{"operation":"document","citation":"PI-18-0002","title":"Connecticut PURA — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-09-24","effective_on":null,"summary":"PI-18-0002 response to Connecticut PURA concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/69171/connecticut-pura-pi-18-0002-09-24-2018-part-192625.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\n1200 New Jersey Avenue SE\nof Transportation\nWashington DC 20590\nSafety Administratior\nPipeline and Hazardous Material:\nSEP 2 4 2018\nMr. Karl H. Baker\nPublic Utilities Supervisor of Technical Analysis\nConnecticut Public Utilities\nRegulatory Authority\n10 Franklin Square\nNew Britain, CT 06051\nDear Mr. Baker:\nIn a January 12, 2018, 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 of the odorization requirement for combustible gas in a distribution line under §\n192.625.\nYou stated that you need clarification on the odorant testing requirements for operators of\nliquefied petroleum gas pipeline distribution systems (LPGPDS). You stated that PHMSA's\nrecent interpretation of § 192.625(f) states operators must conduct periodic sampling of\ncombustible gases using an instrument, but you noted neither § 192.625 nor the interpretation\nletter define where the testing must take place. Therefore, you asked the following questions:\nQuestion 1: Is it permissible for an operator of a LPGPDS to only perform the required\nperiodic instrumented sampling at the bulk plant, as defined in NFPA 58 - 2004 edition,\nSection 3.3.10, that supplies the LPGPDS or must the sampling occur at each specific\nLPGPDS?\nQuestion 2: If it is permissible to only sample at the bulk plant, is there a LPGPDS size\nat which this is no longer permissible? For example, would this only apply to a small\nLPG Operator as defined by 49 CFR 192.1001?\nPHMSA's responses to your questions are as follows:\nResponse 1: For safe transportation of gas by pipeline on distribution and some\ntransmission lines, odorization is required under § 192.625. The odorant must be of a\nconcentration that the gas, at one-fifth of the lower explosive limit, is readily detectable\nby a person with a normal sense of smell. To assure the proper concentration of odorant\nin the gas pipeline, under § 192.625(f), each operator must conduct periodic sampling of\ncombustible gases using an instrument capable of determining the percentage of gas in air\nat which the odor becomes readily detectable. Therefore, the required periodic\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nhelp the public understand how to comply with the regulations.\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\n\n<<<PAGE 2>>>\n\n2\ninstrumental sampling, in this case, cannot be limited to testing at the bulk plant, but must\nbe performed in the pipeline system to ensure the entire pipeline system has the required\nodorant levels.\nResponse 2: Based on PHMSA's response to question 1, the response to this question is\nmoot, since the bulk plant is not a pipeline facility and is not regulated under the Federal\npipeline safety regulations. Therefore, the required periodic instrumental sampling, in\nthis case, is not limited to testing at the bulk plant, but must also be performed in the\npipeline system to insure gas odorant is present up to the consumption of the gas.\nIf we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nJohn A. Gale\nDirector, Office of Standards\nand Rulemaking\n49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to th\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulation\nare provided to help the public understand how to comply with the regulations.\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\n\n<<<PAGE 3>>>\n\n'r) , ,\" __: ~' STATE OF CONNECTICUT\nPUBLIC UTILITIES REGULATORY AUTHORITY\nJanuary 12, 2018\nMr. John Gale\nDirector, Standards and Rulemaking Division\nOffice of Pipeline Safety (PHP-30)\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue SE\nWashington, DC. 20590\nDear Mr. Gale,\nThe Gas Pipeline Safety Unit (GPSU) of the State of Connecticut Public Utilities\nRegulatory Authority seeks clarification on the odorant testing requirements for\noperators of liquefied petro.leum gas pipeline distribution systems (LPGPDS). Your\ninterpretation letter dated December 4, 2017, sent to Mr. David Hedrick of AmeriGas\nPropane, LP, clearly states that under 49 CFR 192.625(f), LPGPDS operators must\nconduct periodic sampling of combustible. gases using an instrument capable of\ndetermining the percentage of gas in air at which the odor becomes readily detectable.\nHowever, neither 49 CFR 192.625 nor this interpretation letter clearly define where this\ntesting must take place. -\nTherefore, the GPSU requests answers to the following questions:\n1. Is it permissible for an operator of a LPGPDS to only perform the required\nperiodic instrumented sampling at the bulk plant, as defined in NFPA 58 - 2004\nedition, Section 3.3.10, that supplies the LPGPDS or must the sampling occur at\neach specific LPGPDS?\n2. If it is permissible to only sample at the bulk plant, is there a LPGPDS size at\nwhich this is no longer permissible? For example, would this only apply to a\nsmall LPG Operator as defined by 49 CFR 192.1001?\nThank you for your consideration in this matter. Please do not hesitate to contact me at\n860-827-2661 or by email at karl.baker@ct.gov if there are any questions or if you\nrequire any additional information.\n~~\nKarl H. Baker\nPublic Utilities Supervisor of Technical Analysis\n10 Franklin Square, New Britain, CT 06051\nAn Equal Opportunity Employer\nwww.ct.gov/pura","truncated":false,"body_characters":5982}