Conoco Pipe Line Company — Pipeline Safety Interpretation

Page 1October 24, 1994 Dwight D. Jackson Manager, Pipeline Services and Regulatory Compliance Conoco Pipe Line Company Houston, Texas 77252 Dear Mr. Jackson: Your letter of August 19, 1994, requests further clarification of the “ single public thoroughfare” interpretation discussed in the preamble of the low-stress pipeline Final Rule (59 FR 35465; July 12, 1994). The interpretation concerned plants that are divided into separate parts by a single public thoroughfare. It provides that a plant transfer line that crosses the thoroughfare may qualify for the in-plant piping exception under § 195.1(b)(6). You asked if a single public thoroughfare includes a railroad. As stated in the preamble, the thoroughfare interpretation applies only to transfer piping that crosses a road. It does not apply to piping that crosses a railroad, whether a mainline or spur. Railroads were excluded because of the added risk that railroads pose to pipeline safety. The thoroughfare interpretation does not mean that every plant transfer line that crosses a railroad comes under the regulations in 49 CFR Part 195. If a plant transfer line does not come under the in-plant piping exception because it crosses a railroad that divides a plant, it may still be excepted under another provision of § 195.1(b). For example, certain low-stress pipelines are excepted under § 195.1(b)(3). If a plant transfer line that crosses a railroad is subject to Part 195, the entire transfer line comes under the regulations, not just the segment of the line inside the crossing. I hope you find this information useful. You may wish to contact James C. Thomas, Director, Southwest Region if you need any further assistance in meeting the Part 195 regulations (phone: (713) 750-1746). Sincerely, Cesar De Leon Deputy Associate Administrator for Pipeline Safety dal/195.1 94-10-24#