Interpretation Response #PI-76-0107

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 07/15/1976

Company Name:

Individual Name:

Location State: OK Country: US

View the Interpretation Document

Response text:

July 15, 1976
Mr. E. S. Hanson
Senior Vice President
Cities Service Gas Company
First national Center
Oklahoma City, Oklahoma 73102

Dear Mr. Hansom
In your letter of May 14, 1976, to Mr. Marshall W. Taylor, II, Chief, Central Region, you ask
whether 49 CFR 192.707(c)
requires line markers at regulator stations. Section 192.707 (c) provides:
“Pipelines Aboveground. Line markers must be placed and maintained along each section of a main and
transmission line that is located aboveground in an area accessible to the public.”

Since under section 192.3 a “regular station” is included within the meaning of the terms
“transmission line” and “main,” any aboveground regulator station must be marked if it is located
in an area accessible to the public.  For the purpose of section 192.707(c), an area is accessible
to the public if entrance into the area is not physically controlled by the operator or if the area
may be entered without difficulty.

With regard to your question about marking a farm tap meter and regulator installation, a farm tap
which serves a single customer is classified as a “service Line” under 49 CFR part 192 and would
therefore not be subject to the marking requirement of section 192.707(c). Where a farm tap serves
more than one customer, a portion of it would be classified as either a “main” or “transmission
line” and subject to the marking requirement if located above ground.

We trust this satisfactorily responds to your inquiry.

Sincerely, Cesar DeLeon Acting Director Office of Pipeline Safety Operations

United States Government Department of Transportation Materials Transportation Bureau

June 10, 1976

To:                       Chief, Regulations Division, MTP-30
Thru: Chief, Operations Division, MTP-50

FROM:                Chief, Central Region

SUBJECT:            Request for interpretation

Cities Service Gas Company has requested an interpretation pertaining to marker requirements for
aboveground pipelines in their information letter of May 14, 1976. The request is contained in item
3 of the letter.

Clarification is requested for 192.707(c) Pipelines aboveground, which states that "Line markers
must be placed and maintained along each section of a main and transmission line that is located
aboveground in an area accessible to the public."

We respectfully submit for consideration aspects of this requirement which have been discussed with
operators in the course of our inspections. This discussion is included to indicate the positions
we have taken in the past.

1.      Marking of metering and regulating stations.

We have contended that metering and regulating stations are required to be marked to meet the
aboveground piping marking requirement. We also contend that valve settings require markers for
identification. We do consider, however, that if a road crossing marker is located in the near
vicinity of such aboveground facilities, an additional marker is not required.

2.      Accessibility to the public.

The question of what is accessible to the public has also been discussed. Some feel that the
presence of a fence around the piping, at a regulating station for instance, renders the piping
inaccessible to the public, and negates the marker requirement. The regulation states, however,
that if the pipe is in an area accessible to the public it must be marked. It does not refer to the
accessibility of the piping alone. The area in which the piping is located should not be construed
to mean that small space often enclosed by the operator's fence.

We have also recommended that markers be located at aboveground piping such as spans, in remote
areas. Remote areas are not necessarily inaccessible to the public.

3.     Farm taps.

Cities Service has suggested that requiring markers at metering and regulating stations might also
require marking of farm tap piping facilities. This office has not recommended the marking of farm
tap facilities. Farm tap piping would not fall under the classification of a main or transmission
line.

We would appreciate it if the items aforementioned could be included - in your interpretation for
Cities Service. If they cannot, since the operator's request does not specifically confront these
situations, please advise us as to the validity of our assumptions to enable us to maintain
uniformity in our compliance program throughout the five regions.

Marshall W. Taylor, II, MTF -50-CE

Cities service Gas Company First National Center Oklahoma City, OK 73102

May 14, 1976

Mr. Marshall W. Taylor, II Chief, Central Region
Office of Pipeline Safety Operations
911 Walnut Street
Kansas City, Missouri 64106

Dear Mr. Taylor:

Pursuant to your request in letter dated April 16, 1976, for compliance information with Title
49 of the Code of Federal Regulations, Part 192, following is Cities Service Gas Company's status
of records, inspection, and policy,

1.     Testing of Relief Devices on the Air System at Saginaw Compressor Station.

It is Cities' policy to test relief valves installed on its compressor station air systems
annually. The fact that the air system relief valves at Saginaw were not tested was an oversight.
Such inspection and testing have been completed and a copy of inspection record is attached.

2.     Testing of Relief Devices at Regulator Stations

Instructions issued by Cities to its responsible field personnel stated that relief devices must be
tested annually. These instructions were interpreted by some employees to mean once each calendar
year. Accordingly, test records indicated appropriate tests in 1974 and 1975 but the time interval
exceeded one year. Revised Instructions are being prepared stating "relief
devices must be tested at intervals not exceeding twelve months."

3.     Marking of Transmission Pipelines

Specific instructions are being prepared emphasizing that all transmission line spans should be
marked. These instructions will be issued to all pipeline divisions to supplement current
instructions. The seven spans mentioned in the inspection report have been marked.

In regard to identifying signs at regulator stations, Cities does not interpret § 192.707 to
require pipeline markers at every above ground appurtenance. The marker regulation was amended
specifically to prevent damage to buried transmission lines and mains by excavation-related
activities. Nearly four pages of discussion and comments were issued in conjunction with the
revised marker regulation dated April 12, 1975. These comments center on protecting buried, unseen
transmission lines and mains with the exception of § 192.707(c), which refers to above ground
transmission lines and mains. For these reasons we do not feel that § 192.707 was intended to
require identifying signs at regulator stations. We„ therefore, respectfully request an official
interpretation of the regulation.

In formulating such interpretation, consideration should be given to the overall ramifications of
carrying out a marker or identification program encompassing all appurtenances. For example would a
farm tap meter and regulator installation require marking or identification?

4.     Transmission Valve Inspections

During 1972 and 1973, a number of supervisory personnel changes occurred at our Miami, Oklahoma
pipeline division. Apparently, due to lack of continuity of supervisory responsible
personnel, Cities' policy of inspecting transmission valves was not carried out during this period;
therefore, we cannot verify such inspections. From 1974 to date, documentation records show the
program has been carried out in full compliance with the regulations.

5.     Atmospheric Corrosion Monitoring of Above Ground Piping

Attached is the form we developed to monitor atmospheric corrosion, together with instructions
pertaining to its use. Such data was issued to meet compliance and documentation requirements of §
192.481. It appears that field supervisors generally misinterpreted these instructions to apply
only to above ground pipelines such as spans or transmission lines mounted on bridges. Your
inspection report has called to our attention that more explicit instructions need to be prepared
and issued with respect to monitoring of atmospheric corrosion. These instructions are now being
prepared.

6.     Calculation of Relief Valve Capacities

When Cities adopted its program to comply with § 192.743, it was felt that appropriate
documentation of relief device capacities should be maintained in the Oklahoma City office where
such calculations are conducted. With this concept, field personnel only test set pressures of
relieving devices. For example calculation of capacity of relief valves installed on the Stones
Corner TBS and Silvercreek Addition TBS are attached for your review.

It is intended that the foregoing provides all of the information requested in your letter of April
16,
1976. Cities Service Gas Company is vitally interested in carrying out safe operations of its
pipeline system and is endeavoring to comply with all applicable DOT regulations. We appreciate the
concern and courtesy extended to our field personnel by your compliance inspector; moreover, we are
fully cognizant of the joint effort required of industry and government to carry out safe pipeline
operations and wish to assure you of our full cooperation.
Yours very truly,
E. S. Hanson, Senior Vice President
Gas Transmission Division

Regulation Sections