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Interpretation Response #PI-76-020 ([BASF Wyandotte Corporation] [John W. Milroy])

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

Interpretation Response Details

Response Publish Date:

Company Name: BASF Wyandotte Corporation

Individual Name: John W. Milroy

Location State: MI Country: US

View the Interpretation Document

Response text:

April 21 1976

Mr. John W. Milroy
Chief Engineer-Design
BASF Wyandotte Corporation
Wyandotte, MI 48192

Dear Mr. Milroy:

This is in response to your letter dated January 22, 1976, regarding interpretations of the Office of
Pipeline Safety Operations (OPSO) rules and regulations, specifically Section 192.5, Class
location. Contrary to the statement in your letter, OPSO regulations were not written to just
describe residential areas. They are intended to include all types of locations including office
buildings, factories, outside recreation areas, etc. Your plant facilities can be included within a
class location definition.

As set forth in Section 192.5 of the regulations, the class location of a pipeline is determined by
the number of buildings intended for human occupancy within the class location unit, the normal
human occupancy, and the number of stories of those buildings.

OPSO analysis of your plant diagram and corresponding description of facilities indicates that all
of your eight buildings or units are intended for human occupancy. The Administration Building
and the Parking Lot lie within 100 yards of the pipeline and have a normal human occupancy of
more than 20 persons. Therefore, this area appears to be in at least a Class 3 location (refer to
Section 192.5(d)(2)). We cannot determine the class location for the areas adjacent to the other
buildings from the data provided since that determination will depend on the building count in the
remainder of the class location unit.

For purposes of determining class location, we do not consider the platform levels of the
industrial facilities described in your letter to be the same as "stories above ground" set forth in
Section 192.5(c).

If the pipeline is designed and qualified to meet the present day class location requirements then as
your plant develops an more units are actually built, the pipeline may need to be reevaluated to
determine if it satisfies the operating requirements for the new class location or it may require
requalification or operating changes. As an alternate you may design and qualify the pipeline now
to meet the most severe class location requirements that may be anticipated for the future then
increase in class location will have minimal effect on the operation of the pipeline. This is a
procedure many operators follow. Requirements for class location changes are detailed in
Sections 192.609 and 192.611 of the regulations.

OPSO regulations prescribe safety goals to be achieved, while permitting pipeline operators the
flexibility of choosing the best method of accomplishment. As this relates to your interest in class
locations, the regulations do not limit the number of buildings, units, or occupants. Instead, they
prescribe safety requirements which vary by degree in many instances according to the
characteristics of a pipeline's location.

We trust that this has answered your particular questions.

If we can be of further assistance, please let us know.


Cesar Deleon
Acting Director
Office of Pipeline
Safety Operations

Regulation Sections

Section Subject
192.5 Class locations