{"operation":"document","citation":"PI-07-0101","title":"National Transportation Safety Board — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-02-16","effective_on":null,"summary":"PI-07-0101 response to National Transportation Safety Board concerning 192.612.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-07-0101.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-07-0101.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-07-0101","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2007/g07-02-16_Dyck_192.612-n_5.4.11.pdf","body":"<<<PAGE 1>>>\n\nPI-07-0101\nFebruary 16, 2007\nMr. Rod Dyck\nPipeline Operations Group Chair\nNational Transportation Safety Board\n490 L ‘Enfant Plaza, SW\nWashington, DC 50594-0001\nRe; Gas pipeline incident I West Cote Blanche bay, Louisiana\nDear Mr. Dyck:\nThis letter responds to your request for a determination by the Pipeline and Hazardous\nMaterials safety Administration (PHMSA) of the regulatory status of an 8-inch gas pipeline involved in an\nincident in west Cote Blanche Bay, Louisiana on October 12, 2006. PHMSA has determine that the\npipeline segment involved in the incident is subject to the pipeline safety requirements in 49 C.F.R.\n§192.612 based on the depth of water and because the pipeline’s location places it within an “inlet” of\nthe Gulf of Mexico for purposes of 49 C.F.R. §192.3.\nThe pipeline is an 8-inch gas gathering line operated by Chevron USA, which transports\nprocessed gas to gathering systems. The pipeline was apparently damages when a barge traveling\nabove the pipeline released a spud or stabilizing stake, which penetrated the ground bed and punctured\nthe pipeline, causing an explosion. The line had approximately 24 to 48 inches of cover when the\nincident occurred. The water depth at the location is approximately 8 feet.\nSection 60102(a)(2) of title 49, United states Code, authorizes PHMSA to prescribe standards for\ngas pipeline transportation. Gas pipeline transportation includes gathering, transmission and\ndistribution of gas by pipeline, but only includes gathering through “regulated gathering lines.” The\nminimum safety requirements for gas pipeline facilities and the transportation of gas are set forth in 49\nC.F.R. Part 192. Under §192.1, these regulations do not apply to the onshore gathering of gas “through\na pipeline that is not a regulated onshore gathering line (as determined in §192.8)” or “within inlets of\nthe Gulf of Mexico, except for the requirements in §192.612”\nPHMSA defines “regulated onshore gathering line” as a gathering line with particular\ncharacteristics located in a Class 2, 3, or 4 area. While regulated onshore gathering lines must comply\nwith the gas pipeline safety regulations under §192.9, onshore gathering lines in a Class 1 area, such a\nWest Cote Blanche Bay, are not subject to Part 192, except that all onshore gathering line within the\nGulf of Mexico and its inlets are subject to the requirements in §192.612 for reducing the risks\nassociated with vessels hitting underwater pipelines.\nSection 192.612 requires each operator to “identify its pipelines in the Gulf of Mexico and its\ninlets in waters less than 15 feet (4.6 meters) deep as measured from mean low water that are at risk of\nbeing an exposed underwater pipeline or a hazard to navigation.” An operator must also “conduct\nappropriate periodic underwater inspections of its pipelines in the Gulf of Mexico and its inlets in waters\nless than 15 (4.6 meters) deep as measured from mean low water based on the identified risk.” If an\noperator discovers that a line has become exposed or poses a hazard to navigation, the operator must\n\n<<<PAGE 2>>>\n\npromptly notify the National Response Center, mark the location of the pipeline, and within 6 months\nbury the pipeline so that the top of the pie is 36 inches below the natural bottom (18 inches for rock\nexcavation).\nPHMSA defines “the Gulf of Mexico and its inlets” to mean “waters from the mean high water\nmark of the coast of the Gulf of Mexico and its inlets open to the sea (excluding rivers, tidal marshes,\nlakes, and canals) seaward to include the territorial sea and Outer Continental Shelf to a depth of 15 feet\n(4.6 meters), as measured from the mean low water.” (§192.3) Based on its geography, and in\naccordance with this agency’s prior interpretations, we consider West Cote Blanche Bay an “inlet” of the\nGulf of Mexico within the meaning of §192.612. Accordingly, to the extent that the pipeline is located in\nwaters less than 15 feet deep (including at the point of impact), the pipeline involved in the October 12,\n2006 incident is subject to the inspection and reburial requirements in §192.612. However, because the\npipeline does not meet the definition of a regulated onshore gathering line, the pipeline is not subject to\nthe other Part 192 requirements.\nPHMSA intends to review these regulations, in particular the definition of “Gulf of Mexico and\nits inlets” in §192.3, to determine if any changes to the text are necessary to improve clarity and\npromote more consistent application of the regulations for pipelines located in the Gulf area. In the\nmeantime, PHMSA plan to work with the State of Louisiana and our other State partners in the Gulf area\nto ensure the pipelines subject to these regulations meet the specifications for burial depth. PHMSA is\nalso developing additional guidance material for pipeline operators to aid them in complying with these\nimportant safety regulations.\nIf you have any further questions pertaining to this matter, please contact Mr. Joy Kadnar of my\nstaff at (202) 366-4595.\nSincerely,\nJeffrey D. Wiese\nActing Associate Administrator\nFor Pipeline Safety","truncated":false,"body_characters":5106}