Interpretation Response #PI-21-0006
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Shell Pipeline Company LP
Individual Name: Ms. Deborah Price
Location State: TX Country: US
View the Interpretation Document
Response text:
Ms. Deborah Price
Integrity and Regulatory Services Managing
Shell Pipeline Company LP
Woodcreek Bldg A-2nd Floor
150 Dairy Ashford Road
Houston, TX 77079
Dear Ms. Price:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated June 4, 2021, you requested an interpretation of 49 CFR Part 195. Specifically, you requested an interpretation as to the applicability of § 195.412 to the use of drones to perform an aerial inspection of pipelines' rights-of-way (ROW).
You stated Shell Pipeline Company LP (SPLC) proposes to use drones to perform aerial inspection of ROW on a new pipeline in the PHMSA Eastern Region. The drone would be equipped with video equipment to fly over the ROW while Operator Qualified personnel will review the footage in real time. You provided, as attachment, examples of the quality of the images produced by the drone. You stated the video footage has an additional benefit of the ability to go back and review the footage. In addition, you stated if necessary, the video footage would also be stored for over time comparisons. You asked PHMSA whether the use of the drone technology complies with the § 195.412 ROW inspection requirements.
Section 195.412(a) requires each operator to inspect the surface conditions on or adjacent to each Part 195 regulated pipeline ROW at intervals not exceeding 3 weeks but at least 26 times each calendar year. Also, § 195.412(a) specifies the methods of inspection to include walking, driving, flying or other appropriate means of traversing the ROW.
Therefore, where aerial ROW inspection is appropriate, § 195.412(a) does not exclude drone (Unmanned Aerial System (UAS)) use as long as the images provided by the UAS have sufficient resolution to provide the necessary details of the surface conditions on and adjacent to each pipeline ROW. However, nothing in this interpretation affects the operator's obligation to operate the UAS in accordance with all laws and regulations regarding UAS use.
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