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Interpretation Response #PI-21-0008

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

Interpretation Response Details

Response Publish Date:

Company Name: Audubon Field Services

Individual Name: Mr. Bryan Louque

Location State: OK Country: US

View the Interpretation Document

Response text:

Mr. Bryan Louque
Vice President Pipeline Integrity
Audubon Field Services
9920 E. 42nd Street
Tulsa, OK 74146

Dear Mr. Louque:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated March 10, 2021, you requested an interpretation of the 49 Code of Federal Regulation (CFR) Part 195. Specifically, you requested an interpretation on the term "nominal diameter" as it relates to the requirements of § 195.11(a).

You asked for clarification on the size of pipelines intended for inclusion in § 195.11 and that PHMSA consider adding a definition to § 195.3.

The nominal pipe size (NPS) is related to the inside diameter in inches, and NPS 12 and smaller pipe has outside diameter greater than the designated size. Therefore, a 6 inches nominal diameter pipe is a 6 ⅝-inches nominal outside diameter pipe and an 8-inches nominal diameter pipe is an 8 ⅝-inches nominal outside diameter pipe. However, for NPS 14 and larger, the NPS is the same as the nominal outside diameter. That is, a 14-inch nominal diameter pipe is the same as a 14-inch nominal outside diameter pipe. API Specification 5L, Specification for Line Pipe, 45th Edition incorporated by reference in 49 CFR § 195.3(b)(13) (API 5L) uses "specified outside diameter" for the nominal outside diameter of pipe. Sections 195.2 (gathering line) and 195.11(a) reference terms "nominal diameter" or "nominal outside diameter" for pipe, with both references being the same nominal outside diameter for pipe that is referenced in API 5L. In addition, the Research and Special Programs Administration (RSPA) (the predecessor to PHMSA) clarified and addressed this issue in a 1994 final rule.1 Also, it should be clear that outside diameters are furnished by pipe mills in nominal outside diameters that are not in whole numbers for less than or equal to 12-inches pipe diameters. For example, pipe with an outside diameter of 2 ⅜-inches is used by pipe mills for a nominal outside diameter of 2-inches. Other examples include 8 ⅝-inches instead of 8 inches, and 10 ¾-inches instead of 10-inches.

Therefore, PHMSA has addressed this issue by regulation as explained by the June 28, 1994, final rule which added using both 6⅝-inches and 8⅝-inches pipe nominal diameters under the § 195.11(a) requirements as pipe outside diameters.

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


John A. Gale
Director, Office of Standards
and Rulemaking

1 RSPA published the final rule in the Federal Register on Tuesday, June 28, 1994 [59 FR 33388].

Regulation Sections

Section Subject
195.11 What is a regulated rural gathering line and what requirements apply?