# Williams Brothers Engineering Company — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-74-0132
- **title:** Williams Brothers Engineering Company — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1974-08-13
- **effective on:** Not available
- **summary:** PI-74-0132 response to Williams Brothers Engineering Company concerning 192.105.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-74-0132
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1974/g74-08-13_MCCLURE_192.105-nlmx.pdf
**body:**

<<<PAGE 1>>>

PI-74-0132
August 13, 1974
Mr. Clint McClure
Williams Brothers Engineering Company
Resource Sciences Center
Tulsa, OK 64103
Dear Mr. McClure:
This responds to your letter of June 25, 1974, requesting an interpretation of the term "right-of-
way" as it relates to the term "railroad" under §192.111(b)(2).
In this section:
"(b) A design factor of 0.60 or less must be used in the design formula in §192.105 for
steel pipe in Class 1 locations that :
* * *
"(2) Crosses without a casing, or makes a parallel encroachment on, the right-of-way
of either a hard surfaced road, a highway, a public street, or a railroad.
* * *
The term "right-of-way" is not defined in 49 CFR Part 192. Terms which are not defined are
intended to have the ordinary dictionary meaning. The Random House College Dictionary
defines "right-of-way" in relation to a railroad as "the strip of land acquired for use by a railroad
for tracks. " We believe this definition is adequate for understanding §192.111(b)(2).
We trust our reply is helpful to you.
Sincerely,
/signed/ Edward F. Cygan
Joseph C. Caldwell
Director
Office of Pipeline Safety

<<<PAGE 2>>>

June 25, 1974
U. S. Department of Transportation
Office of Pipeline Safety
Washington, D. C. 20590
Attention: Mr. Cesar DeLeon
Subject: Interpretation Sub-Section 192.111 CFR
Gentlemen:
Attached are two (2) copies each of our Sketches SK-1 and SK-2.
Sub-section 192.111(b)(2) deals with design factor when a pipeline crosses or makes a parallel
encroachment on the right-of-way of either a hard-surfaced road, a highway, a public street, or a
railroad.
In our particular case, the railroad company owns various parcels of land traversed by the railway
without definition of the right-of-way within those parcels.
We are unable to find a definition of right-of-way in the regulations. We would like to have your
interpretation of distance "X" in each sketch. As you know, many of these parcels amount to
multiple standard sections of land and would create a hardship on the pipeline operators should a
pipeline have to be designed with a .60 factor when it crossed railroad property that may or may
not be related to a railroad.
Your prompt consideration of this matter is appreciated.
Very truly yours,
WILLIAMS BROTHERS ENGINEERING COMPANY
Clint McClure
Senior Engineer
NOTE: ATTACHMENTS
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