{"operation":"document","citation":"PI-01-0115","title":"Alliance Pipeline Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-09-05","effective_on":null,"summary":"PI-01-0115 response to Alliance Pipeline Inc. concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0115.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0115.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0115","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/g01-09-05_Gulstad_192.625-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-01-0115\nU.S. Department of Transportation\nResearch and Special Programs Administration\nSeptember 5, 2001\nMr. Rick Gulstad\nCompliance Engineer\nAlliance Pipeline Inc.\n6385 Old Shady Oak Road, Suite 150\nEden Prairie, MN 55344\nDear Mr. Gulstad:\nThis is in response to your enclosed letter of May 29, 2001, requesting an interpretation of the pipeline\nodorization requirements in 49 CFR § 192.625.\nYou note that Alliance currently odorizes gas for compressors station uses, but would prefer to use\nonly gas detectors to increase the level of safety at unmanned stations. Gas detectors would allow for round-\nthe-clock monitoring for gas leaks at the stations.\nThe odorization requirements at § 192.625 of the pipeline safety regulations only require odorization\nof gas in a transmission facility in a Class 3 or 4 location. Alliance's compressor stations are all in Class 1 or 2\nlocations. Therefore, odorization of gas at these compressor stations, even for domestic uses, is not required.\nIn addition, it is clear that monitored gas detectors at such locations will provide a higher level of safety.\nIn short, the pipeline safety regulations do not require Alliance to odorize gas in its compressor station\nfacilities, as long as they are not in a Class 3 or 4 areas.\nIf you need further assistance, please call me at (202) 366-4565.\nSincerely yours,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nAlliance Pipeline Inc.\n6385 Old Shady oak Road\nSuite 150\nEden Prairie, MN\n55344\nMay 31, 2001\nMr. Richard D. Huriaux\nRegulations Manager\nOffice of Pipeline Safety\n400 Seventh Street, S.W.\nRoom 7128\nWashington, D.C. 20590-0001\nDear Huriaux:\nAlliance Pipeline L.P. (Alliance) formally requests an interpretation of the requirements for odorization of\nnatural gas under § 192.625. The regulation is unclear whether odorization would be required for the\nintended usage of domestic natural gas at Alliance's compressor station facilities.\nAlliance currently odorizes natural gas from its transmission pipeline for compressor station domestic use but\nwould prefer to use only gas detectors in lieu of odorizing the natural gas. We feel the changes proposed\nwould increase the level of safety at our compressor stations that are designed to operate in an \"un-manned\"\nfashion. The installation of additional gas detectors and associated control systems would allow for 7 days a\nweek and 24 hours per day monitoring of the facility and would initiate an alarm of the facility in the event of\na minor leak whether or not personnel were present.\nOdorized natural gas is currently used within the utility building at Alliance compressor stations for the\nfollowing:\n• Boiler fuel to raise the temperature of glycol that flows through piping to supply heat to the fuel gas\nbuilding, utility building, and main compressor building\n• Boiler fuel to heat glycol which in turn is used to heat fuel gas supplied to the compressor units\n• Auxiliary power unit (APU) fuel\nElectric heat is used to heat the Alliance working quarter’s area. The hot water heater and all cooking\nequipment are electric equipment.\nThe main compressor building and the fuel gas building are self enclosed buildings that are more than 80 feet\naway from the utility building and are not connected in any fashion to the utility building. The utility building,\nworking quarters, and MCC building are all under one roof but are partitioned off by walls.\nIn addition to the gas detectors that are currently located in the compressor building and fuel gas building,\nAlliance proposes to install gas detectors in the utility building that would sound an alarm at a concentration\nof gas in air of 20% of the lower explosive level for natural gas and would start a vent fan. Also, the supply of\nnatural gas to the utility building would be shut off. Once the alarm is sounded, an Alliance personnel \"call\nout” would be required to investigate.\nAlliance believes that the proposed gas detection alarm system in the utility building provides as great or a\ngreater level of safety than odorization of the gas would provide. The gas detection system would not be\ndepending on the ability of human intervention (ie-smell) to recognize the potential of a gas leak.\nSincerely,\nRick Gulstad\nCompliance Engineer","truncated":false,"body_characters":4300}