{"operation":"document","citation":"PI-17-0008","title":"AmeriGas Propane, LP — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2017-12-11","effective_on":null,"summary":"PI-17-0008 response to AmeriGas Propane, LP concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0008.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0008.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0008","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/56656/amerigas-pi-17-0008-12-04-2017-part-192625.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\nDEG 0 4 2017\n1200 New Jersey Avenue SE\nWashington DC 20590\nMr. David Hedrick\nNational Pipeline Safety Manager\nAmeriGas Propane, LP\n1173 Parkland\nLake Orion, MI 48360\nDear Mr. Hedrick:\nIn a May 9, 2017 letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you requested an interpretation of 49 CFR Part 192. Specifically, you requested an\ninterpretation on the odorization requirements of§ 192.625(f) as it relates to liquefied petroleum\ngas.\nYou asked whether a verification of the concentration level in air of odorant in a combustible gas\nin a pipeline using an instrument is required for petroleum gas. You stated that the 2004 Edition\nof the National Fire Protection Association (NFPA) 58 requirement for liquefied petroleum\nallows odorant determined by sniff testing. Also, you mentioned that 49 CFR Part 173 .315(b )(1)\nspecifies the minimum addition ratio of odorants to liquefied petroleum gas.\nYou asked \"Since both codes, National Fire Protection Association Pamphlet 58, Liquefied\nPetroleum Gas Code, and Title 49 Code of Federal Regulations specify the minimum addition\nratios of certain odorants to LP Gases (propane in particular) for the gas to be readily detectible\nin air at a concentration of not over one-fifth the lower explosion level, if the amount of odorant\nused per LP Gas gallon meets the Code requirements and that amount is documented, and if sniff\ntesting is an allowable measure to determine the presence of odorant, should operators of LP Gas\npipeline distribution systems be exempted from the requirements of 192.625 (f) to use test\ninstruments to determine the concentration level of odorant in the gas?\"\n49 CFR Part 173 governs the transportation of hazardous materials \"shipment by air, highway,\nrail, or water, or any combination thereof.\" It does not include regulations regarding the\ntransportation of liquefied petroleum gas through a pipeline. Therefore, 49 CFR Part\n173 .3 l 5(b )(1) does not apply to an operator's obligations for transporting liquefied petroleum\ngas through a pipeline distribution system. Liquefied petroleum gas pipeline distribution\nsystems are regulated under 49 CFR Part 192, the pipeline safety regulations governing the\ntransportation of natural and other gas by pipeline.\nPHMSA regulates petroleum gas pipeline systems under 49 CFR § 192.11. Section 192.11\nrequires that each plant that supplies petroleum gas by pipeline to a natural gas distribution\nsystem must meet the requirements of Part 192 and NFPA 58 and 59 (2004) (192.1 l(a)). It also\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the fonn of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nstates that each pipeline system subject to Part 192 that transports only petroleum gas or\npetroleum gas/air mixtures must meet the requirements of Part 192 and ofNFPA 58 and 59\n(192.1 l(b)). Finally, the regulation lays out a primacy provision stating that in the event of a\nconflict between the regulation and the standard, NFPA 58 and 59 prevail(§ 192.1 l(c)).\nHowever, this primacy provision does not excuse operators from following the Part 192\nrequirements. For instance, when NFPA 58 or 59 (2004) does not address a specific subject,\nthen no conflict has occurred and the operator must follow the Part 192 requirements.\nGas odorization is governed by 49 CFR 192.625, which states that \"combustible gas in a\ndistribution line must contain a natural odorant or be odorized so that at a concentration in air of\none-fifth of the lower explosive limit, the gas is readily detectable by a person with a normal\nsense of smell.\" 49 CFR § 192.625(a). Under § 192.625(f) all operators must conduct periodic\nsampling of combustible gases using an instrument capable of determining the percentage of gas\nin the air at which the odor becomes readily detectable, except for master meter system\noperators.\nOperators of liquefied petroleum gas pipeline distribution systems must comply with the\nrequirements of Part 192, including its gas odorization regulations unless there is a conflict\nbetween Part 192 and NFPA 58 and NFPA 59. In this case, there is no conflict between Part 192\nand NFPA 58 and NFPA 59. Therefore, under§ 192.625(f), such operators must use test\ninstruments to determine the concentration level of odorant in the gas. If we can be of further\nassistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nMay 9, 2017\nU.S. DOT\nPHMSA Office of Hazardous Materials Standards\nAttn: PHH-10\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\nREQUEST FOR INTERPRETATION\nThis correspondence is to request a formal interpretation and relief from of the requirements of 49\nCFR Part 192.625 (f) as it relates to liquefied petroleum gas and verification of the concentration\nlevel in air of odorant in a combustible gas in a pipeline by the use of an instrument for such\nverification to assure the level is readily detectable at one-fifth the lower explosive limit of the\ngas.\nAccording to 49 CFR Part 173.315 (b) (1):\n1)Odorization. All liquefied petroleum gas shall be effectively odorized as\nrequired in Note 2 of this paragraph to indicate positively, by a distinctive odor,\nthe presence of gas down to a concentration in air of not over onefifth the lower\nlimit of combustibility provided, however, that odorization is not required if\nharmful in the use or further processing of the liquefied petroleum gas, or if\nodorization will serve no useful purpose as a warning agent in such use or further\nprocessing.\nNOTE 1: The lower limits of combustibility of the more commonly used liquefied\npetroleum gases are: Propane, 2.15 percent; butane, 1.55 percent. These figures\nrepresent volumetric percentages of gas-air mixtures in each case.\nNOTE 2: The use of 1.0 pound of ethyl mercaptan, 1.0 pound of thiophane, or 1.4\npounds of amyl mercaptan per 10,000 gallons of liquefied petroleum gas shall be\nconsidered sufficient to meet the requirements of §173.315(b)(1). This note does\nnot exclude the use of any other odorant in sufficient quantity to meet the\nrequirements of §173.315(b)(1).\nFurthermore, the 2004 Edition of the National Fire Protection Association Pamphlet 58,\nLiquefied Petroleum Gas Code, Section 4.2.1 reads:\n\n<<<PAGE 4>>>\n\nU.S. DOT\nPHMSA Office of Hazardous Materials Standards\nMay 9, 2017\nPage 2\nAll LP Gases shall be odorized prior to delivery to a bulk plant by the addition of\na warning agent of such character that the gases are detectable, by a distinct\nodor, to a concentration in air of not over one-fifth the lower flammability limit.\n4.2.3\nIf odorization is required, the presence of the odorant shall be determined by sniff testing\nor other means and the results shall be documented as follows:\n(1) When LPGas is delivered to a bulk plant\n(2) When shipments of LPGas bypass the bulk plant\nAnd A.4.2.1 states:\nExperience has shown that ethyl mercaptan in the ratio of 1.0 lb (0.45 kg) per\n10,000 gal of liquid LP-Gas has been recognized as an effective odorant. Other\nodorants and quantities meeting the provisions of 4.2.1 may be used.\nSince both codes, National Fire Protection Association Pamphlet 58, Liquefied Petroleum\nGas Code, and Title 49 Code of Federal Regulations specify the minimum addition ratios\nof certain odorants to LP Gases (propane in particular) for the gas to be readily detectible\nin air at a concentration of not over one-fifth the lower explosion level, if the amount of\nodorant used per LP Gas gallon meets the Code requirements and that amount is\ndocumented, and if sniff testing is an allowable measure to determine the presence of\nodorant, should operators of LP Gas pipeline distribution systems be exempted from the\nrequirements of 192.625 (f) to use test instruments to determine the concentration level\nof odorant in the gas?\nThank you for your consideration in this matter. Please do not hesitate to contact me at\n215-970-4159 or by email at david.hedrick@amerigas.com if there are any questions or\nshould you require additional information.\nThank you.\nDavid Hedrick\nDavid Hedrick\nNational Pipeline Safety Manager\nAmeriGas Propane, LP\n1173 Parkland\nLake Orion, MI 48360","truncated":false,"body_characters":9182}