Guidanceguidance
PI-95-023
Exxon Pipeline Company — Pipeline Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline researchPI-95-023
Page 1U.S. Department 400 Seventh Street, S.W. of Transportation Washington, D.C. 20590 Research and Special Programs Administration May 30, 1995 Mr. George G. Persyn Manager, Environmental & Regulatory Compliance Department Exxon Pipeline Company P. O. No. 2220 Houston, TX 77252-2220 Dear Mr. Persyn: This responds to your letter of April 19, 1995, to the Dockets Branch of the Research and Special Programs Administration, regarding § 195.442 of our Final Rule “Excavation Damage Prevention Programs for Gas and Hazardous Liquid and Carbon Dioxide Pipelines,” published on March 20, 1995. Your concern is with § 195.442(b)(1) requiring operators to “Include [in the damage prevention program of paragraph (a)] the identity, on a current basis, of persons who normally engage in excavation activities in the area in which the pipeline is located.” Your maintain that identifying such persons is impractical and unrealistic. During your telephone conversation with this office on May 8, 1995, we suggested that you consider the various sources that operators of gas pipelines have been using to comply with the similar requirement in § 192.614(b)(1), which has been in effect since April 1, 1983. The sources suggested were: • Offices where contractor licenses or excavation permits are obtained. • Yellow pages and advertisements in regional newspapers. • Regional contractor’ s associations or other entities with contractor registration lists. • Vendors of excavation equipment. • One-call systems covering the areas where the pipelines are located. • Other sources suggested by gas operators with pipelines in the same areas. Accordingly, you advised that your office is already investigating some of these sources and expects to be able to handle the requirement in this manner. We trust that this responds to your concerns. Sincerely, Cesar DeLeon Deputy Associate Administrator for Pipeline Safety cc: Mr. Jim Thomas, Director Southwest Region, Office of Pipeline Safety File: 053095 Opinion Book 195.442 192.614#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.