{"operation":"document","citation":"PI-92-0100","title":"Conoco Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1992-02-07","effective_on":null,"summary":"PI-92-0100 response to Conoco Inc. concerning 195.412.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-0100.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-0100.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-0100","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1992/g92_02_07_Towes_195.412_olox.pdf","body":"<<<PAGE 1>>>\n\nPI-92-0100\nFebruary 7, 1992\nMr. Lyman Toews\nDirector, Regulatory Compliance\nConoco Inc.\nP.O. Box 2197\nHouston, TX 77252\nDear Mr. Toews:\nThis responds to your letter of August 19, 1991, concerning inspections of underwater pipeline crossings of\nnavigable waterways. You asked whether the use of divers to probe with rods to detect the depth of cover\nover these crossings is an acceptable method of inspection under § 195.412. Of particular concern were\npipelines buried so deeply that their depth of cover exceeds the length of the rod.\nSection 195.412 (b) provides: \"Except for offshore pipelines, each operator shall, at intervals not exceeding 5\nyears, inspect each crossing under a navigable waterway to determine the condition of the crossing.\" Since\nthis rule does not specify the method of inspection, any method is acceptable if it enables the operator to\nlearn with reasonable reliability the condition of the crossing.\nWe consider the use of divers to probe with rods along the length of the crossing to be an acceptable method\nof inspection for all underwater crossings. The divers can visually check any uncovered portions of the crossing\nfor damage or for potential damage from drifting debris, such as logs or rocks. For covered portions, the divers\ncan note the depth of burial or that the depth exceeds the rod length. From this information, an operator can\ndecide if the crossing needs repair, or if it needs additional protection against reasonably anticipated external\nforces.\nI am sorry we were not able to answer your letter sooner. However, please let me know if you have further\nquestions on this topic.\nSincerely,\nOriginal signed by\nCesar De Leon\nDirector, Regulatory Programs\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nConoco Inc.\nP.O. Box 2197\nHouston, TX 77252\nAugust 19, 1991\nMr. Cesar De Leon\nResearch and Special Programs Administration\nDepartment of Transportation\nRoom 8417\n400 Seventh Street, S.W.\nWashington D.C. 20590\nDear Mr. De Leon:\nThis letter is to request an interpretation of the DOT regulations concerning the inspection of crossings under\nnavigable waters per DOT 195.412.\nThe usual practice for inspection of crossings under navigable waters is to dispatch divers to identify the depth\nof the pipeline in relation to the water bottom by using pipe probes or rods. The diver will push the pipe probe\ninto the soil until the pipe is felt. The depth of the pipeline below the soil surface is then noted. This inspection\npractice is to identify any pipe that does not have adequate soil cover to prevent damage by any vessels or\nother reasonably predictable erosion activity.\nRecently several river crossings have been installed using a directional drilling method as opposed to the\ntrench-and-lay method. The directional drilling method allows the pipe to be installed at much greater depths\nunder the bed of the river. These depths can exceed the ability of divers to locate the pipeline using probes.\nTherefore probing for the pipeline can only verify the pipeline depth within the probe's length or that the pipe\nis deeper than the pipe probe.\nIt is our interpretation that the use of divers and pipe probes is an adequate inspection method for all\nnavigable water crossings. Whenever the pipeline cannot be detected by probes due to the pipeline's depth,\nthe pipeline has adequate cover and no further inspection activities are required until the next scheduled\ninspection or unless other evidence indicates that an intermediate inspection is required (such as evidence of\nexcessive erosion).\nPlease review our interpretation of inspection of crossings under navigable water and indicate whether or not\nthis is an acceptable practice and interpretation of the regulations.\nShould you have any questions, please call me at (713) 293-4864. Thank you for your consideration of this\nmatter.\nLyman Toews\nDirector Regulatory Compliance","truncated":false,"body_characters":3886}