{"operation":"document","citation":"PI-84-0103","title":"Pipeline Safety Interpretation PI-84-0103","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1984-08-06","effective_on":null,"summary":"PI-84-0103 concerning 192.327.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0103.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0103.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0103","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1984/g84-08-06_Thomas_192.327-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-84-0103\nCERTIFIED TRUE COPY\nAugust 6, 1984\nThe Honorable Thomas A. Luken\nHouse of Representatives\nWashington, D.C. 20515\nDear Tom:\nThank you for your letter regarding the Sohio pipeline in Green Township, Ohio.\nI share your concern for pipeline safety and value your ideas for improvements in our program. I have asked\nmy newly appointed Administrator of the Research and Special Programs Administration, Cindy Douglass, to\nundertake a comprehensive review of our pipeline safety program and to make recommendations to me for\nits improvement. This review is to be comprehensive and is expected to take place over the next several\nmonths. Please be assured that your recommendations will be considered as part of this review.\nIn regard to your first recommendation calling for inspection of the pipeline, the Department's Materials\nTransportation Bureau (MTB), which administers pipeline safety regulatory functions, has been in touch with\nthe Sohio Pipeline Company and Green Township officials regarding the Sohio Pipeline accident. On July 13,\n1984, Sohio met with the local officials and subsequently prepared a profile of cover over the pipeline In the\nTownship streets. Sohio has begun to lower the pipeline in areas where the cover was determined to be\ninadequate and proposes to prepare a similar profile on its other pipeline in the Township. MTB and the Green\nTownship officials are satisfied with this course of action.\nYour second recommendation is that the Department require all pipelines to meet reasonable maintenance\nstandards, including a safe burial depth. The Department does have maintenance standards for gas and\nhazardous liquid pipelines (49 CFR Part 192, Subpart M, and Part 195, Subpart F). Although these maintenance\nstandards do not require that any particular amount of cover be maintained, if an operator knows or should\nknow that a pipeline has become unsafe because of inadequate cover, the standards require that appropriate\nremedial action be taken (49 CFR 192.703 and 195.401).\nProper cover over a buried pipeline is an important safety feature, because it distributes external loads and\nprovides stability for the pipeline. Thus, the Department's standards for constructing new pipelines require\nadequate cover over buried pipelines (49 CFR 192.327 and 195.248). However, once installed, cover is costly\nand difficult to maintain, because of erosion and other surface altering activities. Moreover, the Department's\npipeline accident data do not show any significant correlation between depth of cover and prevention of\naccidents due to digging. Although it seems reasonable to expect that adequate cover would reduce these\ntypes of accidents, there is not any evidence to support the proposition that maintaining original cover would\nbe cost-effective as a general safety rule.\nIn contrast, experience has shown that measures such as linemarking, mapping, and advance coordination-of\ndigging activities provide an effective economical approach to damage prevention. The Federal safety\nstandards now require operators of buried pipelines in rural areas to install permanent marking signs along\nthe pipelines to show their location. Each sign provides a warning, the name of the operator, and a telephone\nnumber a person preparing to dig may call to learn more specific information about the pipeline. Another\nstandard that became effective last year for gas pipelines in populated areas requires operators to provide a\ndamage prevention program (49 CPR 192.614). Typically, under these programs a person calls a publicized\n\n<<<PAGE 2>>>\n\nnumber before digging, and the pipeline operator provides specific temporary marking at the site. Such\nprograms provide advance - coordination between operators and persons preparing to dig, and are often run\nin cooperation with operators of other underground utilities. MTB will be monitoring the effects of the various\nprograms established under this new regulation before taking any further action to prevent outside force\ndamage to buried pipelines.\nMTB has learned that a \"one call\" damage prevention program is in effect in Green Township, but the road\ncrew involved in the accident did not call before beginning to dig.\nAgain, thank you for allowing me the benefit of your views. Hook forward to working with you to improve\npipeline safety.\nWith best wishes.\nSincerely,\nSigned\nElizabeth Hanford Dole\n\n<<<PAGE 3>>>\n\nCongress of the United States\nHouse of Representatives\nWashington, D.C. 20515\nJuly 7, 1984\nElizabeth Hanford Dole\nSecretary of Transportation\n400 Seventh St., S.W.\nWashington, D.C.\nDear Mrs. Dole:\nAs a member of the Energy Committee and as representative of the First District of Ohio, I am extremely\nconcerned about the potentially disastrous condition of the Sohio pipeline in Green Township in my district.\nMy recommendations are:\n1.) DOT should immediately require the contractor, Sohio, to inspect the pipeline from end to end in the\nurbanized ares, to determine if there are any other points where the pipeline is at or near the ground\nsurfact.\n2.) Immediately propose and adopt regulations which would require all pipeline operators, even those\nbuilt before 1972, to comply with reasonable standards for maintenance (including a safe depth) of all\npipelines.\n3.) If, in your opinion, legislation is needed for you to take these basic life saving actions, I will introduce\nsuch legislation forthwith.\nOn June 15, road crews penetrated the gasoline pipeline at a depth of approximately 6\" below the street\nsurface 9,000 gallons of gasoline spewed over the surrounding area, endangering 25-30 homes and their\noccupants.\nThere is every reason to believe that the pipeline is at or near the surface in nearby areas, also highly\nurbanized.\nYet, the operator, Sohio, has refused to make an inspection, relying on the defense that the pipeline location is\ngenerally marked by signs. In doing so, Sohio is ignoring the fact that warnings not to \"excavate\" are not\nsufficient to warn of dangerous pipelines only 6\" deep. Reasonable people do not consider they are excavating\nat 6\". In addition, if it is 6\" at this point, at another point nearby it may be 4\" or 3\", because of erosion or\nsettlement of structures.\nAs you know, many more of the 1,75 million miles of pipeline in this country were built 30 or 40 years ago.\nThey are nearing the end of their life span. Therefore, we can expect the 1982 figures of 21 deaths, 272\ninjuries and 200 hazardous spills from pipelines to increase if DOT maintains a hands off policy while the\noperators stonewall pleas for safety.\nPlease advise as to your thoughts on the matter.\nSincerely yours,\nThomas A Luken, M.C.\n1st Dist. Of Ohio","truncated":false,"body_characters":6685}