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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-94-035 ([Conoco Pipe Line Company] [Dwight D. Jackson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Conoco Pipe Line Company

Individual Name: Dwight D. Jackson

Location State: TX Country: US

View the Interpretation Document

Response text:

October 24, 1994

Dwight D. Jackson

Manager, Pipeline Services and Regulatory Compliance

Conoco Pipe Line Company

Houston, Texas 77252

Dear Mr. Jackson:

Your letter of August 19, 1994, requests further clarification of the "single public thoroughfare" interpretation discussed in the preamble of the low-stress pipeline Final Rule (59 FR 35465; July 12, 1994). The interpretation concerned plants that are divided into separate parts by a single public thoroughfare. It provides that a plant transfer line that crosses the thoroughfare may qualify for the in-plant piping exception under § 195.1(b)(6).

You asked if a single public thoroughfare includes a railroad. As stated in the preamble, the thoroughfare interpretation applies only to transfer piping that crosses a road. It does not apply to piping that crosses a railroad, whether a mainline or spur. Railroads were excluded because of the added risk that railroads pose to pipeline safety.

The thoroughfare interpretation does not mean that every plant transfer line that crosses a railroad comes under the regulations in 49 CFR Part 195. If a plant transfer line does not come under the in-plant piping exception because it crosses a railroad that divides a plant, it may still be excepted under another provision of § 195.1(b). For example, certain low-stress pipelines are excepted under § 195.1(b)(3). If a plant transfer line that crosses a railroad is subject to Part 195, the entire transfer line comes under the regulations, not just the segment of the line inside the crossing. I hope you find this information useful. You may wish to contact James C. Thomas, Director, Southwest Region if you need any further assistance in meeting the Part 195 regulations (phone: (713) 750-1746).

Sincerely,

Cesar De Leon

Deputy Associate Administrator for

Pipeline Safety

Regulation Sections

Section Subject
195.1 Which pipelines are covered by this Part?