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Interpretation Response #PI-18-0005


Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 07-31-2018
Company Name: Simplot Company    Individual Name: Mr. Alan L. Prouty
Location state: ID    Country: US

View the Interpretation Document


Response text:

Mr. Alan L. Prouty
Vice President,
Sustainability & Regulatory Affairs
Simplot Company
1099 W. Front Street
P.O. Box 27
Boise, ID 83707

Dear Mr. Prouty:

In a September 28, 2017, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Part 192. Specifically, you requested interpretation of the odorization requirement under § 192.625(f).

You stated the pipeline facility transports biogas that has natural odorizing smell. Therefore, you asked whether Simplot Company must comply with the § 192.625(f) requirements since the gas contains a strong natural odor whose concentration cannot be changed. In addition, in a May 21, 2018, email you provided documentation that describes the pipeline as a 1-mile long, 8-inch diameter biogas plastic (HDPE) intrastate transmission line in a Class 2 location. The document also shows the line operating at a maximum allowable operating pressure (MAOP) of 15 psig or 29.4 percent of the specified minimum yield strength (SMYS).

Section 192.625 does not require transmission pipelines in Class 1 and Class 2 locations to be odorized. Therefore, under the Federal pipeline safety regulations, you are not required to odorize the pipeline.

Please be advised, however, that 49 USC. 60104(c) allows states with a certification under § 60105(a) to adopt additional or more stringent safety standards for intrastate pipeline facilities and intrastate pipeline transportation if those standards are compatible with the minimum standards prescribed by Federal law. Consequently, the State of Washington, which has a certification to regulate intrastate gas transmission pipelines, may have more stringent regulations - including odorization for intrastate transmission lines in all intrastate Class locations which may apply to your pipeline.

If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.

Sincerely,

John A. Gale
Director, Office of Standards
and Rulemaking


Regulation Sections

Section Subject
§ 192.625 Odorization of gas