{"operation":"document","citation":"PI-83-007","title":"Kim R. Henry — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1983-05-19","effective_on":null,"summary":"PI-83-007 concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-007.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-007.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-007","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/PI83007.pdf","body":"<<<PAGE 1>>>\n\nMay 19, 1983\nMr. Kim R. Henry\n10101 Slater Avenue, Suite 204\nFountain Valley, CA 92708\nDear Mr. Henry:\nThis refers to your letter of May 10, 1983, asking whether the requirements of 49 CFR Part 192\nwould apply to a proposed hydrogen gas pipeline to be owned and operated by the Champlin\nPetroleum Company. The pipeline will begin at a Shell refinery in Los Angeles and extend two\nmiles to a Champlin refinery.\nI have issued the enclosed pipeline safety interpretation in response to your inquiry. It provides\nthat the pipeline in question would not be subject to Part 192.\nSincerely,\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nEnclosure\ndal\\192\\3\\83-05-19\n1\n\n<<<PAGE 2>>>\n\nNo. 83-5\nDate: May 19, 1983\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nMATERIALS TRANSPORTATION BUREAU\nNote: _\nPIPELINE SAFETY REGULATORY INTERPRETATION\n_\nThis pipeline safety regulatory interpretation applies a\nparticular rule to a particular set of facts and\ncircumstances, and as such, is binding only on the\noperator to whom the interpretation is specially\naddressed.\nSECTION: 192.1, 192.3\nSUBJECT: Part 192 Jurisdiction Over Proposed Hydrogen Pipeline\nFACTS: Champlin Petroleum Company plans to purchase hydrogen gas from Shell\nOil Company for use in a Champlin refinery. Shell will deliver the gas to Champlin at a\ndehydration plant located inside a Shell refinery where the gas is produced. From the dehydration\nplant, the gas will be transported by Champlin in its own pipeline, which traverses public and\nprivate lands for two miles inside Los Angles before reaching the Champlin refinery.\nQUESTION: Is the proposed Champlin pipeline subject to Part 192?\nINTERPRETATION: As provided in §192.1, Part 192 applies to the \"transportation of gas\",\nwhich is defined in §192.3 to mean \"the gathering, transmission, or distribution of gas by\npipeline... in or affecting interstate on foreign commerce.\" Under the definitions in §192.3 of\n\"gathering line\" and \"service line\" (which is a \"distribution line\"), the transportation of gas that is\nsubject to Part 192 begins at the outlet of a production facility and runs to the point where\nownership of the gas passes to the consumer, or to where gas has been sold and delivered to the\nconsumer. Under the facts, Champlin is the consumer. Both the sale and delivery of hydrogen\ngas to Champlin occur before the gas enters Champlin's pipeline. Therefore, the pipeline\ntransportation of gas to be conducted by Champlin falls outside the jurisdiction of Part 192.\ndal\\192\\3\\83-05-19\n2\n\n<<<PAGE 3>>>\n\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\ndal\\192\\3\\83-05-19\n3\n\n<<<PAGE 4>>>\n\nNo. 83-8\nDate: August 1, 1983\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nMATERIALS TRANSPORTATION BUREAU\n_\nPIPELINE SAFETY REGULATORY INTERPRETATION\n_\nThis pipeline safety regulatory interpretation applies to all\noperators that are subject to the rule under Federal\nor State law.\nNote: SECTION: 192.179\nSUBJECT: Valve Spacing\nFACTS: None.\nQUESTION: How far apart may sectionalizing block valves be placed on an onshore\ntransmission line being constructed in a Class 1 area?\nINTERPRETATION: Section 192.179(a)(4) provides that \"Each point on the pipeline in a Class\n1 location must be within 10 miles of a valve.\" A spacing of not more than 20 miles between\nvalves will result in each point on the pipeline between valves being within 10 miles of a valves.\nThis allowable spacing is supported by the language of the proposed rule (35 FR 5713; April 8,\n1970) upon which §192.179 is based, which stated that \"Each sectionalizing block valve on a\ntransmission line must be installed at a spacing at a spacing not to exceed 20 miles within areas\nconforming to Class 1 Location....\"\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\ndal\\192\\3\\83-05-19\n4\n\n<<<PAGE 5>>>\n\ndal\\192\\3183-05-19\n\n<<<PAGE 6>>>\n\nJuly 14, 1983\nDr. Robert L. Paullin\nAssociate Director\nOffice of Operations & Enforcement\nDepartment of Transportation\n2100 2nd Street, S.W.\nWashington, DC 20590\nRE: D.O.T. Regulations Part 192.179\nDear Dr. Paullin:\nQuestions have developed on the interpretation of valve spacing under 192.179, and we\nwould like to have an official interpretation, hopefully as soon as possible. We have a pipeline\nproject going in within several weeks, and the valve spacing questions will be part of the problems\nwith that job.\nThe opening wording of 192.179 states that each transmission line must have\nsectionalizing block valves spaced as follows:\nUnder sub (4) it states that each point on the pipeline in a Class 1 location must be within\nten miles of a valve.\nA case of ambiguity exists as to whether the actual spacing between valves along a\ntransmission line should be ten, or twenty miles. As worded under (4) above, it could be\nconstrued that if one valve is within ten miles, the requirements have been met. On the other\nhand, if the opening wording of 192.179 referring to sectionalizing block valves it could also be\nargued that each of the two valves required to sectionalize must be within ten miles of any point\non the transmission line.\nPlease provide our office with an interpretation as soon a possible, in view of our\nimminent construction work where this will be arising.\nYours truly,\nA. J. Schellenberg, P.E.\nLead Gas Engineer\ndal\\192\\3\\83-05-19\n6","truncated":false,"body_characters":5450}