Interpretation Response #PI-73-0105 ([Associated Engineering Consultants Incorporated] [Mr. Guy W. Griggs, P.E.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Associated Engineering Consultants Incorporated
Individual Name: Mr. Guy W. Griggs, P.E.
Location State: TX Country: US
View the Interpretation Document
Response text:
March 15, 1973
Mr. Guy W. Griggs, P.E.
Vice President, Associated Engineering Consultants Incorporated
2828 Bammel, Suite No. 107
Houston, Texas 77006
Dear Mr. Griggs:
Your letter of February 23, 1973, addressed to our Houston office has been referred to this office for reply. In that letter you described a situation in which an area traversed by an existing crude oil pipeline is being developed as a subdivision. At three points within the subdivision where the pipeline crosses proposed streets, the pipeline will be lowered, cased, and vented. You ask whether, because of the changes to the pipeline at the street crossings, it is required that the entire existing pipeline within the subdivision be brought into conformity with the new construction requirements of Subpart D of Part 195.
As stated in §195.200, Subpart D prescribes requirements for constructing new pipeline systems with steel pipe and for relocating, replacing, or otherwise changing existing pipeline systems that are constructed with steel pipe.
The phrase “relocating, replacing, or otherwise changing existing pipeline systems,” within the meaning of §195.200, has reference to relocation of, replacement of, or other changes to any segment of an existing pipeline system. The regulation does not mean that relocation, replacement, or other change affecting one segment of a pipeline requires upgrading a carrier’s entire system to current new construction standards. Furthermore, in your situation, there appears to be no basis for defining a pipeline system as that contained within the boundaries of one particular subdivision.
With respect to the segments of the pipeline being changed as they go under the proposed streets, such segments are required to meet the requirements of Subpart D to the extent applicable.
Based on the situation as you have described it, there is no Federal requirement that the entire existing pipeline within the boundaries of a subdivision be upgraded to the construction requirements of Subpart D because three segments of that pipeline are changed or because a housing development is being built in the vicinity.
I trust this answers your inquiries. If you have further questions in this regard, please call on us.
Sincerely,
Original signed by:
Joseph C. Caldwell
Director
Office of Pipeline Safety