Interpretation Response #PI-80-0101
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name:
Location State: CA Country: US
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Response text:
May 22, 1980
Mr. John E. Myrick
Manager, Technical Services
Northwest Alaskan Pipeline Company
Fluor Engineering and Constructors, Inc.
3333 Michelson Drive
Irvine, California 92730
Dear Mr. Myrick:
One of the proposed construction modes for the Alaska portion of the Alaska Natural Gas
Transportation System to be used north of the Brooks Range specifies a five feet deep trench.
Although a berm would be constructed over the pipeline to provide protection, the cover from the
top of the pipe to the natural ground level would only be one foot.
I discussed with you on May 8, 1980 in Hanover, New Hampshire the possibility that this mode of
construction might not comply with the cover requirements of the Minimum Federal Safety Standards
for gas pipelines contained in 49
CFR 192.327(a). A minimum cover of 30 inches in normal soil or 18 inches in consolidated rock is
required in a class 1 location. It is not stated in the regulation from what point the cover is
measured in order to assure compliance. However, there is some guidance given from past
interpretations. One such interpretation dated December 3, 1976 states in part: “Section 192.327 of
the regulations prescribes minimum cover for transmission lines and mains measured at the time of
construction from the ground surface or the bottom of a drainage ditch, as applicable.” The term
"ground surface" would indicate that the cover would be measured from the natural ground level
before ditch excavation.
I would suggest that you request an interpretation of the regulation to eliminate any possibility
of conflict with the cover requirement. Please forward any such request to my office and I will
expedite a response to the request within the Materials Transportation Bureau.
Sincerely, Original Sign By Lloyd W. Ulrich
Acting Associate Director for
Alaska Pipeline
Materials Transportation Bureau
Northwest Alaskan Pipeline Company
1801 K Street, N. W. Washington, D.C. 20006
August 28, 1980
Mr. Lloyd W. Ulrich
Acting Associate Director, Alaska Pipeline
Materials Transportation Bureau
Department of Transportation
Washington, D.C. 20590
Re: Interpretation of 49 CFR 192.327(a) Dear Mr. Ulrich:
Section 192.327(a) of the Code of Federal Regulations, Part 49 specifies the minimum cover required
for the installation of transmission lines. However, the point from where the depth of cover should
be measured is not specified. On the 48" natural gas pipeline to be constructed in Alaska as part
of the Alaska Natural Gas Transportation System, an interpretation might, therefore, be required in
every case where the mode of pipeline burial differed from the normal buried mode.
We have been interpreting Section 192.327 to mean the following:
The word "cover" shall mean "the minimum depth or thickness of backfill around the pipe measured
from any point on the circumference of the pipe."
We understand that where the Code is not explicit in dealing with a special case, an interpretation
from the Office of Pipeline Safety Operations will provide the necessary authority, unless there is
a significant departure from the code. Therefore, an official interpretation is requested of the
word "cover," perhaps a determination that our interpretation is acceptable.
Yours truly,
Northwest Alaskan Pipeline Company
Edwin (Al) Kuhn Director Governmental Affairs
United State Government
Department of Transporation
Research and Special Programs Administration
MEMORANDUM
Date: September 5, 1980
Subject: Request for Interpretation of 49 CFR Part 192
From: Acting Associate Director for Alaska Pipeline, DMT-50
To: Acting Associate Director for Pipeline Safety Regulation,
DMT-30
Attached is a request from Al Kuhn of Northwest Alaskan Pipeline Company for an interpretation of
49 CFR 192.327(a)
concerning depth of cover and specifically the point from where the depth of cover should be
measured.
I would appreciate your Office processing Mr. Kuhn's request and provide me with an interpretation
so that I can
I would appreciate yo
respond to his letter.