{"operation":"document","citation":"PI-80-0101","title":"Pipeline Safety Interpretation PI-80-0101","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1980-05-22","effective_on":null,"summary":"PI-80-0101 concerning 192.327.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0101.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0101.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-80-0101","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1980/g80-05-02_Myrick_192.327-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-80-0101\nMay 22, 1980\nMr. John E. Myrick\nManager, Technical Services\nNorthwest Alaskan Pipeline Company\nFluor Engineering and Constructors, Inc.\n3333 Michelson Drive\nIrvine, California 92730\nDear Mr. Myrick:\nOne of the proposed construction modes for the Alaska portion of the Alaska Natural Gas Transportation System to be\nused north of the Brooks Range specifies a five feet deep trench. Although a berm would be constructed over the\npipeline to provide protection, the cover from the top of the pipe to the natural ground level would only be one foot.\nI discussed with you on May 8, 1980 in Hanover, New Hampshire the possibility that this mode of construction might\nnot comply with the cover requirements of the Minimum Federal Safety Standards for gas pipelines contained in 49\nCFR 192.327(a). A minimum cover of 30 inches in normal soil or 18 inches in consolidated rock is required in a class 1\nlocation. It is not stated in the regulation from what point the cover is measured in order to assure compliance.\nHowever, there is some guidance given from past interpretations. One such interpretation dated December 3, 1976\nstates in part: “Section 192.327 of the regulations prescribes minimum cover for transmission lines and mains\nmeasured at the time of construction from the ground surface or the bottom of a drainage ditch, as applicable.” The\nterm \"ground surface\" would indicate that the cover would be measured from the natural ground level before ditch\nexcavation.\nI would suggest that you request an interpretation of the regulation to eliminate any possibility of conflict with the\ncover requirement. Please forward any such request to my office and I will expedite a response to the request within\nthe Materials Transportation Bureau.\nSincerely,\nOriginal Sign By\nLloyd W. Ulrich\nActing Associate Director for\nAlaska Pipeline\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nNorthwest Alaskan Pipeline Company\n1801 K Street, N. W.\nWashington, D.C. 20006\nAugust 28, 1980\nMr. Lloyd W. Ulrich\nActing Associate Director, Alaska Pipeline\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D.C. 20590\nRe: Interpretation of 49 CFR 192.327(a)\nDear Mr. Ulrich:\nSection 192.327(a) of the Code of Federal Regulations, Part 49 specifies the minimum cover required for the\ninstallation of transmission lines. However, the point from where the depth of cover should be measured is not\nspecified. On the 48\" natural gas pipeline to be constructed in Alaska as part of the Alaska Natural Gas Transportation\nSystem, an interpretation might, therefore, be required in every case where the mode of pipeline burial differed from\nthe normal buried mode.\nWe have been interpreting Section 192.327 to mean the following:\nThe word \"cover\" shall mean \"the minimum depth or thickness of backfill around the pipe measured from any point\non the circumference of the pipe.\"\nWe understand that where the Code is not explicit in dealing with a special case, an interpretation from the Office of\nPipeline Safety Operations will provide the necessary authority, unless there is a significant departure from the code.\nTherefore, an official interpretation is requested of the word \"cover,\" perhaps a determination that our interpretation\nis acceptable.\nYours truly,\nNorthwest Alaskan Pipeline Company\nEdwin (Al) Kuhn\nDirector\nGovernmental Affairs\n\n<<<PAGE 3>>>\n\nUnited State Government\nDepartment of Transporation\nResearch and Special Programs Administration\nMEMORANDUM\nDate: September 5, 1980\nSubject: Request for Interpretation of 49 CFR Part 192\nFrom: Acting Associate Director for Alaska Pipeline, DMT-50\nTo: Acting Associate Director for Pipeline Safety Regulation, DMT-30\nAttached is a request from Al Kuhn of Northwest Alaskan Pipeline Company for an interpretation of 49 CFR 192.327(a)\nconcerning depth of cover and specifically the point from where the depth of cover should be measured.\nI would appreciate your Office processing Mr. Kuhn's request and provide me with an interpretation so that I can\nrespond to his letter.","truncated":false,"body_characters":4050}