{"operation":"document","citation":"PI-94-035","title":"Conoco Pipe Line Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1994-10-24","effective_on":null,"summary":"PI-94-035 response to Conoco Pipe Line Company concerning 195.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-035.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-035.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-94-035","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1994/PI94035.pdf","body":"<<<PAGE 1>>>\n\nOctober 24, 1994\nDwight D. Jackson\nManager, Pipeline Services and Regulatory Compliance\nConoco Pipe Line Company\nHouston, Texas 77252\nDear Mr. Jackson:\nYour letter of August 19, 1994, requests further clarification of the “ single public thoroughfare”\ninterpretation discussed in the preamble of the low-stress pipeline Final Rule (59 FR 35465; July\n12, 1994). The interpretation concerned plants that are divided into separate parts by a single\npublic thoroughfare. It provides that a plant transfer line that crosses the thoroughfare may\nqualify for the in-plant piping exception under § 195.1(b)(6).\nYou asked if a single public thoroughfare includes a railroad. As stated in the preamble, the\nthoroughfare interpretation applies only to transfer piping that crosses a road. It does not apply\nto piping that crosses a railroad, whether a mainline or spur. Railroads were excluded because of\nthe added risk that railroads pose to pipeline safety.\nThe thoroughfare interpretation does not mean that every plant transfer line that crosses a railroad\ncomes under the regulations in 49 CFR Part 195. If a plant transfer line does not come under the\nin-plant piping exception because it crosses a railroad that divides a plant, it may still be excepted\nunder another provision of § 195.1(b). For example, certain low-stress pipelines are excepted\nunder § 195.1(b)(3). If a plant transfer line that crosses a railroad is subject to Part 195, the entire\ntransfer line comes under the regulations, not just the segment of the line inside the crossing.\nI hope you find this information useful. You may wish to contact James C. Thomas, Director,\nSouthwest Region if you need any further assistance in meeting the Part 195 regulations (phone:\n(713) 750-1746).\nSincerely,\nCesar De Leon\nDeputy Associate Administrator for\nPipeline Safety\ndal/195.1\n94-10-24","truncated":false,"body_characters":1859}