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Interpretation Response #PI-95-023 ([Exxon Pipeline Company] [George G. Persyn])

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

Interpretation Response Details

Response Publish Date:

Company Name: Exxon Pipeline Company

Individual Name: George G. Persyn

Location State: TX Country: US

View the Interpretation Document

Response text:

May 30, 1995

Mr. George G. Persyn

Manager, Environmental & Regulatory

Compliance Department

Exxon Pipeline Company

P. O. No. 2220

Houston, TX 77252-2220

Dear Mr. Persyn:

This responds to your letter of April 19, 1995, to the Dockets Branch of the Research and Special Programs Administration, regarding § 195.442 of our Final Rule "Excavation Damage Prevention Programs for Gas and Hazardous Liquid and Carbon Dioxide Pipelines," published on March 20, 1995.

Your concern is with § 195.442(b)(1) requiring operators to "Include [in the damage prevention program of paragraph (a)] the identity, on a current basis, of persons who normally engage in excavation activities in the area in which the pipeline is located." You maintain that identifying such persons is impractical and unrealistic.

During your telephone conversation with this office on May 8, 1995, we suggested that you consider the various sources that operators of gas pipelines have been using to comply with the similar requirement in § 192.614(b)(1), which has been in effect since April 1, 1983. The sources suggested were:

  • Offices where contractor licenses or excavation permits are obtained.
  • Yellow pages and advertisements in regional newspapers.
  • Regional contractor's associations or other entities with contractor registration lists.
  • Vendors of excavation equipment.
  • One-call systems covering the areas where the pipelines are located.
  • Other sources suggested by gas operators with pipelines in the same areas.

Accordingly, you advised that your office is already investigating some of these sources and expects to be able to handle the requirement in this manner.

We trust that this responds to your concerns.


Cesar DeLeon

Deputy Associate Administrator

for Pipeline Safety

cc: Mr. Jim Thomas, Director

Southwest Region, Office of Pipeline Safety

Regulation Sections

Section Subject
192.614 Damage prevention program
195.422 Pipeline repairs
195.442 Damage prevention program