{"operation":"document","citation":"18-0017","title":"Explosives Test Center, LLC — PHMSA Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-06-15","effective_on":null,"summary":"18-0017 response to Explosives Test Center, LLC; G2 Integrated Solutions concerning 173.62, 192.903.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/56666/olin-pi-17-0017-12-07-2017-part-192903.pdf","body":"<<<PAGE 1>>>\n\nU.S . Department\nofTransportation\nPipeline and Hazardous Materials\nS afety Administration\n1200 New Jersey Avenue SE\nWashington DC 20590\nDE C 0 7 2017\nMr. John A. Jacobi\nVice President and Principal\nG2 Integrated Solutions\n10850 Richmond A venue, #200\nHouston, TX 77042\nRe: Petit~ for Finding\nDear Mj'Jacobi:\nOn June 28, 2017, pursuant to 49 C.F.R. § 190.9, G2 Integrated Solutions, on behalf of Olin\nPipeline Services (G2) filed a petition for a finding or approval (Petition) to use its proposed\nmethodology to calculate the Potential Impact Radius (PIR) of non-flammable gas anhydrous\nhydrogen chloride (HCL). Specifically, G2 requested a finding allowing the use of the PIR\nfactor published by Pipeline and Hazardous Materials Safety Administration (PHMSA) in TT0-\n13 for hydrogen, the urban setting PIR for chlorine published in TT0-14, and the TT0-14\nprotocol to calculate the PIR factor for the urban setting for anhydrous HCL. The resulting PIRs\nwould then be used to identify Part 192 High Consequence Areas using 49 CFR § 192.903,\nMethod2.\nSection 190.9 provides that in circumstances where a rule contained in parts 192, 193 and 195 of\nthe pipeline safety regulations authorizes the Administrator to make a finding or approval, an\noperator may petition the Administrator for such a finding or approval. The petition must refer\nto the rule authorizing the action sought and contain information or arguments that justify the\naction.\nHaving reviewed G2's request, PHMSA has determined that it does not meet the requirements\nset forth in § 190.9 for a petition for finding or approval, because G2 has failed to identify a rule\nauthorizing the action sought. The integrity management regulation cited,§ 192.903, does not\nauthorize the Administrator to make a finding or approval with respect to using alternative means\nto calculate PIR. Rather the regulation specifies how PIR must be calculated for the purpose of\nidentifying high consequence areas.\n\n<<<PAGE 2>>>\n\nIf you have any questions or would like to discuss further, please contact Tewabe Asebe at 202-\n366-5523.\nSincerely,\no . a\nDirector, Office of Standards\nand Rulemaking\n\n<<<PAGE 3>>>\n\n,..2 INTEGRATED\n\\.:f-'s o L U TIO N S\n10850 Richmond Ave .. #200 Houston, 'TX 77042\n0: 713 260.4000\ninfo@g2-is.com www.g2-is.com\nJune 28, 2017\nStephanie Weidman, PHMSA Program Director\nRailroad Commission of Texas\nP.O. Box 12967\nAustin, Texas 78711-2967\nRe: Request for finding or approval under 49 CFR §190.9\nOlin Pipeline Services (A Division of Olin Corporation)\n2301 N. Brazosport Blvd., B-101 #38\nFreeport, TX 77541\nPHMSA OPID 39376\nT4 Permit Number #09681 (gas lines)\nDear Ms. Weidman:\nVia e-Mail\nG2 Integrated Solutions (G2) has been retained by Olin Pipeline Services (Olin) to request a\nfinding pursuant to 49 CFR §190.9(a):\n(a) In circumstances where a rule contained in parts 192, 193 and 195 of this chapter\nauthorizes the Administrator to make a finding or approval, an operator may petition the\nAdministrator for such a finding or approval.\nThe Railroad Commission of Texas (RRC) is receiving this request because the lines affected\n(see below) are intrastate Part 192 pipelines under the primary jurisdiction of the RRC and 49\nCFR §190.9(b)(1) requires operators seeking a finding or approval involving intrastate pipeline\ntransportation to send such requests to the State agency certified to participate under 49 U.S.C.\n60105 - in this case, the RRC.\nBackground\nOlin recently acquired a number of pipelines from the Dow Chemical Company, Texas Operations\nand is in the process of conducting a compliance audit under the Texas Environmental, Health\nand Safety Audit Privilege Act. G2 has been and is assisting Olin in conducting the compliance\naudit.\nFor purposes of 49 CFR Part 192, Subpart 0 - Gas Transmission Pipeline Integrity Management,\nOlin has elected to use Method 2 (49 CFR §192.903) to define high consequence areas:\n(2) The area within a potential impact circle containing-\n(i) 20 or more buildings intended for human occupancy, unless the exception in\nparagraph (4) applies; or\n(ii) An identified site.\n\n<<<PAGE 4>>>\n\nG2 Integrated Solutions\nPage 2 of 4\nThe following 49 CFR §192.903 definitions are relevant to this request:\nPotential impact circle is a circle of radius equal to the potential impact radius (PIR).\nPotential impact radius (PIR) means the radius of a circle within which the potential\nfailure of a pipeline could have significant impact on people or property. PIR is\ndetermined by the formula r = 0.69* (square root of (p\"d2), where 'r' is the radius of a\ncircular area in feet surrounding the point of failure, 'p' is the maximum allowable\noperating pressure (MAOP) in the pipeline segment in pounds per square inch and 'd' is\nthe nominal diameter of the pipeline in inches.\nNote: 0.69 is the factor for natural gas. This number will vary for other gases\ndepending upon their heat of combustion. An operator transporting gas other\nthan natural gas must use section 3.2 of ASME/ANSI B31.8S-2001 (Supplement\nto ASME/ANSI 831.8; (incorporated by reference, see §192.7) to calculate the\nimpact radius formula.\nThis request arises because of PHMSA's response to Gas IMP FAQ 144:\nWhat is the preferred method for calculating the Potential Impact Radius (PIR) of a leak\nof a non-flammable gas within the context of Pipeline Integrity Management?\nThe regulation refers to ASME 831.85-2001 Section 3.2 for calculation of PIR for gases\nother than natural gas. However, this document only deals with flammable gases. ASME\nB31.8S-2001 allows alternate models to be used for calculating impact radius, but\nprovides no guidance as to preferred methods of modeling non-flammable or corrosive\ngases. [10/25/2004)\nThe potential impact circle concept is only applicable for flammable gases. Operators of\npipelines carrying non-flammable gases must consider their entire pipelines as if they\nwere in high consequence areas, or they may apply for a waiver to use another method\nthat they may propose for defining HCAs. (emphasis added)\nIn January, 2005 (subsequent to publishing FAQ 144), PHMSA published ITO Number 14,\nDerivation of Potential Impact Radius Formulae for Vapor Cloud Dispersion Subject to 49 CFR\n§192 (TI0-14, available at\nhttos://primis.phmsa.dot.gov/qasimp/docsITT014 finalreport January2005.pdf).\nVery briefly, IT0-14 developed simplified PIR formulae for non-flammable\nhazardous/toxic products using the US Environmental Protection Agency's (EPA) \"Risk\nManagement Program Guidance for Offsite Consequence Analysis.\" (RMP Guidance). In other\nwords, TI0-14 established a scientific basis for calculating CFER PIR factors (0.69 for natural\ngas) for toxic but non-flammable gasses .. Note that the RMP guidance results in the calculation\nof two factors for each toxic endpoint - one for rural settings and one for urban settings. The\nresulting PIRs for rural settings are somewhat larger based on the theory that rural settings are\n\n<<<PAGE 5>>>\n\nG2 Integralcd Solutions\nPage 3 of 4\nflat and offer less resistance to dispersion of vapor clouds. It is Olin's position that a\nrefinery/chemical manufacturing facility more closely resembles EPA's urban setting.\nOne of the non-flammable gasses transported by Olin, chlorine, was specifically addressed by\nTT0-14. Another, anhydrous HCL, was not. A third gas, hydrogen, is a flammable gas and its\nCFER PIR factor was specifically calculated in TT0-13 consistent with the methodology of\nsection 3.2 of ASME/ANSI B31.8S-2001\n(https://primis.phmsa.dot.gov/gasim p/docs/TT013 PotentiallmpactRadius Final Report June200\n5.pdf}\nThe Specific Lines in Question\nUsing published data for PIR factors for hydrogen and chlorine and the TT0-14 protocol for\ncalculating both the rural and urban settings for anhydrous HCL yield the following PIRs for each\nof the Olin Part 192 lines subject to 49 CFR Part 192:\n1 28\n2 130\n3 246\n4 261\n5 331\n6 406\nChlorine\nChlorine\nAnhydrous HCL 24\nAnhydrous HCL 12\nChlorine 12\nHydrogen 30\n150\n200\n650\n650 0.08/0.06 (6)\n150 0.38/0.16\n13 0.47 (5)\n75/32\n86/37\n46/35 (6}\n24/ 19 (6}\n56/26\n51\nNotes:\n1.\n2.\n3. 4. 5. 6. 7. Diameter of largest segment.\nMAOP based on 49 CFR 192.619.\nno 14 = PHMSA Final Report Derivation of Potential Impact Radius\nFormulae for Vapor Cloud Dispersion Subject to 49 CFR 192.\n(rural cond!t!c:1$/ urb;:m conditions}\nPIR Coefficient for natural gas is 0.69 (49 CFR 192.903}.\nPIR Coefficient for hydrogen is 0.47 (TTO 13 - CFER Other Gasses Report).\nCalculated based on no 14 protocol.\nRounded up to nearest foot. PIR= PIR coefficient*(square root of (p* d2))\nReauest\nOlin hereby requests permission to use the PIR factor published by PHMSA in TT0-13 for\nhydrogen, the urban setting PIR for chlorine published in TT0-14, and the TT0-14 protocol to\ncalculate the PIR factor for the urban setting for anhydrous HCL. The resulting Pl Rs will be used\nto identify Part 192 High Consequence Areas using 49 CFR §192.903, Method 2.\n\n<<<PAGE 6>>>\n\nG2 lntl'grated Solution~\nPage .J of 4\nPlease note that, under 49 CFR §190.9, the RRC must provide the Associate Administrator for\nPipeline Safety (Alan Mayberry) a written recommendation as to the disposition of this request for\nfinding. If PHMSA does not reverse or modify the RRC's recommendation within 10 business\ndays of its receipt, the RRC's recommendation shall constitute PHMSA's decision.\nClosing\nOlin maintains all its lines to OSHA PSM standards. Where the pipeline safety regulations (49\nCFR Parts 190 -199) impose different or additional requirements, Olin complies with those\ndifferent or additional requirements as well. The PIRs proposed above are consistent with the\nbest available scientific data currently available and, at least in my opinion, consistent with the\ngoal of providing reasonable protection of both human health and the environment and the\nintegrity of the lines themselves as authorized and required by the pipeline safety statutes (49\nUSC §60101 et.seq.), the pipeline safety regulations (49 CFR Parts 190 -199) and the Texas\nAdministrative Code (16 TAC Chapter 8).\nYour prompt consideration of this request would be very much appreciated.\nPlease do not hesitate to contact the undersigned should you have any questions (cell 832-71 2-\n3098, e-mail john.jacobi@g2-is.com).\nCF: Terry Fassnidge (Olin)\nRandal Anderson (Olin)","truncated":false,"body_characters":10292}