# Natural Resources Engineering Company — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-04-0106
- **title:** Natural Resources Engineering Company — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2004-04-20
- **effective on:** Not available
- **summary:** PI-04-0106 response to Natural Resources Engineering Company concerning 192.5.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2004/g04-04-20_Peterson_192.5-lmx.pdf
**body:**

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PI-04-0106
U.S. Department of Transportation
Research and Special Programs Administration
400 Seventh Street, S.W.
Washington, D.C. 20590
April 20, 2004
Mr. Joseph Peterson
GIS Specialist
Natural Resources Engineering Company
69 North 28th Street, Suite 27
Superior, WI 54880
Dear Mr. Peterson:
This is in response to your e-mail of March 29, 2004, in which you request an interpretation of the provisions
of the Federal gas pipeline safety regulations at 49 CFR 192.5, Class locations, as it relates to the concept of clusters.
The original edition of the gas pipeline safety regulations at 49 CFR Part 192 (35 FR 13251; August 19, 1970)
sought to address the problem that the class location scheme could create a two-mile stretch of higher class location
solely to protect a small cluster of buildings at a crossroads or road crossing. To avoid this situation a new paragraph was
added to allow adjustment of class location unit boundaries to address isolated clusters of buildings intended for human
occupancy.
In the regulations the term, "cluster," is used in its ordinary dictionary sense, and has not been a significant
source of misunderstanding. The dictionary meaning is: a number of similar things together, a bunch, a group.
The history of § 192.5 shows that the cluster exception applies only when all buildings in a one-mile class
location unit are in a single cluster. If a class location unit contains buildings outside a cluster or more than one
cluster of buildings, all buildings in the unit must be counted to determine the class location of the unit.
If you have any further questions about the pipeline safety regulations, please contact
Sincerely,
Richard D. Huriaux, P.E.
Manager, Regulations
Office of Pipeline Safety
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