{"operation":"document","citation":"PI-01-0116","title":"EFI Corporation — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-09-15","effective_on":null,"summary":"PI-01-0116 response to EFI Corporation concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0116.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0116.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0116","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/g01-09-15_Jacobus_192.625-msfx.pdf","body":"<<<PAGE 1>>>\n\nPI-01-0116\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nSeptember 15, 2001\nMr. John Jacobus\nEFI Corporation\n2218 Northpark Drive\nKingwood, TX 77339\nDear Mr. Jacobus:\nSubsequent to our conversation on September 10, 2001, you forwarded an e-mail asking for an\ninterpretation of the exception to the gas transmission line odorization requirements found in the pipeline\nsafety regulations at 49 CFR §192.625(b)(1). This regulation states that a gas transmission line in a Class 3 or\nClass 4 location must be odorized unless \"[a]t least 50 percent of the length of the line downstream from that\nlocation is in a Class 1 or Class 2 location.\" In your example, you note that ten miles of Class 3 or Class 4\ntransmission line would not have to be odorized if it terminated with as little as one mile of transmission line in a\nClass 1 or Class 2 location.\nYour interpretation is correct. If 50 percent of more of the transmission line mileage downstream from a\nClass 3 or Class 4 location is in a Class I or Class 2 location, the gas need not be odorized. This exception to the\nodorization requirements was included to address long distance pipelines that pass through some Class 3 or\nClass 4 locations, but are predominately Class 1 or Class 2 downstream from that location.\nAlthough your example is possible, it should be very rare. There are several reasons for this exception.\nOne is that odorization of gas complicates its use as an industrial feed stock. Another is that odorization of\ntransmission lines is of questionable value compared to odorization of distribution pipelines, which operate at a\nmuch lower pressure and are more likely to experience slow leaks that could only be detected by odor.\nIf we can be of further assistance in this matter, please contact me at (202) 366-4565.\nSincerely yours,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nHuriaus, Richard\nFrom: John Jacobus [jjacobus@mindspring.com]\nSent: Monday, September 10, 2001 11:59 AM\nTo: richard.huriaux@rspa.dot.gov\nSubject: 196.625 interpretation\nThank you for taking the time to talk to me earlier today. My question specifically deals with 49CFR\n192.625(b) and sequel. Specifically, (b) states that,\n“(b) . . .a combustible gas in a transmission line in a class 3 or 4 location must comply with the requirements\nof paragraph (a) of the section [i.e., must be odorized] unless:\n(1) At least 50 percent of the length of the line downstream from that location is in a class 1 or 2\nlocation. . .\nAm I correct in interpreting this section to mean that there is no requirement for odorization of natural gas if a\ntransmission line passes through, for example, 10 miles of class 3 and/or 4 locations and terminates with one\nmile (or even less) of transmission line passing numerous class 3 and /or 4 locations where long intervening\ndistances are class 1 or 2, but the mere fact that a transmission line terminates in a class 1 or 2 area should\nnot preclude odorization.\nI would value your comments.\nThank you,\nJohn jacobus\nEFI Corporation\n2218 Northpark Drive\nKingwood, TX 77339","truncated":false,"body_characters":3183}