Interpretation Response #PI-73-0104 ([Williams Brothers Pipeline Company] [M. W. A. Elliott])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Williams Brothers Pipeline Company
Individual Name: M. W. A. Elliott
Location State: OK Country: US
View the Interpretation Document
Response text:
January 10, 1973
M. W. A. Elliott
Senior Vice President
Williams Brothers Pipeline Company
P.O. Drawer 3448
Tulsa, Oklahoma 74101
Dear Mk. Elliott:
This refers to your correspondence dated December 4, 1972, concerning pipeline markers at the residence of Stephen P. and Evelyn V. Stimac.
With exceptions not here pertinent, Section 195.410(a) specifically provides that a marker shall be placed ". . . over each buried line. . ." Therefore, you are correct in your interpretation. When we stated in our previous letter that the Federal regulations on line markers afford necessary flexibility to the carrier in his method of compliance, we had reference to such things as vertical positioning, overall size, or height of markers which are not wavered by the regulations. We were not suggesting that you develop a marking policy that did not comply with Section 195.410. The safety objective will not be met if you are allowed to mark multiple lines with only one line marker. Therefore, we do not agree that using a single marker over multiple lines in residential areas such as the Stimacs' is an acceptable solution.
In our previous letter we referenced the API publication for marking liquid pipelines. In this publication API recognized that different type markers could be used and suggested some alternatives for the operators' consideration.
Please review your policy for marking pipelines in residential areas. We suggest that you consider developing a marking policy that would be more satisfactory to the property owners and still comply with Section 195.410.
If we may be of any further assistance to you in this matter, please advise.
Sincerely,
SIGNED
Joseph C. Caldwell
Director
Office of Pipeline Safety
October 17, 1972
Mr. W. A. Elliott
Senior Vice President
Williams Brothers Pipeline Company
P.O. Drawer 3448
Tulsa, Oklahoma 74101
Dear Mr. Elliott
This office recently received inquiries from Senator Robert Dole and Representative Larry Winn, Jr. concerning pipeline markers on the front lawn of Stephen P. and Evelyn V. Stimac's residence.
The Stimac's live at 2736 N. 45th Street, Kansas City, Kansas. They have expressed their grave dissatisfaction with the method that was used to mark the location of the pipeline that crosses 45th street. They have requested a modification as to size and number of these markers in a purely residential area.
The markers you installed do comply with the Federal minimum safety regulations for the Transportation of Liquids by Pipeline, 49 CFR, Part 195, Section 195.410. However, the Federal regulation on line markers is a regulation which affords necessary flexibility to the carrier in his method or compliance. Accordingly, the regulation does not set forth any requirement with regard to vertical positioning, overall size, or height of markers all of which may reasonably vary to meet a local situation. The carrier could utilize one style marker for open county and a completely different style for a residential area and still comply with the minimum Federal safety standard with respect to location, letter size, and color.
The American Petroleum Institute, Division of Transportation, published a recommended Practice for marking Liquid Petroleum Pipeline Facilities, dated October, 1971. In this recommended practice API gives detailed specifications for the type of marker you have apparently utilized on marking the pipelines that cross 45th street. However, in that document API also recognizes that there are certain situations where the conventional marker may not be appropriate. In paragraph 2.8 some alternatives in the type and method of marking a pipeline are suggested.
In the present situation, since Williams Brothers is in compliance with the Federal standards, and therefore meets the safety objective, we believe the matter is one to be resolved between the property owner and the carrier. However, in view of the flexibility afforded by the regulations, the complaint, and the Congressional interest, it is suggested that Williams Brothers review their policy for marking of pipelines in residential areas. We suggest that you consider developing a marking policy that would be more satisfactory to the property owners and still provide an equivalent degree of safety.
If you desire any additional information or wish to further discuss our comments, please contact this office. I would appreciate being advised of any action taken and the final resolution of this problem.
Sincerely,
SIGNED
Joseph C. Caldwell
Director
Office of Pipeline Safety
Regulation Sections
| Section | Subject |
|---|---|
| 195.410 | Line markers |