Interpretation Response #PI-71-035 ([City of Palo Alto, Water-Gas Sewer Department] [H. R. Remmel])

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

Interpretation Response Details

Response Publish Date: 03/11/1971

Company Name: City of Palo Alto, Water-Gas Sewer Department

Individual Name: H. R. Remmel

Location State: CA Country: US

View the Interpretation Document

Response text:

Mr. H. R. Remmel
Senior Engineer
City of Palo Alto
Water-Gas Sewer Department
Palo Alto, California 94301

Dear Mr. Remmel:

This is in reply to your letter of February 11, 1971, submitting your annual report as required by
49 CFR, Part 191 and requesting an interpretation of 49 CFR, Section 192.321(e). You state that
you have a good mapping system and therefore have not used an electric conductive wire for
locating underground plastic pipe. You further state that, as a municipal agency you control other
street excavations.

49 CFR, Section 192.321(e) was intended to be prospective in effect and apply only to new
construction, not to pipe in the ground on the effective date of the regulation.

We would interpret your mapping systems to be "other means" within the regulation, if it has a
permanent geographic reference that is not solely the location of the street.

Thank you for your interest in pipeline safety.

Sincerely,

/signed/

Joseph c. Caldwell
Director, Acting
Office of Pipeline Safety

Regulation Sections