Interpretation Response #PI-84-0103
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
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Location State: DC Country: US
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Response text:
August 6, 1984
The Honorable Thomas A. Luken House of Representatives Washington, D.C. 20515
Dear Tom:
Thank you for your letter regarding the Sohio pipeline in Green Township, Ohio.
I share your concern for pipeline safety and value your ideas for improvements in our program. I
have asked my newly appointed Administrator of the Research and Special Programs Administration,
Cindy Douglass, to undertake a comprehensive review of our pipeline safety program and to make
recommendations to me for its improvement. This review is to be comprehensive and is expected to
take place over the next several months. Please be assured that your recommendations will be
considered as part of this review.
In regard to your first recommendation calling for inspection of the pipeline, the Department's
Materials Transportation Bureau (MTB), which administers pipeline safety regulatory functions, has
been in touch with the Sohio Pipeline Company and Green Township officials regarding the Sohio
Pipeline accident. On July 13,
1984, Sohio met with the local officials and subsequently prepared a profile of cover over the
pipeline In the Township streets. Sohio has begun to lower the pipeline in areas where the cover
was determined to be inadequate and proposes to prepare a similar profile on its other pipeline in
the Township. MTB and the Green Township officials are satisfied with this course of action.
Your second recommendation is that the Department require all pipelines to meet reasonable
maintenance standards, including a safe burial depth. The Department does have maintenance
standards for gas and hazardous liquid pipelines (49 CFR Part 192, Subpart M, and Part 195, Subpart
F). Although these maintenance standards do not require that any particular amount of cover be
maintained, if an operator knows or should know that a pipeline has become unsafe because of
inadequate cover, the standards require that appropriate remedial action be taken (49 CFR 192.703
and 195.401).
Proper cover over a buried pipeline is an important safety feature, because it distributes external
loads and provides stability for the pipeline. Thus, the Department's standards for constructing
new pipelines require adequate cover over buried pipelines (49 CFR 192.327 and 195.248). However,
once installed, cover is costly and difficult to maintain, because of erosion and other surface
altering activities. Moreover, the Department's pipeline accident data do not show any significant
correlation between depth of cover and prevention of accidents due to digging. Although it seems
reasonable to expect that adequate cover would reduce these types of accidents, there is not any
evidence to support the proposition that maintaining original cover would be cost-effective as a
general safety rule.
In contrast, experience has shown that measures such as linemarking, mapping, and advance
coordination-of digging activities provide an effective economical approach to damage prevention.
The Federal safety standards now require operators of buried pipelines in rural areas to install
permanent marking signs along the pipelines to show their location. Each sign provides a warning,
the name of the operator, and a telephone number a person preparing to dig may call to learn more
specific information about the pipeline. Another standard that became effective last year for gas
pipelines in populated areas requires operators to provide a damage prevention program (49 CPR
192.614). Typically, under these programs a person calls a publicized
number before digging, and the pipeline operator provides specific temporary marking at the site.
Such programs provide advance - coordination between operators and persons preparing to dig, and
are often run in cooperation with operators of other underground utilities. MTB will be monitoring
the effects of the various programs established under this new regulation before taking any further
action to prevent outside force damage to buried pipelines.
MTB has learned that a "one call" damage prevention program is in effect in Green Township, but the
road crew involved in the accident did not call before beginning to dig.
Again, thank you for allowing me the benefit of your views. Hook forward to working with you to
improve pipeline safety.
With best wishes.
Sincerely,
Signed
Elizabeth Hanford Dole