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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-95-004 ([D. R. Linger])

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: D. R. Linger

Location State: MA Country: US

View the Interpretation Document

Response text:

January 30, 1995

Mr. D. R. Linger

Vice President, Operations

1284 Soldiers Field Road

Boston, MA 02135

Dear Mr. Linger:

This responds to your letter of June 30, 1994, to Mr. Donald Moore of our Central Region office, regarding his interpretation of 49 CFR § 192.5 (Class locations.) made in the course of the recent New Jersey Audit. Mr. Moore's establishment of the class change end points for a cluster of houses is inconsistent with your understanding of the requirements for clusters in § 192.5(f).

Your position appears to be based on a misinterpretation of "ends 220 yards from the nearest building" as that phrase is used in paragraphs (f)(1) - (f)(3). These paragraphs use "building" in the singular because they refer to the nearest building in the group or cluster to which the boundary adjustment of 220 yards applies in relation to the other buildings intended for human occupancy. As such, the two boundary adjustments are measured along the centerline of the pipeline, beginning at points which are the perpendicular projection of the extremities of the furthermost upstream building and furthermost downstream building.

Accordingly, your agreement to extend the two designated pipeline segments, to conform with Don Moore"s interpretation, will put them in compliance with § 192.5

We trust that this responds to your request for a resolution of the interpretation issue by this office.


Cesar De Leon

Deputy Associate Administrator for

Pipeline Safety

Regulation Sections

Section Subject
192.5 Class locations