{"operation":"document","citation":"PI-95-0102","title":"McDowell Owens Engineering, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1995-10-09","effective_on":null,"summary":"PI-95-0102 response to McDowell Owens Engineering, Inc. concerning 192.317.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-0102.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-0102.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-95-0102","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1995/g95_10_09_Gamse_192.317_nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-95-0102\nU.S. Department 400 Seventh Street, SW\nof Transportation Washington, DC 20590\nResearch and\nSpecial Programs\nAdministration\nOctober 9, 1995\nMr. Beryl Gamse\nConsulting Engineer\nMcDowell Owens Engineering, Inc.\nSuite 100\n1075 Kingwood Drive\nKingwood, TX 77339\nDear Mr. Gamse:\nI am responding to your letter of September 1, 1995, concerning application of the gas pipeline safety regulation\nin 49 CFR 192.317(b) to a liquid petroleum gas transmission line in a rural area. You asked what criteria can be\nused to determine if the pipeline is a “safe distance from the traffic” under §192.317(b).\nI must first point out that pipelines carrying liquid petroleum gas in a liquid state are not subject to the\nregulations in 49 CFR Part 192. These regulations apply only to the pipeline transportation of certain hazardous\nmaterials in a gaseous state. Pipelines carrying liquid petroleum gas in a liquid state are subject to the safety\nregulations in 49 CFR Part 195.\nAs to §192.317(b), we have not adopted criteria to judge the safety of distances separating aboveground gas\npipeline facilities from vehicular traffic. So a safe distance would be whatever a reasonable and prudent\npipeline operator would conclude is safe under the circumstances, considering relevant factors such as the speed\nlimit, the direction of traffic, the terrain, and any natural barriers.\nSincerely,\nRichard D. Huriaux, P.E.\nDirector for Technology and Regulation\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nMcDowell Owens\nTexas commerce Bank Building\nSuite 100\n1075 Kingwood Drive\nKingwood, Texas 77339\nSeptember 1, 1995\nOffice of Pipeline Safety\nDepartment of Transportation\nDPS-1\n400 Seventh Street, S.W.\nRoom 2335\nWashington, D.C. 20590\nRE: Our File No: 952631\nDear Associate Administrator:\nI have reviewed CFR49 192.317(b) which is concerned with the protection of pipelines from damage by vehicular traffic.\nThe paragraph reads:\n\"Each aboveground transmission line or main, not located offshore or in inland navigable water areas, must be\nprotected from accidental damage by vehicular traffic or other similar causes, either by being placed at a safe\ndistance from the traffic or by installing barricades.\"\nI would like to get guidance on the definition of the term safe distance from the traffic. In the field of highway design,\nthe generally accepted requirement for a \"clear zone\" is that any fixed object more than 30 feet from the edge of the\ntravel way, on relatively flat ground, does not have to be protected from errant highway vehicles by guard rails or other\nsuch barricades. The authority for the highway design clear-zone criteria is the American Association of State Highway\nand Transportation Officials (AASHTO).\nWhat, if any other authorities and factors should be taken into consideration in defining the safe distance from the\ntraffic required by par. 192.317? The situation of particular interest is a liquid petroleum gas (LPG) transmission line in a\nrural setting.\nThank you very much for your help.\nSincerely,\nMcDOWELL OWENS ENGINEERING, INC.\nBeryl Gamse, Ph.D., P.E.\nConsulting Engineer","truncated":false,"body_characters":3106}