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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-17-0017

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

Interpretation Response Details

Response Publish Date:

Company Name: G2 Integrated Solutions

Individual Name: Mr. John A. Jacobi

Location State: TX Country: US

View the Interpretation Document

Response text:

December 7, 2017

Mr. John A. Jacobi
Vice President and Principal
G2 Integrated Solutions
10850 Richmond Avenue, #200
Houston, TX 77042

Re: Petition for Finding

Dear Mr. Jacobi:

On June 28, 2017, pursuant to 49 C.F.R. § 190.9, G2 Integrated Solutions, on behalf of Olin Pipeline Services (G2) filed a petition for a finding or approval (Petition) to use its proposed methodology to calculate the Potential Impact Radius (PIR) of non-flammable gas anhydrous hydrogen chloride (HCL). Specifically, G2 requested a finding allowing the use of the PIR factor published by Pipeline and Hazardous Materials Safety Administration (PHMSA) in TTO-13 for hydrogen, the urban setting PIR for chlorine published in TTO-14, and the TTO-14 protocol to calculate the PIR factor for the urban setting for anhydrous HCL. The resulting PIRs would then be used to identify Part 192 High Consequence Areas using 49 CFR § 192.903, Method 2.

Section 190.9 provides that in circumstances where a rule contained in parts 192, 193 and 195 of the pipeline safety regulations authorizes the Administrator to make a finding or approval, an operator may petition the Administrator for such a finding or approval. The petition must refer to the rule authorizing the action sought and contain information or arguments that justify the action.

Having reviewed G2's request, PHMSA has determined that it does not meet the requirements set forth in § 190.9 for a petition for finding or approval, because G2 has failed to identify a rule authorizing the action sought. The integrity management regulation cited, § 192.903, does not authorize the Administrator to make a finding or approval with respect to using alternative means to calculate PIR. Rather the regulation specifies how PIR must be calculated for the purpose of identifying high consequence areas.

If you have any questions or would like to discuss further, please contact Tewabe Asebe at 202-366-5523.



John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.903 What definitions apply to this subpart?