# US Senate — Pipeline Safety Interpretation

- **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:** Not available
- **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>>>

The Honorable John C. Danforth
Committee on Commerce, Science,
and Transportation
United States Senate
Washington, D. C. 20510
Dear Senator Danforth:
Thank you for your letter to Mr. Richard Beam of the Office of Pipeline Safety (OPS) on behalf
of Gary O. Schuchardt, Director of the Emergency Management Agency in St. Charles County,
Missouri. Mr. Schuchardt is concerned that Department of Transportation pipeline safety
regulations do not require maintenance of safe burial depths in flood plains and farms and for
pipelines converted to gas service. You asked that OPS consider the adequacy of its depth
standards in developing new criteria for inspecting pipelines as required by the Pipeline Safety
Reauthorization Act of 1988 (the Act).
The pipeline safety regulations specify the depth to which a pipeline must be buried at the time of
construction. Although land erosion may reduce pipeline cover, pipeline operators are required to
survey their lines periodically for the presence of unusual operating and maintenance conditions,
and to take corrective action if conditions are unsafe. Thus, when an operator learns that a
pipeline is unsafe because of potential damage of flooding or a farming activity, it must correct the
problem. Remedial action may include lowering the pipeline, adding more cover over the line, or
otherwise protecting it against outside force damage.
As you know, sections 108 and 207 of the Act require that we consider certain factors in
determining the frequency of pipeline inspections and tests. These factors, which are to be
applied on a case-by-case basis, are based on the premise that different pipeline facilities and
different operating conditions (i.e., variable risk) require different levels of regulatory control. As
such, sections 108 and 207 permit us to consider any factor relevant to pipeline safety. Thus, in
implementing these sections, OPS is taking depth of burial into account for these situations in
which it is appropriate to do so.
Even though depth of burial is an important safety consideration, we have found that damage
prevention programs employing "one-call systems" provide the best protection against excavation
damage, including damage by farm implements. Under these programs, pipeline operators
temporarily mark and inspect their lines upon request by excavators. Operators of gas pipeline
systems are currently required to carry out such a program to prevent damage to pipelines by
excavation activities in urban locations. OPS has proposed a rule to extend existing requirements
for damage prevention programs for gas pipelines in urban areas to cover gas pipelines in rural
areas, as well as to establish similar damage prevention program requirements for hazardous liquid
in pipelines. This proposal would apply to the pipelines in St. Charles County cited in the
DB
C:\WP51\INTERPRT\192\613\89-12-1
1

<<<PAGE 2>>>

enclosures to your letter, namely, those of ARCO and the Missouri Pipeline Company. A final
rule is expected early next year.
You may be assured that as we carry out the inspections of pipelines required under the Act, we
will assess the issue of pipeline burial depths. Should our assessment reveal the need to amend
our depth standards, we will act accordingly.
I hope this information is helpful. Please call me if you have any questions.
Sincerely,
Travis P. Dungan
DB
C:\WP51\INTERPRT\192\613\89-12-1
2
- **truncated:** false
- **body characters:** 3416