Interpretation Response #PI-80-0105
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name:
Location State: CT Country: US
View the Interpretation Document
Response text:
November 14, 1980
Mr. Alan Bieber
Montview Engineering Co.
78 Town Woods Road
Lyme, Conn. 06371
Dear Mr. Bieber:
Thank you for your letter of September 5, 1980, regarding the use of indirect techniques, such as
side- scanning sonar, for locating underwater pipelines.
Underwater pipeline inspections are required by 49 CFR 195.412(b) to determine the condition of
pipelines crossing navigable waterways. The purpose of the inspections is to check for conditions
that could endanger safe pipeline operations, such as washouts above or below the pipeline.
Although identifying a pipeline's alignment or location with respect to the river bottom, which the
indirect techniques you have described
seem capable of doing under favorable conditions, is a condition to examine under Section
195.412(b), it is not the only condition to consider. The inspection method must also be capable of
detecting other problems, such as below-grade washouts and physical damage to the pipeline or
coating. Thus, while the indirect techniques would be of value in making the required inspections,
they are not sufficient to furnish all the information needed to comply with Section 195.412(b).
For full compliance, they would have to be complemented by
direct observational techniques.
Sincerely, SIGNED
Melvin A. Judah Acting Director for Pipeline Safety Regulation
Materials Transportation Bureau
Montview Engineering Co.
78 Town Woods Road
Lyme, Conn 06371
September 5, 1980
Mr. Melvin A. Judah
Acting Associate Director
Office of Pipeline Safety Regulations Materials Transportation Bureau Department of Transportation
400 7th St., S.W.
Washington, D.C. 20590
Dear Mr. Judah:
Several weeks ago I discussed with Mr. Heverly the techniques which we use for locating and
determining the position and cover for pipeline river crossings, both for initial acceptance and
periodic inspection. Many of our clients feel that the present method of using a diver to "walk"
the line is not effective; having done black-water diving in the past I tend to agree. The diver
can't see the pipe and must probe for it; and it is very difficult, particularly in swift currents,
to accurately plot the diver's position.
Our clients have asked that we get a determination from you permitting the use of our methods for
these inspections. After describing the procedures to Mr. Heverly, he felt there should be no
problem in this regard, but suggested I formally request this determination from you.
I have enclosed several copies of a technical brochure describing our methods for your information
and to aid you in making this determination. I would appreciate hearing from you at your earliest
convenience.
Very truly yours,
Alan Bieber