Interpretation Response #PI-76-047

Interpretation Response Details

August 11, 1976

Mr. Bruce Raddatz, P.E.
Wilson & Company
P.O. Box 28
Salina, Kansas 67401

Dear Mr. Raddatz:

Your letter of June 29, 1976, requests an interpretation of Title 49, Code of Federal Regulations, Part 195, Transportation of Liquids by Pipeline, Section 195.248 regarding the cover over a proposed liquid pipeline crossing a channel. You state that, "It is my understanding that thirty-six (36) inches of cover between the top of the pipe and the channel flow line will be adequate."

In as much as the channel appears to be a "drainage ditch" within the meaning of Section 195.248(a), the requisite amount of cover would be thirty-six (36) inches for normal excavation, subject to Sections 195.210 and 195.248(b). The cover would not, however, be measured from the top of the pipe to the channel flow line.

Consistent with the requirements of Section 195.248(a), which indicate that cover is measured between "the top of the pipe and ground level, road bed, or river bottom as applicable," the required cover would be measured from the top of the pipe to the bottom of the channel.

Thank you for you interest in pipeline safety.

Sincerely,

Cesar DeLeon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections