Virginia State Corporation Commission — Pipeline Safety Interpretation

Page 1September 9, 1992 Mr. Massoud Tahamtani Utilities Manager Division of Energy Regulation Virginia State Corporation Commission Post Office Box 1197 Richmond, Virginia 23209 Dear Mr. Tahamtani: Your letter of August 3, 1992, transmits an order by the Virginia State Corporation Commission (Virginia) granting Virginia Natural Gas, Inc. (VNG) a waiver of 49 CFR 192.327(a) for a particular pipeline. Section 192.327(a) requires each buried transmission line installed in normal soil to have a minimum cover of 36 inches when located in drainage ditches of public roads. In constructing the pipeline, VNG bored a distance of 554-feet under interstate highway I-295. When the bore emerged on the side of the right-of-way, it had risen to a point 16 inches below existing grade, which is less than the 36-inch depth required by §192.327(a). The petition requested a waiver for an 87-foot section of pipe located beyond the toe of the bank of the highway. Virginia has inspected the site and observed that VNG has installed pipeline warning markers and warning tape showing the location of the pipeline for the section of pipeline requiring waiver. Based on the information provided in the application for waiver and since the section of pipeline requiring waiver is located on the outer fringes of the Chickahominy River swamp wetlands, we believe granting a waiver from §192.327(a) for the circumstances described would not be inconsistent with pipeline safety. For this reason, we offer no objection to approval of the waiver. Sincerely, Cesar De Leon Director, Regulatory Programs Office of Pipeline Safety dal\192\327\92-09-09#