Columbia Gas — Pipeline Safety Interpretation

Page 19-27-95 Dr. Donald K. Gartman, Ph.D. Environmental Affairs Columbia Gas 20 Montchanin Road P.O. Box 4020 Wilmington, DE 19807-0020 Dear Dr. Gartman: This is in response to your question to L.E. Herrick at the September 7-8, 1995, INGAA Foundation Stream and River Crossing Roundtable in Orlando, FL. Your question concerned allowing a trail system on a natural gas pipeline right-of-way. Section 192.5(d)(2)(ii) of 49 CFR states "A Class 3 location is an area where the pipeline lies within 100 yards of either a building or a small, well-defined outside area (such as a playground, recreation area, outdoor theater, or other place of public assembly) that is occupied by 20 or more persons on at least five days a week for 10 weeks in any 12-month period. (The days and weeks need not be consecutive.)" Although a trail system bears some resemblance to a "small, well-defined outside area that is occupied by 20 or more people," it differs in a number of significant aspects. In particular, it appears that a trail used by hikers, bicycles, horses, cross country skiers, etc., would not be occupied by 20 or more people in a small and well-defined area at the same time. Furthermore, such a trail system would not be basically similar to a playground, recreation area, outdoor theater, or other place of public assembly. Therefore, the trail system would not require a change in class location. We trust that this has answered your particular question. If we can be of further assistance, please let us know. Sincerely, Cesar De Leon Office of Pipeline Safety Deputy Associate Administrator#

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