Interpretation Response #PI-19-0010

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

Interpretation Response Details

Response Publish Date: 09/11/2019

Company Name: East Goshen Township

Individual Name: Mr. Rick Smith

Location State: PA Country: US

View the Interpretation Document

Response text:

Mr. Rick Smith
Township Manager
East Goshen Township
1580 Paoli Pike
West Chester, PA 19380

Dear Mr. Smith:

In an August 6, 2019, email to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Part 195. Specifically, you requested an interpretation of §195.250-Clearance between pipe and underground structures.

You stated that Energy Transfer has asked for a permit from the East Goshen Township to work "around the clock" during pull back operations. You stated that Energy Transfer plans to pull back dual pipes with 16-inch and 20-inch nominal diameters. You stated that it is your understanding that when the two pipes are pulled there will be less than 12 inches of clearance, as required by §195.250. You indicated that a question arose as to whether §195.250 would be applicable to Energy Transfer. Section 195.250 states:

§195.250 Clearance between pipe and underground structures. Any pipe installed underground must have at least 12 inches (305 millimeters) of clearance between the outside of the pipe and the extremity of any other underground structure, except that for drainage tile the minimum clearance may be less than 12 inches (305 millimeters) but not less than 2 inches (51 millimeters). However, where 12 inches (305 millimeters) of clearance is impracticable, the clearance may be reduced if adequate provisions are made for corrosion control.

Therefore, you asked for PHMSA's responses to the following three questions. PHMSA's response follows each of your questions.

Question #1: Would §195.250 be applicable to two pipelines that are installed by the same company?

Response to #1: Yes, the requirements of §195.250 are applicable. However, "...where 12 inches of clearance is impracticable... ," §195.250 permits clearance to be reduced "....if adequate provisions are made for corrosion control." Therefore, §195.250 does not necessarily restrict two pipelines from being installed with less than 12 inches of clearance between them. In this situation where the pipelines will be close to each other, corrosion control must consider at a minimum the regulatory requirements specified in §195.575 pertaining to electrical isolation.

Question #2: Who determines if it is “impracticable” to reduce the clearance between the two pipelines?

Response to #2: The pipeline operator is responsible for complying with all applicable pipeline safety regulations. The operator is solely responsible for implementing design, construction, operation, and maintenance procedures that meet 49 CFR Part 195. Thus, the pipeline operator would be responsible for making that determination and for ensuring that adequate provisions are made for corrosion control if 12 inches of clearance was determined to be impracticable per §195.250. PHMSA or the State pipeline safety regulator validate and verify if operators are compliant with applicable pipeline safety regulations, including this provision.

In addition to addressing corrosion control, another key design requirement that Energy Transfer should address in their dual "pull back" design and installation is how they are going to comply with §195.110 External loads, particularly those associated with localized stresses on the pipelines. Any pipe bundles and associated spacers must be designed to keep the pipelines separated as to minimize localized stresses between the two pipes, and facilitate design, operation, and maintenance of a proper corrosion control system that meets the requirements of 49 CFR Part 195, Subpart H.

Question #3: Who determines if the provisions for corrosion control are "adequate"?

Response to #3: The pipeline operator is responsible for complying with all applicable pipeline safety regulations, including corrosion control. The operator most install sufficient test leads to monitor and demonstrate the adequacy of the corrosion control system for each pipeline along the entire horizontal directional drilling (HDD) segment per §§195.567, 195.571 and 195.573. Furthermore, the pipelines should be protected against fault current and interference currents, per §§195.575 and 195.577, respectively. PHMSA or the State pipeline safety regulator will determine if the operator is compliant with applicable pipeline safety regulations, including this provision.

If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.

Sincerely,

John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections