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Interpretation Response #PI-83-0108

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

Interpretation Response Details

Response Publish Date: 08-05-1983

Location state: MO    Country: US

View the Interpretation Document

Request text:

July 21, 1983
Department of Transportation
Office of Pipeline Safety
400 7th St.
S.W., Washington, D.C.  20270

Dear Sirs:
I am writing you in order to determine if there is a legal maximum hydrogen sulphide content of a natural gas stream to be transported both inter and intra state. Also, are gas distribution systems treated the same?

If you can refer me to proper legislation or guides, please write me at the address below. I currently am aware of NACE MR-01-75 (1978) and DOT paragraph 192.475.

Thank you, in advance, for your cooperation.

Sincerely, yours,

J. B. Haug
Panhandle Eastern Pipe Line Co. Engineering/Design Development P. O. Box 1348
Kansas City, MO  64141

Response text:

August 5, 1983

Mr. J. B. Haug Engineering/Design Development Panhandle Eastern Pipe Line Company P. O. Box 1348
Kansas City, Missouri  64141

Dear Mr. Haug:
Your letter of July 21, 1983, asks if there is a legal maximum hydrogen sulfide content of a
natural gas stream to be transported both inter and intrastate, and if gas distribution systems are
treated the same.

The only legal limitation that we are aware of on the amount of hydrogen sulfide permitted in gas
is the 0.1 grain of hydrogen sulfide per 100 standard cubic feet requirement of Section 192.475(c).
This limitation is only applicable to gas stored in pipe-type or bottle-type holders.

Under the Natural Gas Policy Act of 1978, Section 110 and in the Federal Energy
Regulatory Commission (FERC) Order 24, July 25, 1900, RM 88-47, 18 CFR Part
271.1104, a limit of one grain per 100 cubic feet has been established as a dividing line between
what may be charged against producer costs versus pipeline operator costs. However, this does not
place any limit on the amount of hydrogen sulfide that may be transported by pipeline.

There is no regulatory distinction in the Federal pipeline safety standards for gas distribution
systems relative to hydrogen sulfide content.  Individual States may have additional requirements
for intrastate systems as long as they are not incompatible with the Federal minimum standards.

We hope that this provides the information you need.


Richard L. Beam 
Associate Director for Pipeline Safety Regulation
Materials Transportation Bureau

Regulation Sections

Section Subject
§ 192.475 Internal corrosion control: General