{"operation":"document","citation":"PI-93-009","title":"Columbia Gas Distribution Companies — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1993-02-11","effective_on":null,"summary":"PI-93-009 response to Columbia Gas Distribution Companies concerning 192.723.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-009.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-009.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-009","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93009.pdf","body":"<<<PAGE 1>>>\n\nFebruary 11, 1993\nMs. Marjorie H. Brant\nColumbia Gas Distribution Companies\n200 Civic Center Drive\nP.O. Box 117\nColumbus, OH 43216-0117\nDear Ms. Brant:\nThis responds to your letter of February 4, 1993, to George W. Tenley, Jr. in which you ask our\nopinion if, using an HFI, would a standard bar hole depth of 10\" be an acceptable operating\ntechnique for conducting a leakage detection survey on a liquid propane distribution system as\nrequired by §192.723(b).\nI am enclosing a January 8, 1993, letter from William H. Gute, Regional Director, Eastern\nRegion, to the Virginia Corporation Commission responding to that question. I trust that this\nadequately responds to your inquiry.\nSincerely,\nCesar De Leon\nDirector Regulatory Programs\nOffice of Pipeline Safety\ndal\\192\\723\\93-02-11\n1\n\n<<<PAGE 2>>>\n\nJanuary 8, 1993\nMr. Massoud Tahamtani\nUtilities Manager\nVirginia State Corporation Commission\nJefferson Building\nP.O. Box 1197\nRichmond, VA 23209\nDear Mr. Tahamtani:\nThis is in response to your letter dated October 26, 1992, to Mr. Cesar DeLeon, Director,\nRegulatory Programs, Office of Pipeline Safety, requesting interpretations of Code §192.625(a)\n(Odorization of Gas) and §192.723(b) (Leakage Surveys and Procedures - Relating Specifically to\nLiquid Propane Gas Distribution Systems).\nThe Eastern Region has discussed these Code Sections with Mr. DeLeon and as the result, we\noffer the following:\n1. Concerning §192.625(a):\nA violation does not automatically exist if an operator, during random\ntests, finds an inadequate level of odorant in his distribution system\n(assuming the operator can demonstrate a history of adequate levels of\nodorant in his system). However, when an inadequate level is discovered,\nprompt action must be taken by the operator to insure that the level is\nincreased to acceptable limits. The operator must be able to demonstrate\nthat prompt action was taken.\nIf for example, an unacceptable odorant level is discovered and the remedy\ninvolves increasing the injection rate of the odorizer servicing that\nparticular area, then the operator must note that an adjustment was made\n(either to his test document sheet or at least some type of daily log), thus\ndemonstrating that prompt action was taken.\nObviously, some time must pass before the adjustment of the odorizer\neffects the area where insufficient odorant levels were discovered.\nConsequently, a follow-up test must be conducted by the operator in a\ntimely manner to insure that the prompt action taken by the operator has\nsufficiently increased the level of odorant in the problem area.\ndal\\192\\723\\93-02-11\n2\n\n<<<PAGE 3>>>\n\n2\n2. Concerning §192.723(b):\nYou may with to consult the Gas Piping Technology Committee (GPTC)\nGuide for Gas Transmission and Distribution Piping System, 1990-91,\nGuide Material Appendix G-11A, Gas Leakage Control Guidelines for\nPetroleum Gas Systems for guidance in further determining the instruments\nand techniques to be used in leak detection of liquid propane distribution\nsystems.\nIn your letter, you noted the following different methods presently being\nused by operators in Virginia:\n1) Bar hole to a depth at or below main and use\nCGI,\n2) Bar hole to a depth of ten inches and use HFI,\nand;\n3) Mobil Survey using HFI.\nAccording to Appendix G-11A, any of the methods above \"may be employed, as applicable,\nsingly or in combination, in accordance with written procedures\".\nYou will note from this Appendix on Page 302, Section 4.4(a)(2), copy attached, that \"The\nrequired depth of the test hole will depend upon the soil conditions, the depth of and pressure in\nthe pipeline, and the type of instrument being used\".\nConsequently, method No.2 above would be acceptable if soil conditions are such that the partial\nvacuum created by the HFI unit enabled the taking of \"consistent and worthwhile readings\".\nShould you have any questions, please don't hesitate to contact me.\nSincerely,\nWilliam H. Gute\nEastern Regional Director\ndal\\192\\723\\93-02-11\n3\n\n<<<PAGE 4>>>\n\nOffice of Pipeline Safety\ndal\\192\\723\\93-02-11\n4","truncated":false,"body_characters":4043}