Flordia Gas Company — Pipeline Safety Interpretation

Page 1PI-72-0107 June 1, 1972 Mr. J. E. Hansford Safety Director Flordia Gas Company P.O. Box 44 Winter Park, Flordia 32789 Dear Mr. Hansford: This is in reply to your letter dated May 12, 1972, regarding an interpretation of Section 192.111(b) (2). Your particular question was: Would the creation of a public bicycle path parallel to an existing transmission line designed, constructed, tested, and operated as prescribed for a Class 1 location, require either requalification or reduction of the maximum allowable operating pressure in that transmission line based on the Office of Pipeline Safety's regulations contained in Title (49), CFR Part 192. Although a bicycle path bears some resemblance to a public highway, it differs in at number of significant aspects. Therefore, the creation of a bicycle path as you have described would not require either requalification or reduction of the maximum allowable operating pressure. We trust that this has answered your particular question. If we can be of further assistance, please let us know. Sincerely, Original signed by: Joseph C. Caldwell Director Office of Pipeline Safety#

Page 2Florida Gas Company General Offices Orlando and Orange Avenues P.O. Box 44 Winter Park, Florida 32789 May 12, 1972 Mr. Joseph C. Caldwell, Director Office of Pipeline Safety Department of Transportation Washington, D. C. 20590 Dear Mr. Caldwell: Florida Gas Transmission Company operates gas transmission pipelines in Central Florida. We have been approached by a local group, represented by the Orange County Commission, whose efforts are directed toward creating bicycle paths in the Central Florida area. Their current plans include the utilization of portions of our pipeline right of way in Class 1 areas. The bicycle paths would consist of an 8-foot wide improved path parallel to and along the edge of our pipeline right of way. These paths would be open to the public but motorized vehicles would not be allowed. These paths would probably be located within the cleared right of way about 20 feet from our pipeline. This proposal is under consideration by our management and one question which has arisen concerns Section 192.111(b)(2) of the Office of Pipeline Safety's regulations. Our concern is that the creation of bicycle paths parallel to our transmission line might be considered to be a "... hard surface road, a highway, a public street ..." which would change the design factor from .72 to .60 and might require revisions to our existing operating procedures. We therefore request an interpretation on the following question: "Would the creation of a public bicycle path parallel to an existing transmission line designed, constructed, tested and operated as prescribed for a Class 1 location, require either requalification or reduction of the maximum allowable operating pressure in that transmission line based on the Office of Pipeline Safety's regulations contained in Title 29 CFR, Part 192?" Sincerely, J. E. Hansford Safety Director#