{"operation":"document","citation":"PI-82-0113","title":"Pipeline Safety Interpretation PI-82-0113","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1982-12-27","effective_on":null,"summary":"PI-82-0113 concerning 192.327.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0113.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0113.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-0113","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1982/g82-12-27_Leach_192.327-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-82-0113\nU. S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nDecember 27, 1982\nThe Honorable Jim Leach\nU.S. House of Representatives\nWashington, D.C. 20515\nDear Mr. Leach:\nThis refers to your communication of December 7, 1982, requesting our consideration of a letter from Bonnie T. Eggers\nregarding the proper depth at which gas pipelines should be buried. Ms. Eggers' concern stems from the death of two\nrelatives in a recent pipeline accident at Hudson, Iowa.\nThe Federal safety standards for gas pipelines are set forth in Part 192 of Title 49 of the Code of Federal Regulations.\nThese standards were issued under the Natural Gas Pipeline Safety Act of 1968 (49 U.S.C. 1671 et seq.). Section 192.327\nof the standards requires that buried transmission lines in rural areas, like the one involved in the Hudson accident, be\nconstructed with at least 30 inches of soil cover or 18 inches of rock cover. The required cover increases to 36 inches\nand 18 inches, respectively, for areas with a higher population density. These burial depths exceed the depths that\nwere recommended for gas pipelines by the American Society of Mechanical Engineers in its B31.8 Code for pressure\npiping that was in effect when the standards were adopted.\nThe purpose of the prescribed depths is to reduce the likelihood that a buried pipeline will be damaged by normal\ncultivation or other digging activities. While a greater burial depth might logically be expected to further reduce this\nlikelihood, there is no empirical evidence supporting the proposition that increasing burial depth would be cost-\neffective from a safety perspective.\nIn contrast, experience has shown that measures such as line marking, mapping, and advance coordination of\nconstruction work provide more effective and economical approaches to damage prevention than deeper burial. In this\nregard, the Federal safety standards require operators of buried pipelines in rural areas to install permanent marking\nsigns along the pipelines to show their location. Each sign provides a warning, the name of the operator, and a\ntelephone number that an excavator may call to learn more specific information about the pipeline before beginning to\ndig. Another standard that was recently adopted for pipelines in populated areas (47 FR 13818; April 4, 1982) requires\noperators to provide a damage prevention program. Typically, under these programs an excavator calls a publicized\nnumber before digging, and the pipeline operator furnishes temporary marking at the job site. Such programs provide\nadvance coordination between operators and excavators and are often run in cooperation with operators of other\nunderground utilities. We will be monitoring the effects of the various damage prevention programs established under\nthe new regulation before taking any further rulemaking action toward prevention of outside force damage to buried\npipelines. The protective measures that the Federal standards provide are, of course, not infallible. I understand that\nthe pipeline involved in the tragic Hudson accident had been temporarily marked before it was damaged by the\ntrenching equipment. Human error, particularly by excavators outside the pipeline industry and the reach of our\njurisdiction, will inevitably continue to be a causal factor in pipeline accidents despite the most diligent Federal\nregulatory efforts.\nI trust this adequately responds to your inquiry, but should you need additional information, do not hesitate to contact\nme.\nSincerely,\nHoward Dugoff\n\n<<<PAGE 2>>>\n\n1006 Park Street\nUniversity Park, IA 52595\nDecember 1, 1982\nThe Honorable James Leach\nHouse of Representatives\nWashington, D. C, 20515\nDear Mr. Leach:\nOn November 4, 1932, a gas pipeline exploded near Hudson, Iowa, taking the lives of my uncle, cousin, and three\nother innocent people'. Not until that tragedy happened was I or the general public aware that the gas companies\nwere required to bury their pipelines only 30 inches deep. This is a travesty which must be remedied.\nWhile I am aware that regulating the gas companies has been delegated to an Administrative Agency; namely, the\nUnited States Department of Transportation, I believe this should be changed. Legislation should be introduced to\nregulate the gas companies.\nAlthough I do plan to petition the United States Department of Transportation, I have worked in a law office for five\n(5) years and therefore, I know that it is nearly impossible to get an administrative rule change,\nMr. Leach, you represent a state that is largely comprised of farmers. I know of several farmers who presently have\nexposed pipelines or the pipelines are buried below the minimum standard, -With soil erosion, doesn't a 30-inch\nminimum standard seem more than a little ridiculous? How long before a farmer hits one of these lines with a chisel\nplow? Are you aware that this makes about the fifth explosion in the past three years? Perhaps the loss of a few lives\ndue to lax regulations and indifference are no big deal.\nI beseech you to introduce legislation to remedy the situation. My family members can never be brought back, but\nplease don't let them have died in vain.\nPlease let me hear from you.\nYours very truly,\nBonnie J. Eggers JJ","truncated":false,"body_characters":5308}