{"operation":"document","citation":"PI-84-001","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1984-01-12","effective_on":null,"summary":"PI-84-001 response to Memo: Internal concerning 192.625.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1984/PI84001.pdf","body":"<<<PAGE 1>>>\n\nSUBJECT: INFORMATION: Questions on Section 192.625, Odorization of Gas\nFROM: Richard L. Beam\nAssociate Director for Pipeline Safety Regulation, DMT-30\nTO: James C. Thomas\nChief, Southern Region, OOE, DMT-16\nTHRU: Robert L. Paulin\nAssociate Director for Operations and Enforcement, DMT-10\nYour memo of October 3, 1968, provided additional information to that in your memo of June 9,\n1983, which now enables OPSR to respond more fully to questions posed in three cases, than was\npossible in our response of September 14, 1983.\nIn the conditions described in Case 1, the pipeline may be either transmission or distribution\ndepending upon the size of the direct sale customer. From a strict reading of the definitions in\n§192.3 of \"transmission line\" and \"distribution line,\" one would classify this line as a \"distribution\nline\" and thus it would be required to be odorized. However, an interpretation of November 30,\n1978, to East Tennessee Natural Gas Company (a copy of the entire package is attached)\nrecognizes the similarity between delivery to a distribution operator and delivery to a direct sale\nindustrial customer of similar size (flow rate) as justification for classifying the upstream pipeline\nas transmission. The determination of whether such a line is transmission or distribution would\ntherefore have to be made in each case based upon the definitions of §192.3 and the attached\ninterpretation. If the line is determined to be transmission and located in a Class 3 or 4 location,\nthe line would also be required to be odorized under §192.625(b) unless it meets one of the\nexceptions under that section.\nIn Case 2 the line serving the customer and operating at or above 20 percent of the SMYS stress\nlevel is a transmission line as defined in §192.3. As in Case 1, a transmission line in a Class 3 or 4\nlocation must be odorized under the requirements of §192.625(b) unless it meets one of the\nexceptions under that section.\nIn Case 3 that portion of the pipeline operating at or above 20 percent of the SMYS stress level\nwould be similar to Case 2 and the same requirements would apply. That portion downstream of\nthe pressure regulator would be similar to Case 1.\nYour memorandum also requests guidance as to how to distinguish between a \"large volume\ncustomer\" and an industrial or farm tap customer. At this time we are not aware of any such\nDB\nC:\\WP51\\INTERPRT\\192\\625\\84-01-12\n1\n\n<<<PAGE 2>>>\n\nguidelines nor any basis for establishing such guidelines other than adopting some arbitrary flow\nrate, which has not been done, as the dividing line between classifications.\nAttachment\nDB\nC:\\WP51\\INTERPRT\\192\\625\\84-01-12\n2","truncated":false,"body_characters":2652}