{"operation":"document","citation":"PI-98-006","title":"Shell Oil Products Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-11-18","effective_on":null,"summary":"PI-98-006 response to Shell Oil Products Company concerning 195.2.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1998/PI98006.pdf","body":"<<<PAGE 1>>>\n\nNovember 18, 1998\nMs. Gweneyette Broussard\nShell Oil Products Company\nPO Box 2463\nHouston TX 77252\nDear Ms. Broussard:\nThis responds to your inquiry on our interpretation of the term, \"in-plant piping system,\" as defined in 49 CFR 195.2. asked us to expand the interpretation to include in-plant transfer piping that crosses railroad mainlines.\nYou\nThe request arises because some refinery or petrochemical plants are separated by a railroad mainline over which trains\ntravel at a reduced speed through the plant. A typical plant is said to have 30-50 transfer lines up to 16 inches in diameter\nthat cross a railroad. The crossings may be up to 500 feet long, with a 6 to 10-foot clearance between overhead crossings\nand trains. As with other in-plant piping, the railroad crossings are designed and inspected in accordance with ANSI B31.3\nstandards for chemical plants and refineries and are subject to the Process Safety Management regulations of the\nOccupational Safety and Health Administration (29 CFR 1910.119).\nThe safety standards in 49 CFR Part 195 do not apply to transportation through onshore production, refining, or\nmanufacturing facilities, or storage or in-plant piping systems associated with such facilities (§195.1(b)(6)). To clarify the\nlimits of Part 195 for in-plant piping systems, we defined the term and stated that it includes pipeline crossings of single\npublic thoroughfares that divide plants (59 FR 33389; June 28, 1994). We further explained that by thoroughfare we meant\na road but not a railroad. Although we considered road crossings to be comparable in most respects to other in-plant\npiping, we were apprehensive about the risk of train-related accidents at railroad crossings.\nYour request has caused us to reconsider whether railroad crossings fall under the in-plant piping exception from Part 195.\nThe information you provided about design, maintenance, and regulation demonstrates that in-plant railroad crossings are\nsubject to the same safety standards as other in-plant piping. And our increased familiarity with in-plant railroad crossings\nconfirms that the risk of train-related accidents does not jus6tify distinguishing these crossings from road crossings. It\nfollows that, like road crossings, in-plant railroad crossings are comparable in most respects to other in-plant piping.\nTherefore, we will consider the thoroughfare interpretation of in-plant piping system to include in-plant railroad crossings.\nSincerely,\nRichard B. Felder\nAssociate Administrator for Pipeline Safety\nPage 1 of 1","truncated":false,"body_characters":2553}