Sincerely,
Melvin A. Judah
Acting Associate Director for
Pipeline Safety Regulation
Materials Transportation Bureau
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