{"operation":"document","citation":"PI-82-014","title":"Williams Brothers Engineering Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1982-07-30","effective_on":null,"summary":"PI-82-014 response to Williams Brothers Engineering Company concerning 192.5.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-014.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-014.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-82-014","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1982/PI82014.pdf","body":"<<<PAGE 1>>>\n\nMr. John Suglove\nWilliams Brothers Engineering Company\nSuite 300 W\n50 Briar Hollow Lane\nHouston, TX 77027\nDear Mr. Suglove:\nI apologize for length delay in answering your letter concerning applications of the class location\ndefinitions contained in 49 CFR §192.5.\nYour application of paragraph (f) of §192.5, to restrict the boundaries of Class 2 and Class 3\nlocations created by a cluster of buildings in otherwise Class 1 situations such as you portray in\nyour drawing is not correct. Because the two clusters portrayed are within a continuous 1-mile\nlength of pipeline, they affect one another and in the example you give would cause the class\nlocation to be Class 3 to a point of 220 yards beyond the extremities of the two \"combined\"\nclusters. The enclosed highlighted excerpts from Notice 70-4 proposing the regulation and the\npreamble to the original 49 CFR part 192 (FB 35, 13251) should clarify the meaning of the\nregulation regarding clusters of buildings.\nAn interpretation of §192.5(e) and (f) regarding encroachment of a single 4-story building is\nenclosed.\nSincerely,\n/signed/\nMelvin A. Judah\nActing Associate Director\nfor Pipeline Safety Regulation\nMaterials Transportation Bureau\nEnclosures\nNOTE: ATTACHED ARTICLE\nNo. 82-7\nDB\nC:\\WP51\\INTERPRE\\192\\5\\73-09-05\n1\n\n<<<PAGE 2>>>\n\nDate: July 30, 1982\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nMATERIALS TRANSPORTATION BUREAU\n_____________________________________________________________________________\nPIPELINE SAFETY REGULATORY INTERPRETATION\n_____________________________________________________________________________\nNOTE:A pipeline safety regulatory interpretation applies a particular rule to a particular\nset of facts and circumstances, and, as such, may be relied upon only by\nthose persons to whom the interpretation is specifically addressed.\nSECTION: 192.5(e) and (f)\nSUBJECT: Class locations.\nFACTS: Paragraph (e) refers to buildings with four or more stories in a plural sense.\nParagraph (f)(1) refers to building in a singular sense.\nQUESTION: Does encroachment by a single building of four or more stories require upgrading\nto a Class 4 location?\nINTERPRETATION: Having a single four or more story building within 220 yards of a gas\npipeline does not require upgrading to Class 4 requirements because\nparagraph (e) states in part: \"where buildings with four or more stories\nabove ground are prevalent.\" The use of \"prevalent\" indicates that they are\ncommon or that there are more than one such building in the area.\nTherefore, a single four or more story building would not cause an area to\nbe designated a Class 4 location.\nSubparagraph (f)(1) uses \"building\" in the singular because it is\nreferring to the nearest building in group or cluster to which the\nboundary adjustment of 220 yards applies in relation to other\ndwelling units.\nMelvin A. Judah\nActing Associate Director\nDB\nC:\\WP51\\INTERPRE\\192\\5\\73-09-05\n2\n\n<<<PAGE 3>>>\n\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDB\nC:\\WP51\\INTERPRE\\192\\5\\73-09-05\n3\n\n<<<PAGE 4>>>\n\nNovember 6, 1980\nMr. Melvin A. Judah\nActing Associate Director of\nPipeline Safety Regulation\nMaterials Transportation Bureau\nDepartment of Transportation\nWashington, D. C. 20590\nDear Sir:\nThis is in regard to requirements of Section 192.5 of the Code of Federal Regulations, Title 49,\nPart 192, Subpart A. My specific question regards the intent of Paragraph (f) when applying the\nprovisions for adjustments to requirements of the preceding paragraphs as permitted by\nSubparagraphs (2) and (3).\nThe attached sheet contains two examples, which represent ny understanding of the application of\nadjustments permitted by Paragraph (f), Subparagraphs (2) and (3). This understanding is based\non the premise that when the Class Location requirement for a cluster of buildings is satisfied,\nthese dwellings are then not included in the count of dwellings for the continuous 1-mile class\nlocation criteria in the circumstances described by these examples. Stated in a different manner, it\nis assumed that the intent of Paragraph (f) is to offer relief from class location requirements of the\npreceding paragraphs employing the continuous 1-mile criteria; which, in the case of the two\nexamples, would require extending the length of the higher class location unit due to the influence\nof the cluster of dwellings.\nIn the examples, the pipeline is onshore, the buildings are all single dwellings intended for human\noccupancy, and Paragraphs 192.5(e), 192.5(d)(2)(i) and 192.5(d)(2)(ii) do not apply.\nWhile reviewing Section 192.5 it was noted that Paragraph (e) refers buildings with four or more\nstories in a plural sense, while Paragraph (f) Subparagraph (1) refers building in a singular sense.\nThis raised the question whether encroachment by a single building of four or more stories would\nrequire up-grading to a Class 4 location. This is a separate general question and not related to the\nspecific questions pertaining to the examples.\nDB\nC:\\WP51\\INTERPRE\\192\\5\\73-09-05\n4\n\n<<<PAGE 5>>>\n\nAny comments or guidelines you can give relative to these specific questions and the general\nintent of Paragraph (f) would be appreciated.\nVery truly yours,\nWilliams Brothers Engineering Company\nJohn Suglove, Project/Manager\nNOTE: DIAGRAM ATTACHED\nDB\nC:\\WP51\\INTERPRE\\192\\5\\73-09-05\n5","truncated":false,"body_characters":5334}