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Interpretation Response #PI-91-0102

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

Interpretation Response Details

Response Publish Date: 04-15-1991
Company Name: U. S. House of Representatives Room    Individual Name: The Honorable E. Thomas Coleman
Location state: MO    Country: US

View the Interpretation Document

Response text:


April 15, 1991

The Honorable E. Thomas Coleman
U. S. House of Representatives Room 301
851 N. W. 45th Street
Kansas City, Missouri 64116

Attention: Ruth Coffman Dear Congressman


This responds to your correspondence of March 22 and April 2, 1991, regarding installation of plastic marker poles to identify the location of petroleum pipelines. We have reviewed the enclosures accompanying your letters of March 22 and April 2 and have found the questions raised and comments made all deal with the same subject addressed in Ms. Fowler's letter to Congressman Coleman dated February 11, 1991. The letter of February 11 was forwarded to us on February 25, 1991, and answered by our letter of April 2. We believe our April 2, 1991; letter (copy enclosed) is responsive to the additional constituent letters enclosed with your letters of March 22 and April 2, 1991.

If we can be of further assistance, please let us know.


Original signed by
George W. Tenley, Jr.
Associate Administrator for Pipeline Safety

U.S. Department of Transportation
400 Seventh Street, S.W.
Washington, D.C. 20590

April 2, 1991

The Honorable E. Thomas Coleman
U. S. House of Representatives
2468 Rayburn House Office Building
Washington, DC 20515

Dear Congressman Coleman:

Your recent inquiry transmitted a letter from your constituent, Lana Fowler, to our Office of Congressional Affairs. Ms. Fowler, President of the Hidden Lake Homes Association, explained therein that Williams Pipe Line Company (Williams) had installed white plastic marker poles in her neighborhood to identify the location of petroleum pipelines. The Association proposes to replace the marker poles with markers flush with the ground.

The markers identify the location of four pipelines in a single corridor that traverse the neighborhood. They carry gasoline, jet fuel, and home heating oil. The federal regulation (49 CFR 195.410) referred to by Ms. Fowler requires operators such as Williams to mark the presence of pipelines carrying these products by using signs or other objects. The particular type or size of marker is not specified in the regulation, but is left to the operator's discretion provided the objectives of the rule - to warn others of the presence of underground pipelines and to provide an emergency telephone number - are carried out. The importance of pipeline markers was recognized by Congress in 1988 in the Pipeline Safety Reauthorization Act when the destruction or removal of pipeline markers was made subject to criminal penalties.

Although the flush markers recommended by Ms. Fowler may technically be permissible under the pipeline safety regulations, we do not encourage their use because they can become obscured by snow, debris, or vegetation. 1 believe the most effective alternative would be an above ground marker that conveys the required information, but in an aesthetically pleasing manner. Hopefully, this can be worked out in discussions between Ms. Fowler's homeowners' association and Williams.

If we can be of further assistance, please let us know.



Travis P. Dungan
House of Representatives, U.S.
Washington, D.C.

Date: April 2, 1991 respectfully referred to:

Mr. George Tenley
Associate Administrator of Pipeline Safety
Department of Transportation
400 Seventh Street, S. E.
Room 8417
Washington, D. C. 20590

RE: Hidden Lakes Homes Association

Please find enclosed additional information concerning pipeline markers installed in the Hidden Lakes area. My original inquiry to you was dated 3/22/91, in the name of Kathryn L. Breckenridge, Kansas City, MO 64118. Your assistance in this matter would be appreciated.

Thank you.

Congressman Tom Coleman (6th-MO)
Attention: Ruth Coffman
851 N. W. 45th Street, Room 301
Kansas City, Missouri 64116

Regulation Sections

Section Subject
§ 192.707 Line markers for mains and transmission lines