Safety Regulation for Small LPG Distribution Systems (2018) / Chapter Skim
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1 Summary Propane and other types of liquefied petroleum gas (LPG) are important fuels for homes and businesses that do not have access to natural gas service.
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2 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS (CFR) Title 49, Part 192, Transportation of Natural and Other Gas by Pipeline (herein referred to as "Part 192")
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SUMMARY 3 corresponding NFPA requirement. Some of these Part 192 requirements are highly targeted and prescriptive, such as a stipulation to use an instrument to test for odorant in gas, while others contain broader mandates, such as a requirement for the development and maintenance of an integrity management program and emergency response plan.
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4 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS Transportation Safety Board and the U.S. Chemical Safety and Hazard Investigation Board.
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SUMMARY 5 apparently not being identified as jurisdictional and actively compelled by regulators to follow the Part 192 requirements, one might reason that LPG industry claims about the inapplicability of these federal requirements to ensuring the safety of small systems are valid. The committee did not reach this specific conclusion because of the shortage of information on the number of these small systems, their risk characteristics, and their actual level of regulatory compliance.
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6 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS 1. Responses to the NAPSR questionnaire by state pipeline safety regulators suggest that many small, multi-user LPG systems that should be subject to the federal Part 192 pipeline safety regulatory requirements -- that is, "jurisdictional" -- are not being identified by enforcement programs, and thus are not being regularly inspected for compliance with these federal requirements.
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SUMMARY 7 Recommendation 1: Congress should direct PHMSA to ensure that the regulatory term "public place" is defined in such a way that regulators and regulated entities alike will uniformly interpret that definition to establish jurisdiction over LPG pipeline systems under CFR Title 49, Part 192, Transportation of Natural and Other Gas by Pipeline. Recommendation 2: Congress should direct PHMSA to require • Operators of LPG pipeline systems to report to regulators the location and number of customers served by each of their jurisdictional systems; and • States to confirm that all identified jurisdictional systems are subject to regular enforcement and inspection activity, which should include a review of operator-reported data on leaks and damage.
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8 SAFETY REGULATION FOR SMALL LPG DISTRIBUTION SYSTEMS ment to perform such inspections of operator-identified systems on a regular basis should increase the state regulators' familiarity with the characteristics, conditions, and safety performance of the LPG systems, which in turn will assist states and PHMSA in making more risk-informed determinations of regulatory requirements that are most suitable to small LPG systems and deserving of enforcement attention. The recommended authorization of a waiver program is intended to allow states and PHMSA to make such riskinformed determinations about regulatory application and enforcement, as opposed to determinations that are based simply on system size.
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