{"operation":"document","citation":"PI-83-017","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1983-09-14","effective_on":null,"summary":"PI-83-017 response to Memo: Internal concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-017.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-017.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-83-017","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1983/PI83017.pdf","body":"<<<PAGE 1>>>\n\nSeptember 14, 1983\nINFORMATION: Questions on Section 192.625, Odorization of Gas\nRichard L. Beam\nAssociate Director for Pipeline Safety Regulation, DMT-30\nJames C. Thomas\nChief, Southern Region, OOE, DMT-16\nTHRU: Robert L. Paullin\nAssociate Director for Operations & Enforcement, DMT-10\nYour memo of June 9, 1983, asks questions based on conditions listed in five cases relating to the\nodorization requirements of §192.625.\nThe information provided on Cases 1, 2, and 3 is inadequate for us to determine whether the lines\ninvolved are distribution or transmission, or are transmission that may be excepted under\n§192.625(b)(2) or (3). Therefore, we cannot make a determination as to the need for odorization.\nIn the conditions described in Case 4, the pipeline may be odorized at any point that would ensure\ndetectability of appropriate concentrations in air (one fifth of the explosive limit) along the entire\nlength of pipeline (§192.625(a)). The most likely location would be at the closest practicable\npoint just downstream of the tap. While §192.625 does not specifically prohibit introducing the\nodorant on the consumer's piping, it is highly unlikely that odorant introduced at this point would\nin fact odorize all of the pipeline required to be odorized upstream of the sales meter.\nIn response to Case 5, the nature of the commerce the company conducts does not affect the\nclassification of the line under §192.3. Cases 1 and 3 would be affected if the line terminates at a\nlarge volume customer because the line may be a transmission line and might be exempt from\nodorization under §192.625(b). The decision in Case 2 would not be affected because the line is\nalready in the transmission category.\ndal\\192\\625\\83-09-14\n1\n\n<<<PAGE 2>>>\n\nDate: June 9, 1983\nSubj: ACTION: Odorization Interpretations\nFrom: James C. Thomas, Chief\nSouthern Region, Pipeline Safety, DMT-16\nTo: Thru: Richard L. Beam, Associate Director,\nOPSR, DMT-30\nRobert L. Paullin, Associate Director,\nOOE, DMT-10\nInterpretations concerning the odorization of certain pipelines need further\nclarification for the proper enforcement of this rule. Therefore, I request that the\nOPSR respond to the following questions relating to Section 192.625.\nAre the following pipelines serving gas to one customer required to be odorized at\nsome point between the tap on the source line and the sales meter? (Assume that\nthe source line is legally unodorized and that the presence of odorant would not\nharm the customer).\n1. Direct sales line, owned by an interstate operator and operating at a hoop stress\nless than 20% SMYS.\n2. Same as 1. above except operating at or above 20% SMYS.\n3. Same as 2. above except that the downstream line section operates at less than\n20% SMYS between the pressure limiting device and the sales meter.\n4. In the above examples that do require odorization, at what place on the line\nsegment must the odorization equipment be located? (For example, the closest\nmost practicable point just downstream of the tap, or at any place on the pipeline?\nCould it be installed downstream of the sales meter on customer piping?\n5. In situations 1., 2., and 3. above, would the answers remain the same if the\npipeline serving gas to one customer was owned and operated by an intrastate\ndal\\192\\625\\83-09-14\n2\n\n<<<PAGE 3>>>\n\ncompany? Would the answers be affected by whether the line terminates at a\n\"large volume customer\" or not?\n#\ndal\\192\\625\\83-09-14\n3","truncated":false,"body_characters":3449}