{"operation":"document","citation":"PI-18-0005","title":"Simplot Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-07-31","effective_on":null,"summary":"PI-18-0005 response to Simplot Company concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0005.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0005.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-18-0005","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/58906/simplot-pi-18-0005-07-31-2018-part-192625.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\n' JUL 3 1 2018\nMr. Alan L. Prouty\nVice President,\nSustainability & Regulatory Affairs\nSimplot Company\n1099 W. Front Street\nP.O. Box 27\nBoise, ID 83707\nDear Mr. Prouty:\nIn a September 28, 2017, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you requested an interpretation of 49 CFR Part 192. Specifically, you requested\ninterpretation of the odorization requirement under§ 192.625(f).\nYou stated the pipeline facility transports biogas that has natural odorizing smell. Therefore, you\nasked whether Simplot Company must comply with the§ 192.625(f) requirements since the gas\ncontains a strong natural odor whose concentration cannot be changed. In addition, in a May 21,\n2018, email you provided documentation that describes the pipeline as a 1-mile long, 8-inch\ndiameter biogas plastic (HDPE) intrastate transmission line in a Class 2 location. The document\nalso shows the line operating at a maximum allowable operating pressure (MAOP) of 15 psig or\n29.4 percent of the specified minimum yield strength (SMYS).\nSection 192.625 does not require transmission pipelines in Class 1 and Class 2 locations to be\nodorized. Therefore, under the Federal pipeline safety regulations, you are not required to\nodorize the pipeline.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form 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\nPlease be advised, however, that 49USC. 60104( c) allows states with a certification under\n§ 60105(a) to adopt additional or more stringent safety standards for intrastate pipeline facilities\nand intrastate pipeline transportation if those standards are compatible with the minimum\nstandards prescribed by Federal law. Consequently, the State of Washington, which has a\ncertification to regulate intrastate gas transmission pipelines, may have more stringent\nregulations - including odorization for intrastate transmission lines in all intrastate Class\nlocations which may apply to your pipeline.\nlfwe can be of further assistance, 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 (49 CFR\nParts 190-199) in the form 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 3>>>\n\n• S1mpo\n.Ht Simplot Company\nSimplot Headquarters\n1099 \\IV. Front Street\nBo ise, lclaho 83702\nP D Box 27\nBoise, Idaho 83707\n20 8 336 21i0\nSeptember 28, 2017\nSENT VIA UPS OVERNIGHT DELIVERY\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nEast Building, 2nd Floor\nMail Stop: E24-455\n1200 New Jersey Ave., SE\nWashington, DC 20590\nDear Sir or Madam:\nSimplot Foods Group requests an interpretation of 49 CFR, Part 192.625 in\nregards to odorant testing of a naturally odorized biogas pipeline.\nAs background information, the pipeline facility in question transports biogas\nproduced by an anaerobic digester to an industrial facility to be used as boiler\nfuel. The natural characteristics of this biogas give it a strong smell and contains\nhydrogen sulfide which is a toxic gas. The naturally produced odor and hydrogen\nsulfide is produced by the biologic action of the bacteria consuming the organic\nmaterial within the digester and is not added to the gas stream as would a\ntraditional odorant.\nAdditionally, 49 CFR, Part 192.625(f) requires the use of an instrument to\ndetermine odorant concentration. The traditional methods of determining odorant\nconcentration uses an odorometer which subjects operating personnel to\nbreathing the hydrogen sulfide which is toxic.\nSpecifically Simplot requests an interpretation of 49 CFR, Part 192.625(f)\nspecifically if the gas contains a strong natural odor whose concentration cannot\nbe changed due to the biologic process by which it is produced, and that gas\ncontains a toxic constituent which precludes traditional concentration testing, can\nodorant concentration testing be waived in this situation.\n\n<<<PAGE 4>>>\n\nThank you for your prompt attention and response to this letter. Your\ninterpretation and insight are greatly appreciated.\nSincerely,\nAlan L. Prouty\nVice President, Sustainability & Regulatory Affairs\ncc: Tara Swanson, J.R. Simplot Company\nBurl Ackerman, J.R. Simplot Company\nAlicia Duke, J.R. Simplot Company","truncated":false,"body_characters":5180}