Road crossings and parallel encroachment

The pipeline safety regulations in Part 192 do not require casings when crossing a road or railroad right-of-way.  This is often a requirement of the road department or railroad and if a casing must be installed operators must follow the requirements in §192.323.

However the regulations do recognize that pipe under or near a road or railroad may be subject to some additional stress.  This is found in §192.111(b)(1), (2), and (3).  Of course this is for the initial design and construction of the pipeline.

But what happens when a roadway is rerouted and the pipeline must be moved or replaced and is still within the right-of-way?  The following interpretation from 1975 provides some insight.

Interpretation 192.111  10
May 30, 1975

Mr. J. H. Glamser
Vice President
Oklahoma Natural Gas Company
P.O. Box 871
Tulsa, Oklahoma  74102

Dear Mr. Glamser:

This responds to your letter of April 23, 1975, asking whether in rebuilding a pipeline under the right-of-way of a public highway in a Class 1 location, a design factor of 0.50 or 0.60 should be used in the design formula in 49 CFR 192.105 for steel pipe.

Where steel pipe in a Class 1 location, crosses without a casing, or makes a parallel encroachment on a highway right-of-way, Section 192.111(b)(2) requires that a design factor of 0.60 or less by used.

In rebuilding the pipeline, the use of a design factor of 0.60 would satisfy Section 192.111(b)(2).  The term “or less” in Section 192.111(b) should not be construed as requiring that a lower design factor, e.g., 0.50, be used in certain circumstances.  Rather, the term “or less” permits the pipe at the operator’s discretion, to be designed for greater strength than that provided by a design factor of 0.60.

We trust this satisfactorily answers your inquiry.


Joseph C. Caldwell
Office of Pipeline Safety

Oklahoma Natural Gas Company
Post Office Box 871
Tulsa, Oklahoma 74102

April 23, 1975

Mr. Joe Caldwell
Director of Pipeline Safety
Department of Transportation
Washington, DC 20590

Dear Mr. Caldwell:

Oklahoma Natural Gas Company (ONG) owns and operates a 22-inch natural gas pipeline designated as R-900 on private right-of-way in Section 34, T13N, R17E, Muskogee County, Oklahoma. The Oklahoma State Highway Department proposes to relocate U.S. Highway 69 across ONG’s pipeline, thus changing a portion of the pipeline from private to public right-of-way. The general area in question is a Class 1 location under Department of Transportation Gas Pipeline Safety Regulations, Par. 192.5.

Oklahoma Natural proposes to rebuild this pipeline to a .60 design factor, within the new highway right-of-way, under Par. 192.111(b) (2). The Oklahoma City Office of the Federal Highway Administration maintains that this section of pipeline be built to .50 design factor. They also use the Department of Transportation Gas Pipeline Safety Regulations as their standard.
The interpretation ONG is asking for is as follows: Does the above-mentioned section of pipeline need to be built to a .50 or a .60 design factor?

Yours truly,

J.H. Glamser

All this and more in WinDOT, The Pipeline Safety Encyclopedia.


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