Compressed Gas Association, Inc. — Pipeline Safety Interpretation

Page 1January 4, 1971 Mr. Robert E. Lenhard Managing Director Compressed Gas Association, Inc. 500 Fifth Avenue New York, New York 10036 Dear Mr. Lenhard: This is in reply to your letter of December 1, 1970, addressed to Mr. William K. Byrd, which was referred to this office for reply. You questioned the advisability of applying the requirements of 49 CFR, Section 192.625 to hydrogen to be used for food processing, and other applications of odorization where the odorant could have a detrimental effect on the end use of gas. Your earlier comments were carefully considered in the rulemaking process. No reply was sent you, since it is our practice not to reply to comments on our proposed rulemaking. All such comments are part of a docket and available for public inspection. Comments on odorization were also considered at and after an informal public hearing held on September 17, 1970. From your letter it appears that some of your facilities may not be included in the jurisdiction of this Office under the Natural Gas Pipeline Safety Act of 1968. That is to say, they appear not to be engaged in the transportation of gas by pipeline. However, should your members interpret themselves to be within this jurisdiction, they may wish to apply for a waiver of the regulations as provided for in Section 3(e) of the Natural Gas Pipeline Safety Act of 1968 (49 USC 1671 et seq.). Thank you for your interest in the pipeline safety program. Sincerely, Joseph C. Caldwell Director, Acting Office of Pipeline Safety DB/dal/192.625 71-01-04.1#