Interpretation Response #PI-18-0012
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Ms. Stacie Campbell-Eckhoff
1186 Lower River Road
Charleston, TN 37310
Dear Ms. Campbell-Eckhoff:
In an April 30, 2018, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Part 192. Specifically, you requested interpretation for the applicability of Part 192 to your pipeline.
You stated that Olin and Wacker own and operate separate portions of a 4-inch diameter, 9,965-foot long (~ 1.9 miles) pipeline in Charleston, Tennessee used to transport chlorine gas from the Olin manufacturing facility to Wacker the customer. You stated that the Wacker-owned portion of the pipeline is a transmission line. Olin owns and maintains 5,240 feet (~1-mile) of the line that is completely within Olin's property line. You stated that just before the end of the Olin portion of the pipeline (where the pipeline transfers to Wacker) there is a manual block valve and directly upstream of the manual block valve there is an automatic shutoff valve that can be operated in the field by an "emergency stop" button or remotely from a central control room by Olin. Also, you mentioned an August 2010 PHMSA interpretation you believe indicates PHMSA does not apply the safety regulations to lines like yours. You asked whether Olin's portion of the line is regulated under Part 192.
Interpretation PI-09-0020, (Illinois Commerce Commission (Aug. 11, 2010)) responded to a request for an interpretation regarding whether "in-plant piping" operated by a large volume customer is subject to the pipeline safety laws and regulations. PHMSA stated that such piping downstream of where pressure control changes from a transmission pipeline operator to a large volume customer would not be subject to the pipeline safety regulations. The August 2010 Interpretation does not apply to your case, however, because Olin is not operating in-plant piping as a large volume customer receiving gas from a transmission line. In this case, the pipeline in question transports chlorine gas (a toxic and corrosive gas) from the Olin manufacturing facility to the Wacker transmission line.
Part 192 prescribes minimum safety requirements for pipeline facilities and the transportation of gas, including pipeline facilities and the transportation of gas within the limits of the outer continental shelf (49 CFR 192.1). In-plant pipelines that are involved in the transportation of gas are subject to the Part 192 regulations. It is the opinion of this office that the Olin owned and operated 5,240-foot pipeline line is involved in the transportation of gas and is subject to the regulations in 49 CFR Part 192.
If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
John A. Gale
Director, Office of Standards
|§ 192.1||What is the scope of this part?|