Comment from Anonymous

Comment for Docket PHMSA-2025-0112 - Part 192.3 - Definitions for In-plant piping system PHMSA is recommended to add the words noted in "..." in the below paragraph to add flexibility for the type of control, isolation, or whether plant or pipeline control (pressure or flow) or isolation valve is used. Sometimes the pipeline and plant systems will have the same maximum operating pressures, so a control valve is not needed and a normal isolation valve is used. Also, the change of facility type may change at piping or flanges near the flow control, pressure control, or isolation mainline valve. In-plant piping system means piping that is located on the grounds of a plant and used to move gas between plant facilities or between plant facilities and a pipeline or other mode of transportation, not including any device “or valve” and associated piping that are necessary to control pressure “or gas flow” in a pipeline. The point of demarcation between a pipeline and an in-plant piping system is the inlet of the pressure control device “or valve and associated piping” if the pipeline is moving gas out of the plant or the outlet of the pressure control device “or valve and associated piping” if the pipeline is moving gas into the plant. If there is no such pressure "or flow" control device located on the grounds of the plant, an in-plant piping system extends to the plant boundary “or to the pipeline valve and associated piping located inside the plant and near the plant boundary.”