Looper, Reed, Ewing & McGraw Incorporated — Pipeline Safety Interpretation

Page 1Mr. Douglas B. Wyatt Looper, Reed, Ewing & McGraw Incorporated Attorneys Suite 1717 Nine Greenway Plaza Houston, Texas 77046 Dear Mr. Wyatt: you requested clarification of our August 31, 1989, letter regarding protection for offshore pipelines. The requirements of 49 CFR 192.317(a) apply to conditions known or that can be foreseen at the time of construction. Thereafter, an operator does not have a continuing obligation under this rule to provide protection against hazards from changed or new conditions. However, if the operator learns the pipeline has become unsafe due to these changed or new conditions, the operator would have to take remedial action as required by 49 CFR 192.703(b). We would agree that the protection required by §192.317(a) could be any measure considered reasonably necessary to guard against foreseeable damage from a foreseeable event, provided that measure is based on sound engineering judgment. Sincerely, /signed/ James C. Thomas Deputy Director Office of Pipeline Safety DB C:\WP51\INTERPRT\192\317\89-09-27 1#