Eastern Shore Natural Gas Company — Pipeline Safety Interpretation

Page 1PI-75-0103 Mr. Howard E. Boller General Superintendent Eastern Shore Natural Gas Company P.O. Box 615 Dover, Delaware 19901 Dear Mr. Boller: This responds to your letter of April 18, 1975, regarding construction of a public road over an existing gas pipeline. You ask what criteria should be used in determining whether the pipeline should remain in place or be relocated. The Federal gas pipeline safety standards in 49 CFR Part 192 (copy enclosed) for the design, installation, and testing of pipelines would not apply to the existing pipeline unless it is replace, relocated, or otherwise changed as a result of constructing the road. Standards for operation and maintenance of the pipeline in 49 CFR 192.613 and 192.703(b) would require, however, that the pipeline be evaluated for safety purposes as a result of the road construction and appropriate remedial action taken, if necessary, in accord with those sections. The Federal safety standards would not require that the pipeline be relocated as a result of the road construction. In determining what other protective measures may be necessary, you should consider the types and magnitudes of all anticipated road construction. Various causes of external forces which you should consider include: unstable soils, floods, movement by heavy construction or maintenance equipment, and direct damage by construction equipment. We trust this satisfactorily answers your inquiry. Sincerely, Joseph C. Caldwell Director Office of Pipeline Safety#

Page 2EASTERN SHORE NATURAL GAS COMPANY P. O. BOX 615 DOVER, DELAWARE 19901 April 18, 1975 Mr. Joseph Caldwell, Director Office of Pipeline Safety Department of Transportation Washington, D. C. 20590 Dear Mr. Caldwell: We have a section of pipeline which lies in a Class 3 location and operates at between 30 and 39% SMYS. This pipeline is within the confines of the state highway right of way. We have received plans from the State Highway Department indicating they are going to widen and change the location of this road with the result that our pipeline will be under the new roadbed. What criteria must we use in determining whether the pipeline can remain under the new roadbed or it must be relocated? Sincerely yours, EASTERN SHORE NATURAL GAS COMPANY Howard E. Boller General Superintendent#