Interpretation Response #PI-79-0100

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

Interpretation Response Details

Response Publish Date: 02/06/1979

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Location State: OK Country: US

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Response text:

PI-79-0100
February 06, 1979

DEPARTMENT OF TRANSPORTATION
RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION WASHINGTON, D. C. 20590
Mr. Donald E. McCoy
Transportation Safety Institute
6500 S. MacArthur Boulevard
Oklahoma City, Oklahoma 73125

Dear Mr. McCoy:
This is in response to your recent letter asking how much time is permitted under Part 192 to make
system changes (in particular odorization) necessitated by class location changes.

While  §192.613(a)  requires  an  operator  to  make  necessary  changes,  no  time  period  for
compliance is specified.  However, a similar provision under §192.611(c) requires confirmation or
revision  of MAOP  within  18  months  after a change in class location.   In view of this
similarity,  it  appears  that  an  18-month  compliance  period  is  appropriate  to  apply  under
§192.613(a).  In a previous interpretation, we have stated that the 18-month period begins to run
upon completion of a structure which results in a new class location (see May 12, 1978 memo to
DMT-213.)
Sincerely, Cesar De Leon Associate Director for
Pipeline Safety Regulation
Materials Transportation Bureau
Mr. Cesar DeLeon, Associate Director
Office of Pipeline Safety Regulations Materials Transportation Bureau Washington, D. C.  20590

Dear Mr. DeLeon:
The purpose of this letter is to request your office's interpretation concerning CFR 49, paragraph
192.625(b) regarding the odorization of natural gas in transmission lines. The question is as
follows:
Suppose a transmission operator is not odorizing the gas in a segment of his pipeline system  
because  the  segment  met  the  class  location  exemption  allowed  by either paragraph
192.625(b)(1) or 192.625(b)(3).  If the operator were to detect a class location change (i.e., from
Class 1 or 2 to Class 3 or 4) when performing the surveillance procedures required by paragraph
192.613(a), what period of time is he allowed under the regulations to accomplish the physical
system changes necessary to now odorize the gas?  Moreover, is this period of time measured from
when the class locations actually changed or from when the operator detected the change in class
location?

Your assistance in clarifying this question is appreciated.
Your very truly, Donald E. McCoy
Pipeline Safety Specialist

Regulation Sections