Placement of line markers

§192.707  Line Markers for Mains and Transmission Lines and §195.410  Line markers describe the requirements for line markers and the information they should include.  As the summer months progress vegetation growth may obscure the markers and mowing along roadways may damage or remove markers.  Operators must be vigilant in their patrols to ensure that the required markers remain visible. Additionally, the information on the markers must be legible and accurate.

The following is from the latest PHMSA Compliance Guidance offering information on how to comply with marking regulations.

Guidance Information
§192.707  Line Markers for Mains and Transmission Lines

1.  Install line markers for each transmission line that crosses or lies in close proximity to any high risk area where the potential for future excavation or damage is likely such as:a.  Flood zone areas.

b.  Irrigation ditches and canals subject to periodic excavations for cleaning out or deepening.

c.  Drainage ditches subject to periodic grading, including those along roads.

d.  Agricultural fields subject to deep plowing or where deep-pan breakers are employed.

e.  Active drilling or mining areas.

f.  Waterways or bodies of water, especially those subject to dredging or commercial vessel activities.

g.  Fence lines, notable changes in direction, or exposed pipe including spans.

2.  The operator must have pipeline markers in adequate quantity so that the route of the pipeline can be accurately known.  Land under cultivation, swamps, and commercial areas with significant numbers of buildings and paved areas may present practical exceptions to enforcement of basic pipeline marking requirements but the operator must show that installation of basic markers is impractical in any location where line markers are not installed as described above.

3.  Temporary or permanent line markers are required when the pipeline becomes exposed by design or through acts of nature (erosion by wind or water), in areas accessible to the public.

4.  Line markers are required when the pipeline becomes exposed by design or through acts of nature (erosion by wind or water), in areas accessible to the public.  Some examples of areas that are still considered accessible to the public include: remote areas, barbed wire fences around properties, and cow gates.

5.  Projects of long duration near or on the pipeline may require more frequent verification that markers are in place (see damage prevention guidance).

6.  Multiple lines in a common ROW must have markers for each pipeline located in the ROW.

7.  Assure line markers have current operator name and current telephone number.

8.  Verify that listed 24-hour phone number is responded to by a person who works for the pipeline operator, not just a recorder.

9.  Other methods of indicating the presence of the line are adequate (such as stenciled markings, cast monument plaques, signs or other devices installed in curbs, sidewalks, streets, building facades or any other appropriate location) where the use of conventional markers are not feasible.

10.  Consider where feasible to include on the line marker the Dig Safely national campaign logo and message: Call Before You Dig; Wait the Required Time for Marking; Respect the Marks; and Dig With Care. Call your local One-Call Center or the toll-free National Referral number, 1-888-258-0808.

11.  All exposed pipe must have a marker, whether the pipe is intentionally or unintentionally exposed.

12.  Stickers, as long as permanently affixed and fully legible must be applied may be applied over outdated info as soon as practicable (within six months) over outdated information: however, the telephone number must reach the pipeline operator at all times.

13.  Letters on the marker should be about 1″ high with ¼ inch stroke, and easily readable.

§195.410  Line markers.

1.  The operator must have written procedures for placing and maintaining pipeline markers.

2.  Install line markers for each pipeline that crosses or lies in close proximity to any high risk area where the potential for future excavation or damage is likely such as:

a.  Flood zone areas

b.  Irrigation ditches and canals subject to periodic excavations for cleaning out or deepening

c.  Drainage ditches subject to periodic grading, including those along roads

d.  Agricultural fields subject to deep plowing or where deep-pan breakers are employed

e.  Active drilling or mining areas

f.  Fence lines, notable changes in direction if practicable

g.  Exposed pipe including wash outs and spans, in areas accessible to the public.

3.  The operator must have pipeline markers in adequate quantity so that the route of the pipeline can be accurately known.  Land under cultivation, swamps, and commercial areas with significant numbers of buildings and paved areas may present practical exceptions to enforcement of basic pipeline marking requirements but the operator must show that installation of basic markers is impractical in any location where line markers are not installed as described above.

4.  Line markers are required when the pipeline becomes exposed by design or through acts of nature (erosion by wind or water), in areas accessible to the public.  Some examples of areas that are still considered accessible to the public include: remote areas, barbed wire fences around properties, and cow gates. 5.  Ongoing construction projects near or on the pipeline may require more frequent verification that markers are in place (see Damage Prevention Guidance – §195.442).

6.  Letters on the marker should be about 1″ high with approximate ¼ inch stroke, and easily readable.

7.  Above ground valves must be identified by a line marker in an area accessible to the public.

8.  Stickers, as long as permanently affixed and fully legible, must be applied as soon as practicable, but within six months, over outdated information; however, the telephone number must reach the pipeline operator at all times.

9.  Multiple pipelines in the same ROW shall be individually marked.

10. Final Order Guidance:a.  Kinder Morgan CO2 Company, LP [4-2006-5003] (October 12, 2010): While many operators use the so-called “line of sight” test in determining whether a sufficient number of line markers are placed over buried lines, many other do not.  Section 195.410 does not expressly require that line-of-sight be maintained.

All this and more including the latest PHMSA Guidance on compliance in WinDOT, The Pipeline Safety Encyclopedia.

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