Please be aware of the following requirements for measuring and documenting the amount of odorant in LP-Gas for jurisdictional propane systems in Maine:
Chapter 421 § 5(B) of the Maine Public Utilities Commission Rules requires that the presence of odorant in LP-Gas distribution systems is determined, and the results documented upon delivery to system storage containers, or when LPG is loaded into the containers of delivery vehicles at a bulk facility.
This State regulation establishes the requirement to document the presence of odorant, and to do so either at bulk facilities or upon delivery to customer containers.
Jurisdictional propane systems are also subject to the federal requirements of 49 CFR, Part 192. Part 192.625 covers odorization of gas. This federal subsection requires that LP-Gas is odorized so that a concentration in air of one-fifth of the lower explosive limit can be detected by a person with a normal sense of smell. This federal subsection also requires that the odorant level is verified with an instrument capable of determining the percentage of gas in air at which the odor becomes readily detectable. While stain tubes, sniff tests, and other methods can help technicians determine that odorant is present in the LP-Gas, the federal code language means that the only acceptable method of determining that the correct odorant concentration is present is a tool that can measure the percentage gas in air where the odorant is detectable
During the September, 2016 LP Operator Training at the Maine Public Utilities Commission office in Hallowell, and during the 2016 and 2017 MEMA Propane Operators Summits, Gas Safety Staff presented information about these requirements and expressed the Staff’s intent to spot-check jurisdictional operators’ good faith compliance efforts by ensuring that operators were making a reasonable effort to utilize the required equipment, document the results of the measurements, and select sampling locations and frequencies that were appropriate to their specific operating characteristics. Gas Safety Staff used an example of quarterly samples, taken at bulk plants, as potentially appropriate for a medium to large size operator.
In September, 2018, the U.S. Department of Transportation, Pipeline Hazardous Materials Safety Administration (PHMSA), issued interpretation PI-18-0002, on the subject of § 192.625, and directly related to your question. I have attached a copy of the interpretation to this email. The interpretation provides additional detail on this issue and gives PHMSA’s views on the appropriate location at which instrument sampling must occur. Some pipeline safety jurisdictions in New England may be choosing to strictly enforce the propane odorization requirements according to this interpretation.
While we are providing this requested information on odorant sampling, we wanted to take the opportunity to bring up another compliance issue that may also be important to your membership.
49 CFR 192.285(c), which applies to jurisdictional propane systems, requires that personnel making plastic pipe joints by any method must be qualified once each calendar year at intervals not exceeding 15 months. Personnel must also be requalified if a production joint fails a pressure test. Based on field inspections and conversations with propane operator personnel, it appears that the current “OQ” interval for pipe joining in the LP-Gas community may be 3 years. While in some cases, the training programs for pipe joining may be appropriate for delivery every 3 years, to achieve compliance with 192.285, operator personnel making plastic pipe joints must make a specimen joint for each applicable procedure that passes an inspection and test at a minimum once each calendar year (not to exceed 15 months).