{"operation":"document","citation":"PI-88-005","title":"U.S. House of Representatives — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1988-12-02","effective_on":null,"summary":"PI-88-005 response to U.S. House of Representatives concerning 195.412.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-88-005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-88-005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-88-005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1988/PI88005.pdf","body":"<<<PAGE 1>>>\n\nDec 2 1988\nThe Honorable Bill Archer\nMember, U.S. House of Representatives\n515 Rusk\nHouston, Texas 77002\nDear Congressman Archer:\nI am responding to your request for consideration of the pipeline\nright-of-way matter involving landowners, Byron L. Brown and\nJuanita M. Brown. While we are sympathetic to any disagreement\nconcerning the rights of landowners in relation to those of\neasement owners, the solution is largely a matter of state and\nlocal law.\nIn regard to the landowners' specific concerns, the Department of\nTransportation's Office of Pipeline Safety (OPS) has looked into\nthis matter and advised me that Exxon has three crude oil\npipelines crossing the Browns' property and that the trees on the\neasement have been cut down, but not fully removed from the\nproperty. The federal pipeline safety standards require all\noperators, to \"...inspect the surface conditions on or adjacent\nto each pipeline right-of-way.\" The purpose of these inspections\nis to locate any pipeline leaks and to detect excavation activity\nwhich could affect the safe operation of the pipeline. The\nfederal standards allow operators to choose the manner of\ninspection. Exxon, as have most operators, has chosen air\nsurveillance. Thus, it is necessary to observe the ground in the\nvicinity of the pipeline from the air. OPS does not require that\nthe surveillance be by air or that any specific width be clear-\ncut, only that the method of surveillance chosen and its\nimplementation allow the surface condition to be adequately\nsurveyed. Exxon has advised OPS that, due to the number of miles\nof pipeline in their system, air patrol is the most economical\nmethod available to meet the federal requirement for inspection\nof rights-of-way.\nIn addition to the patrolling requirements, federal rules require\nthat Exxon must maintain and repair its pipelines at all times to\nprotect the public safety. Exxon advised OPS that the tree roots\ndal\\195\\412\\88-12-02\n1\n\n<<<PAGE 2>>>\n\nhere may threaten the integrity of its pipelines. They believe,\nand we agree, that tree roots can damage pipe coating and\ndiminish the effectiveness of the corrosion control system, which\nis required for safety by federal law.\nI hope this information is helpful to you.\nSincerely,\nM. Cynthia Douglass\ndal\\195\\412\\88-12-02\n2","truncated":false,"body_characters":2292}