Associated Safety Consultants, Inc. — Pipeline Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Ave, S.E. Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration DEC 2 0 2012 Mr. Michael J. Frenzel Associated Safety Consultants, Inc. 8315 Kelwood A venue Suite B Baton Rouge, LA 70806 Dear Mr. Frenzel: In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated August 9, 2012, the Associated Safety Consultants (ASC), Inc., requested an interpretation ofthe applicability of the Federal pipeline safety regulations at 49 CFR 192.317(b) to an aboveground gas transmission line or main. Specifically, ASC asks PHMSA's interpretation of how a 'safe distance' is defined or determined, and what would constitute an effective barricade? Section 192. 317(b) reads as follows: (b) Each aboveground transmission line or main, not located offshore or in inland navigable water areas, must be protected from accidental damage by vehicular traffic or other similar causes, either by being placed at a safe distance from the traffic or by installing barricades. PHMSA has not adopted general criteria to judge the safety of distances and effective barricades separating aboveground gas pipeline facilities from vehicular traffic. Therefore, a safe distance and effective barricade would be whatever a reasonable and prudent pipeline operator would conclude is safe under the site specific circumstances, considering relevant factors such as the speed limit, the direction of traffic, the terrain, and any natural barriers. I hope that this information is helpful to you. If I can be of further assistance, please contact me at 202-366-4046. Director, Office of Standards and Rulemaking The Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the public understand how to comply with the regulations.#

Page 2/>[-/1--cc~ Y ASSOCIATED SAFETY CONSULTANTS, INC. Providing Safety Program Management Services to Business and Industry 8315 Kelwood Avenue, Suite B, Baton Rouge, Louisiana 70806 Phone (225) 926-0560, Fax (225) 926-1509 August 9, 2012 Office of Pipeline Safety (PHP-30) PHMSA US Department of Transportation 1200 New Jersey Avenue, SE Washington DC 20590-0001 'AUG 1'1 ln,1 RE: Interpretation of 49CFR 192.317(b) Dear Sir: 49CFR 192.317(b) reads in part that 'Each above ground transmission line or main ... must be protected from accidental damage by vehicular traffic or other similar causes, either by being placed at a safe distance from the traffic or by installing barricades.' My questions are: Assuming a safe distance means from a highway or roadway, how is a 'safe distance' defined or determined, and by whom? What would constitute an effective barricade? If my questions are not clear, please call. Otherwise, I eagerly await your response. Sincerely, ASSOCIATED SAFETY CONSULTANTS, INC. r--- MICHAEL J. FR 'CSP#