Interpretation Response #PI-05-0101 ([Nieder, Bodeux, Carmichael, Huff, Lenox and Pashos, L.L.P] [Mr. Charles W. Nieder])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Nieder, Bodeux, Carmichael, Huff, Lenox and Pashos, L.L.P
Individual Name: Mr. Charles W. Nieder
Location State: MO Country: US
View the Interpretation Document
Response text:
PI-05-0101
U.S. Department of Transportation
Pipeline and hazardous Materials Safety Administration
400 Seventh Street, S.W.
Washington, D.C. 20590
July 22, 2005
Mr. Charles W. Nieder
Attorney at Law
Nieder, Bodeux, Carmichael, Huff, Lenox and Pashos, L.L.P
131 Jefferson Street
St. Charles, MO 63301-2885
Dear Mr. Nieder:
Thank you for your letters of September 28, 2004, and October 13, 2004, requesting an interpretation of Part 49 CFR 192.307.
On March 3, 2005, you modified your requests, asking that the Office of Pipeline Safety (OPS) answer whether or not concrete falls within the definition of consolidated rock at § 192.327. Section 192.327 reads (in part):
§ 192.327 Cover.
(a) Except as provided in paragraphs (c), (e), (1), and (g) of this section, each buried transmission line must be installed with a minimum cover as follows:
| Location | Normal Soil | Consolidated Rock |
|---|---|---|
| Inches (Millimeters) | ||
| Class 1 locations | 30 (762) | 18 (457) |
| Class 2, 3, and 4 locations | 36 (914) | 24(610) |
| Drainage ditches of public roads and railroad crossing | 36 (914) | 24 (610) |
(b) Except as provided in paragraphs (c) and (d) of this section, each buried main must be installed with at least 24 inches (610 millimeters) of cover.
The terms concrete and consolidated rock are defined using the ordinary dictionary definition. Concrete is a synthetically formed coalition of particles into one solid mass, and consolidated rock is a natural geological formation. Because concrete is not a natural geological formation, it does not fall within § 192.327.
If you have further questions regarding this interpretation, please contact me at (202) 366-4595.
Sincerely,
Florence L. Hamn
Director for Regulations
Office of Pipeline Safety