{"operation":"document","citation":"PI-14-0017","title":"Air Products and Chemicals, Inc. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-03-11","effective_on":null,"summary":"PI-14-0017 response to Air Products and Chemicals, Inc. concerning 192.5.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-14-0017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-14-0017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-14-0017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2015/Air_Products_PI_14_0017_10_01_2014_Part_192.5.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\n~t~.P. 1 1 2015\nMr. Jody R. Arner\nAir Products and Chemicals, Inc.\n7201 Hamilton Boulevard\nAllentown, P A 18195-1501\nDear Mr. Arner:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nSeptember 18, 2014, you requested an interpretation on the manner in which structures are\ncounted for purposes of determining class location along a gas pipeline. Specifically, your\nquestions involved the use of \"clustering\" of buildings as referenced in 49 CPR 192.5( c )(2).\nIn particular, you asked whether there is any overall length limit to the application of clustering.\nYou provided an example diagram (attached) and explained the diagram as a hypothetical cluster\nof buildings extending for 1.15 miles in a Class 3 location. You stated that because the length\nexceeds 1 mile, you would like to know if clustering is allowed under § 192.5( c) to end the\nClass 3 location at 220 yards from the end of the 1.15 miles. You stated that there are few\nstructures on either end of the cluster in the example you provided, but not within 220 yards at\nthe end of the 1.15 miles. You stated that if any structure( s) would be present outside of the\n220 yards that would result in a Class 3 sliding mile count, then that structure(s) would be given\nClass 3 status over the appropriate length as required.\nUnder§ 192.5(a), the class location unit establishes the class location, identifying the highest\nconcentrations of dwellings along the pipeline in a continuous mile of pipeline. As you slide\nthe class location unit down the pipeline for 220 yards, as soon as you encounter a higher\nconcentration of dwellings, you have a higher class location (see Graphic 1). Section 192.5(c)\nallows an operator to cluster or reduce the amount of pipe that is subject to the requirements of\na higher class location.\nA Class 3 location can be longer than a mile or shorter than a mile when using the clustering\nmethod. As illustrated in Graphic 2, if a class location unit is determined to be Class 3 with a\ngroup ofhomes on one end (A) and a group ofhomes on the other end (B), the amount of\npipeline that would be subject to Class 3 requirements can be reduced by the application of\nclustering. To cluster, the operator could establish the Class 3 location limit 220 yards on the\nupstream side of (A) and 220 yards on the downstream side of (A). The same would be\nrepeated for (B) at the other end of the class location unit. The pipeline between these two\nclusters is still in a Class 3 location; it is just not subject to the requirements of a pipeline in a\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nClass 3 location. If the 220 yard limits intercept or overlap between the two clusters, then\nclustering between the two groups would not be applicable and the entire length of the pipeline\nfrom 220 yards upstream of (A) to 220 yards downstream of (B) would be subject to the Class\n3 location requirements.\nClass Location Unit Application I· Class I ·I· Class 2\nClass 3\nClass 2\n·I~ ·I\nml9\nIEll\nClass 1\nClass 2\n.--··-··-··-··-··-··-··-··-··-··-··-··-··-··-··,\n! 1-mile length -blue box i\nL.·-··-··-··-··-·· ··-··-··-··-··-··-··-··-··~\nClass 3\nClass 3\nClass 2\nIn the above example use\nthe highest Class location\nGraphic 1\nClustering\nOne (1) Mile) Segment\nClass 3 (Established by the Class Location Unit)\n·I\n220 yards lillii\nGroup A Group B\n220 yards 9\n220 yards 11111!!11 1111 220 yards\nAny additional dwelling outside Group A in the !-mile segment would\nbe classified a Class 3 location as described by example Group B above.\nmi Eiil\n1!!11El11!!11\n1!!11 )\nClass 3 + Class 1 + Class 3\nI~\nCluster- Class 3 Cluster- Class 3\nGraphic 2\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\nWe hope this clarifies the application of clustering in§ 192.5(c). If we can be of further\nassistance, please contact Tewabe Asebe of my staff at 202-366-5523.\nSincerely,\n;Jj~\n(__/!~Gale\nDirector, Office of Standards\nand Rulernaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nAIR .1•\nPRODUCTSC:\nAir Products and Chemicals, Inc.\n7201 Hamilton Boulevard\nAllentown, PA 18195-1501\nTelephone (610) 481-4911\nOffice of Pipeline Safety (PHP-30), PHMSA\nU.S. Department of Transportation\n1200 New Jersey Avenue S.E.\nWashington, DC 20590-0001\n18 September 2014\nRef.: Request by Air Products and Chemicals, Inc., for interpretation on the use of clustering as\ndefined in 49 CFR Part 192, section 192.5(c)(2).\nDear Sir/Madam:\nAir Products and Chemicals, Inc., is requesting an official interpretation on the use of clustering as defined in\n49 CFR Part 192, section 192.5(c)(2). Our general question is related to whether or not there is any overall\nlength limit to the application of clustering. There may be situations considered for clustering where there is\na group of buildings determined to be class 3 that extends for more than 1 mile. Can class 3 end at 220\nyards from the structures at each end of that section, or must it be carried out to the distance where the\nactual structure count drops to class 2?\nPlease refer to the enclosed example diagram (Exhibit A) for detail and clarification for this interpretation. In\nthis example, the specific question would arise as a result of the obvious 1.15 mile length of class 3 between\npoints A and B. Given that that length exceeds 1 mile, is it allowable to apply clustering to end the class 3 at\n220 yards west of point A and 220 yards east of point B, or must the class 3 be extended to the boundary of\nthe sliding mile on each end?\"\nPlease note that there are few structures on either end of the grouping in this example, and as indicated\nthere are none within 220 yards. If any structure(s) would be present outside of the 220 yards that would\nresult in a class 3 sliding mile count, then that structure(s) would be given class 3 status over the\nappropriate length as required.\nPlease contact me with any additional questions or if any additional information is required to provide this\ninterpretation.\nSin ~ £~\nJody R. Arner\nAir Products & Chemicals, Inc.\nGlobal Operations I Pipeline Maintenance I Project Engineering\nPh. 610-481-1707 Fax: 610-481-8790\ne-mail: arnerjr@ airproducts.com\nAttachment:\n1) Exhibit A; diagram of 192.5(c)(2) clustering\n\n<<<PAGE 5>>>\n\nEXH IBIT A: Reference Air Products and Chemicals request for interpretation on applicability of clustering per 49 CFR Part 192, section\n192.5(c)(2), dated 18 September 2014.\n- Notes: 1) All structures are single dwelling units within the 220 yard buffer zone.\n2) No structure located between point A and point B has more than 220 yards separation from another structure.\n1 MILE NO OTHER\nSTRUCTURES ~\nWITHIN 220\nYARDS\n1 MILE r NO OTHER\nSTRUCTURES\nWITHIN 220\nYARDS\n~I\nNORTH\nt\n••••••••••••••••••••••••\n••••••••••••••••••••••••\n••••••••••••••••••••••••\n••••••••••••••••••••••••\n220 YARDS 1<11 ~ I\n1011 ~ ~ 220 YARDS\n1.15 MILES\nCLASS 3 -----------~\n(Clustering Applicable)\nC~SS3------------------------------~\n(Clustering Not Applicable)\nAir Products Internal Use Only","truncated":false,"body_characters":8541}