Part 192, Regulation of a Toxic Gas

The proper title for 49 CFR 192 is “Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards”.  We are likely familiar with Natural Gas, but what about this “Other Gas”?

The definition of gas in 192.3 is “Gas means natural gas, flammable gas, or gas which is toxic or corrosive.”

So what are some of these other gases?  Hydrogen and Carbon Monoxide are two that readily come to mind.  Another, Chlorine, is the subject of today’s interpretation.  PHMSA not only explains why a Chlorine gas pipeline is regulated, but also describes other conditions which make this a transmission line.

Aug 14, 2014

PHMSA Response Letter

Mr. Paul Maguire, P.E.
Manager, Engineering Division
Public Utilities Commission of Nevada
9075 West Diablo Drive, Suite 250
Las Vegas, Nevada 89148

Dear Mr. Maguire:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated    April 15, 2014, you asked whether a chlorine gas pipeline would be regulated under 49 CFR Part 192.  You stated that a manufacturing facility plans to construct a pipeline to transport chlorine gas by pipeline from a chlorine gas production facility to an industrial manufacturing facility.

You stated that both the chlorine production facility and the manufacturing facility are located in an industrial complex.  The manufacturing facility owns the real property on which its plant is located.  The chlorine facility owns the real property on which its plant is located.  A parcel of property owned by a third party is located between the two properties.  The portion of the pipeline that will be built on the third party property is less than 1-mile in length.  You noted that chlorine gas is not “natural gas” or a “hazardous liquid,” and asked if the pipeline is regulated under the Part 192 requirements.

In addition, on May 12, 2014, you emailed the following additional information to my staff:

(1) The total length of the pipeline will be approximately 3,300 linear feet and the length of the pipeline on the third party property will be approximately 2,600 linear feet.
(2) The current plan is to use 8-inch, carbon steel, seamless, schedule 80 pipe and the buried portion of the pipeline will have all welded joints.
(3) There is an existing steel aboveground pipeline built in approximately 1942, and currently transports the chlorine in gas form.  The existing pipeline will be decommissioned as soon as the new pipeline becomes operational.

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 (§192.1).

Section 192.3 defines the term “gas” as natural gas, flammable gas, or gas which is toxic or corrosive.

Chlorine gas is both toxic and corrosive.   In addition, in § 192.1(b) there is no exclusion for the length of the pipeline.  Therefore, the transportation of chlorine gas by pipeline (whether aboveground or underground) is subject to the Part 192 regulations.  The pipeline will transport the chlorine gas off of the grounds of the chlorine production facility across a third party’s property and deliver the gas to the manufacturing facility.  As an industrial user of gas, the manufacturing facility is considered a large volume customer.  Therefore, the pipeline would be regulated as a transmission pipeline.  If the PUC of Nevada has limitations on its ability to assert authority over this pipeline due to the operator not meeting Nevada’s definition of a “public utility” or similar reason, please inform PHMSA’s Director of State Programs who will then coordinate with PHMSA’s Western Region Office as necessary.

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


John A. Gale
Director, Office of Standards and Rulemaking

T:/PHP-30:Interps:Open:Nevada:PI-14-0009-4-21-2014-Part 192

DMS ID# PI-14-0009

 All this and more in WinDOT, The Pipeline Safety Encyclopedia.

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