{"operation":"document","citation":"PI-73-0105","title":"Associated Engineering Consultants Incorporated — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1975-03-15","effective_on":null,"summary":"PI-73-0105 response to Associated Engineering Consultants Incorporated concerning 195.200.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-73-0105","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1973/g73-03-15_Griggs_195.200-DBx.pdf","body":"<<<PAGE 1>>>\n\nPI-73-0105\nMarch 15, 1973\nMr. Guy W. Griggs, P.E.\nVice President, Associated Engineering Consultants Incorporated\n2828 Bammel, Suite No. 107\nHouston, Texas 77006\nDear Mr. Griggs:\nYour letter of February 23, 1973, addressed to our Houston office has been referred to this office for reply. In\nthat letter you described a situation in which an area traversed by an existing crude oil pipeline is being\ndeveloped as a subdivision. At three points within the subdivision where the pipeline crosses proposed\nstreets, the pipeline will be lowered, cased, and vented. You ask whether, because of the changes to the\npipeline at the street crossings, it is required that the entire existing pipeline within the subdivision be brought\ninto conformity with the new construction requirements of Subpart D of Part 195.\nAs stated in §195.200, Subpart D prescribes requirements for constructing new pipeline systems with steel\npipe and for relocating, replacing, or otherwise changing existing pipeline systems that are constructed with\nsteel pipe.\nThe phrase “relocating, replacing, or otherwise changing existing pipeline systems,” within the meaning of\n§195.200, has reference to relocation of, replacement of, or other changes to any segment of an existing\npipeline system. The regulation does not mean that relocation, replacement, or other change affecting one\nsegment of a pipeline requires upgrading a carrier’s entire system to current new construction standards.\nFurthermore, in your situation, there appears to be no basis for defining a pipeline system as that contained\nwithin the boundaries of one particular subdivision.\nWith respect to the segments of the pipeline being changed as they go under the proposed streets, such\nsegments are required to meet the requirements of Subpart D to the extent applicable.\nBased on the situation as you have described it, there is no Federal requirement that the entire existing\npipeline within the boundaries of a subdivision be upgraded to the construction requirements of Subpart D\nbecause three segments of that pipeline are changed or because a housing development is being built in the\nvicinity.\nI trust this answers your inquiries. If you have further questions in this regard, please call on us.\nSincerely,\nOriginal signed by:\nJoseph C. Caldwell\nDirector\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nAssociated Engineering\nConsultants Incorporated\n2828 Hammel, Suite No. 107\nHouston, Texas 77006\nFebruary 23, 1973\nDepartment of Transportation\n201 Fannin, Room 315\nHouston, Texas 77002\nAttention: Mr. Delafuente, P. E.\nRe: Audubon Park Subdivision - Harris County, Texas\nNew Concrete Street Crossings of Existing Pipeline\nDear Sir:\nI would like to confirm my phone conversation of 2/22/73 regarding the captioned project. You said that\naccording to the rules and regulations by the Department of Transportation Hazardous Materials Regulations\nBoard that the rules indicated under Title 49 Transportation refer to new pipeline construction.\nIn our situation, where we have an existing crude oil pipeline operating at approximately 200 psi with\napproximately 20 feet of cover, you stated this line will not be required to follow the rules for new pipeline\nconstruction if it is lowered and cased at street crossings only. This type of work is not considered alteration or\nmodification that would cause the entire pipeline through the subdivision to have to conform to the rules for\nnew pipeline construction. This type of work is just considered as \"lowering\".\nAlso, as we discussed there will be no dwellings or other buildings within 50 feet of the pipeline at any point\nwithin the subdivision. We would greatly appreciate your prompt attention in helping us get written\nconfirmation of this matter due to the fact that our contracts have already been let for construction of utilities\nand streets and we would like to have this matter resolved and the work done well ahead of their schedule.\nIf we can be of any further help, or if you need additional information on this, please do not hesitate to call\nme.\nVery truly yours,\nGuy W. Griggs , P. E.\nVice President","truncated":false,"body_characters":4117}