{"operation":"document","citation":"PI-84-0100","title":"Pipeline Safety Interpretation PI-84-0100","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1984-01-10","effective_on":null,"summary":"PI-84-0100 concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0100.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0100.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0100","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/Pipeline/1984/g84-01-10_Shelby_192.3_Service%20Line%20-%20xs.pdf","body":"<<<PAGE 1>>>\n\nPI-84-0100\nJanuary 10, 1984\nMr. James D. Shelby\nAttorney at Law\n1148 Standard Building\n1370 Ontario Street\nCleveland, OH 44113\nDear Mr. Shelby:\nYour letter of December 22, 1983, requesting available interpretation involved eight questions concerning service lines\nsupplying natural gas to a consumer, odorization of natural gas, and responsibilities of a pipeline operator for leak\ndetection surveys.\nYour first four questions asked whether certain requirements of §§192.143, 192.159, 192.161(e), and 192.273 apply to\nservice lines and for which you requested interpretations that are available. However, please note that in §192.3, the\nfollowing definitions are given: \"'Pipeline’ means all parts of those physical facilities through which gas flows in\ntransportation, including . . .\" and \"'Service line' means a distribution line that transports gas from a common source of\nsupply to (a) a customer meter or …” The key word here is transportation. Therefore, since a service line transports gas\nto a consumer, it is a pipeline and subject to the same requirements that would be generally applicable to pipelines.\nThere are no interpretations on file which are relevant concerning these specific questions.\nYour fifth question asks \"What are the minimum requirements of Sec. 192.361(d) as concern the use of Type L 1/2\" I.D.,\n5/8\" O.D. copper tubing which is connected to an outdoor meter riser assembly by means of a Style #90-65 Dresser\nreducing coupling and steel ells?\" Section 192.361(d), Protection against pipe strain and external loading, is in\nperformance language and applicable to all service lines. This is intended to tell what must be done and does not specify\nhow this must be accomplished or relate to specific components.\nIn response to your sixth question concerning odorization of gas, please note that §192.625(a) refers to \"A combustible\ngas in a distribution line . . .\" Filtration of odorant from natural gas by soil is not relevant to that specific requirement.\nIn 1974, this office had a study (DOT/OPSO-75-08) conducted by the Institute of Gas Technology (IGT) titled \"Study of\nthe Properties of the Numerous Odorants and Assessment of Their Effectiveness in Various Environmental Conditions to\nAlert People to the Presence of Natural Gas.\" This study is available from the U.S. Department of Commerce, National\nTechnical information Service (NTIS), Springfield, Virginia 22161, telephone (703) 487-4650. The study is identified in\nthe NTIS system as PB 249528/AS. For your information, we are enclosing three pages copied from the IGT study that\naddress odor retention in utility piping systems and odor retention under special conditions, including gas passage\nthrough soil.\nYour seventh question asks “Considering Sec. 192.721 and .723, under the following circumstances, what duty does an\noperator of a distribution system have to provide more than its usual annual or twice annually leak detection survey\noutside of a customer's residence: . . .\" It should be noted that §192.723(b) requires a gas detector survey to be\nconducted on distribution systems in business districts at intervals not exceeding 1 year and outside of business districts\nat intervals not exceeding 5 years. There are no specific requirements for more frequent gas detector surveys in\ndistribution systems that would be relevant to the circumstances you described.\nYour last question asks “. . . does the operator have a duty to warn the occupant-customer that digging near the service\nline might cause a leak that won't be detectable by smell?” There are no specific requirements relevant to the\ncircumstances you describe; however, §192.615(d) states that \"Each operator shall establish a continuing educational\nprogram to enable customers, the public, appropriate government organizations, and persons engaged in excavation\nrelated activities to recognize a gas pipeline emergency for the purpose of reporting it to the operator or appropriate\npublic officials. The program and the media used must be as comprehensive as necessary to reach all areas in which the\noperator transports gas. The program must be conducted in English and in other languages commonly understood by a\nsignificant number and concentration of the non-English speaking population of the operator's area.”\nWe hope that we have adequately responded to your questions and that you will find this information useful.\nSincerely\nOriginal signed by\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nJames D. Shelby\nAttorney at Law\n1148 stnadard Buiding\n1370 Ontario Street\nCleveland, Ohio 44113\nDecember 22, 1983\nMr. Richard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\nU. S. Dept. of Transportation\n400 Seventh Street, S.W.\nWashington, D. C. 20590\nRe: 49 CFR Sec. 192.01, et seq.\nDear Mr. Beam:\nThank you for your letter of December 19, 1983 regarding the availability of interpretations of Part 192.\nI am hereby requesting the interpretations that are available regarding the following specific questions.\n1. Do the general requirements of Sec. 192.143 apply to service lines?\n2. Do the flexibility requirements of Sec. 192.159 apply to service lines?\n3. Do the supports and anchors requirements of Sec. 192.161(e) apply to service lines?\n4. Do the general requirements of Sec. 192.273 apply to service lines?\n5. What are the minimum requirements of Sec. 192.361(d) as concern the use of Type L 1/2\" I.D., 5/8\" O.D.\ncopper tubing which is connected to an outdoor meter riser assembly by means of a Style #90-65 Dresser reducing\ncoupling and steel ells?\n6. As applies to Sec. 192.625(a), what consideration is given to the fact that the odorant contained in\nnatural gas will be adsorbed when the natural gas passes through soil? Are operators required to introduce\nodorants into their distribution lines which will remain readily detectable by a person with a normal sense of smell\neven after the natural gas has passed through soil, from a break in the service line, and entered the customer's\nbasement?\n7. Considering Sec. 192.721 and .723, under the following circumstances, what duty does an operator of a\ndistribution system have to provide more than its usual annual or twice annually leak detection survey outside of a\ncustomer's residence:\na) The outdoor meter is read monthly by a meter reader, and\nb) The soil over the underground gas service line in the immediate area of the meter, for a distance\nof ten feet and a width of two - three feet, has obviously been disturbed by digging, and is noticeable to anyone\nwho approaches the meter, and\nc) Three or four monthly meter readings are made between the time of the digging and the time\nthat an explosion and fire occur as a result of a leak in the underground gas service line within five feet of the\nmeter?\n8. Knowing that the natural gas distribution system's odorant will be absorbed by the passage of natural\ngas through soil if a leak occurs underground, what duty does an operator have under sec. 192.751 to post warning\nsigns to minimize the danger of accidental ignition of gas in occupied structures alongside of which an underground\nservice line runs? For example, does the operator have a duty to warn the occupant-customer that digging near the\nservice line might cause a leak that won't be detectable by smell?\nThank you for your kind assistance in this matter.\nSincerely,\nJames D. Shelby","truncated":false,"body_characters":7459}