{"operation":"document","citation":"PI-89-027","title":"US Senate — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1989-12-01","effective_on":null,"summary":"PI-89-027 response to US Senate concerning 192.613.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-027.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-027.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-89-027","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1989/PI89027.pdf","body":"<<<PAGE 1>>>\n\nThe Honorable John C. Danforth\nCommittee on Commerce, Science,\nand Transportation\nUnited States Senate\nWashington, D. C. 20510\nDear Senator Danforth:\nThank you for your letter to Mr. Richard Beam of the Office of Pipeline Safety (OPS) on behalf\nof Gary O. Schuchardt, Director of the Emergency Management Agency in St. Charles County,\nMissouri. Mr. Schuchardt is concerned that Department of Transportation pipeline safety\nregulations do not require maintenance of safe burial depths in flood plains and farms and for\npipelines converted to gas service. You asked that OPS consider the adequacy of its depth\nstandards in developing new criteria for inspecting pipelines as required by the Pipeline Safety\nReauthorization Act of 1988 (the Act).\nThe pipeline safety regulations specify the depth to which a pipeline must be buried at the time of\nconstruction. Although land erosion may reduce pipeline cover, pipeline operators are required to\nsurvey their lines periodically for the presence of unusual operating and maintenance conditions,\nand to take corrective action if conditions are unsafe. Thus, when an operator learns that a\npipeline is unsafe because of potential damage of flooding or a farming activity, it must correct the\nproblem. Remedial action may include lowering the pipeline, adding more cover over the line, or\notherwise protecting it against outside force damage.\nAs you know, sections 108 and 207 of the Act require that we consider certain factors in\ndetermining the frequency of pipeline inspections and tests. These factors, which are to be\napplied on a case-by-case basis, are based on the premise that different pipeline facilities and\ndifferent operating conditions (i.e., variable risk) require different levels of regulatory control. As\nsuch, sections 108 and 207 permit us to consider any factor relevant to pipeline safety. Thus, in\nimplementing these sections, OPS is taking depth of burial into account for these situations in\nwhich it is appropriate to do so.\nEven though depth of burial is an important safety consideration, we have found that damage\nprevention programs employing \"one-call systems\" provide the best protection against excavation\ndamage, including damage by farm implements. Under these programs, pipeline operators\ntemporarily mark and inspect their lines upon request by excavators. Operators of gas pipeline\nsystems are currently required to carry out such a program to prevent damage to pipelines by\nexcavation activities in urban locations. OPS has proposed a rule to extend existing requirements\nfor damage prevention programs for gas pipelines in urban areas to cover gas pipelines in rural\nareas, as well as to establish similar damage prevention program requirements for hazardous liquid\nin pipelines. This proposal would apply to the pipelines in St. Charles County cited in the\nDB\nC:\\WP51\\INTERPRT\\192\\613\\89-12-1\n1\n\n<<<PAGE 2>>>\n\nenclosures to your letter, namely, those of ARCO and the Missouri Pipeline Company. A final\nrule is expected early next year.\nYou may be assured that as we carry out the inspections of pipelines required under the Act, we\nwill assess the issue of pipeline burial depths. Should our assessment reveal the need to amend\nour depth standards, we will act accordingly.\nI hope this information is helpful. Please call me if you have any questions.\nSincerely,\nTravis P. Dungan\nDB\nC:\\WP51\\INTERPRT\\192\\613\\89-12-1\n2","truncated":false,"body_characters":3416}