{"operation":"document","citation":"PI-007-2012","title":"Southern LNG Company LLC — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2012-08-21","effective_on":null,"summary":"PI-007-2012 response to Southern LNG Company LLC concerning 193.2051.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-007-2012.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-007-2012.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-007-2012","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/Pipeline/2012/Southern%20LNG-PI-0007-08-21-2012-Part%20193.2051.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nMr. William G. Cope\nVice President, Operations\nSouthern LNG Company LLC\n569 Brookwood Village. Suite 501\nBirmingham, AL 35209\nDear Mr. Cope:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA). Southern\nLNG Company. LLC (SLNG) requested a written interpretation concerning 49 CFR 193.2051.\nSpecifically, SLNG asked whether an increase in the unloading flow rate at an existing liquefied\nnatural gas (LNG) facility would be considered a \"significant alteration\" under § 193.2051. A\n''significant alteration\" to the facility would require revision of SLNG's calculations and\nmodeling to satisfy the siting requirements of Subpart B of Part 193. SLNG believes such a\nchange would not count as a significant alteration because the increase in flow rate would not\nrequire the replacement or modification of facilities. The only changes to the facility would be\nthe increase in flow rate and the resulting increase in operational pressure. This change m\noperational pressure would be within the pipeline system's design pressure limits.\nPHMSA agrees that because this operational change is within the original design parameters and\nthe facility would not require any further modification, an increase in flow rate would not be a\nsignificant alteration and the siting requirements of§ 193.2051 and Subpart B of Part 193 would\nnot be triggered.\nI hope that this information is helpful to you. If I can be of further assistance, please contact me\nat 202-366-4046.\nn\nDirector. Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration. OtTice of Pipeline Safety provides written clarifications of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requestmg the clarification. Interpretations do not create legally-enforceable nghts or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\nAPR 18 2011\n~-t{-oDD' l\ne A P ISouthern\nLNG\nan El Paso company\nApril 15, 2011\nMr. Jeffrey D. Wiese\nAssociate Administrator for Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEast Building, 2\"d Floor, Mail Stop: E24-455\n1200 New Jersey Avenue, SE\nWashington, DC 20590-000 I\nRe: Request for Written Interpretation of Southern LNG Company, LLC\nIncrease in Terminal Unloading Rate\nDear Mr. Wiese:\nSouthern LNG Company, LLC (\"'SLNG\") is requesting a written interpretation from the U.S. Department\nof Transportation (\"DOT\") as allowed in 49 CFR Part 190.1 L regarding Section 49 CFR Part 193.2051 of\nthe DOT Regulations regarding Federal safety law for LNG Terminals. SLNG is the operator under Part\n193 of the Elba Island LNG Terminal (\"'Elba Terminal\") near Savannah, Georgia. SLNG recently\ncompleted an expansion of the Elba Terminal CEiba Ill Expansion\") with the addition of a 200,000m'\ntank (D-5), boil-off gas (BOG) handling facilities, send out equipment and LNG transfer line from the\nNorth Unloading Dock effective July I, 20 I 0. Approval for constructing this work was received from\nFERC in an order dated September 20, 2007 in Docket Nos. CP06-470, et al. The expansion facilities\ncomply with the DOT regulations under the 49 CFR Part 193.2051. 2002. requirements for siting.\nNow that the Elba Ill Expansion is complete, the Elba Terminal is capable of unloading two ships either\nsimultaneously or separately. The Elba Ill Expansion provided the Elba Terminal with dual unloading\nlines and automated valves for selecting the flow path to the storage tanks. Typically. a cargo is either\nsplit between D-1 /2/3/4 using line 36\"-LNG-150-1 003 or sent in its entirety to D-5 tank through line 36\"LNG-150-1\nI 02. The Elba Terminal relies on program controls for valve set-up and tlowrate alarms to\nensure that the maximum tlowrate for a tank is not exceeded. In combination. tanks D-1 /2/3/4 are\ndesigned to handle the increased tlmvrate of 62,000 gpm: l10wever the flow going into tank D-5 is limited\nto 50.000 gpm. Therefore, the maximum flowrate for unloading two ships simultaneously is 112,000\ngpm. If two ships are off-loaded simultaneously. either berth could be used to unload at the 62.000 gpm\nrate but the other berth would off-load at the 50,000 gpm rate.\nSLNG proposes to decrease the unloading time for large LNG carriers by increasing the unloading rate\nfrom 50,000 gpm to 62,000 gpm. Such increase in unloading rate will reduce the time needed to unload\nthe larger carriers by 19%. SLNG does not generally plan to use the higher unloading rate except when it\nreceives the larger Q-max ships. The ability for SLNG to receive the larger ()-max ships at the Elba\nTerminal was approved by the U.S. Coast Guard in its Letter of Recommendation dated October I 0,\n2008.\nSouthern LNG\nColonial Brookwood Center\n569 Brookwood Village. Suite 501 Birmingham, Alabama 35209\nPO Box 2563 Birmingham, Alabama 35202.2563\ntel205.325.7410\n\n<<<PAGE 3>>>\n\nMr. Jeffrey D. Wiese\nApril 15.2011\nPage 2\nThe current and new unloading lines at the Elba Terminal are designed for 220 psig. An independent\nengineering firm conducted a study to evaluate the hydraulics and surges due to the increased flow rate\npressure and abnormal shutdowns. The highest peak pressure is predicted to be about 163.5 psig which is\nbelow the design pressure of 220 psig. The study indicates there is no need for any modifications or\nchanges to the piping system to accommodate the increased flow rate to 62,000 gprn and corresponding\nincrease in ptpmg pressure.\nIn addition, SLNG has more than adequate containment for a guillotine cut of the largest branch line\nwhich is a 12-inch line. In the event of a 10 minute spill from a guillotine cut ofthe largest branch line at\n62.000 gpm, the required containment volume would be 42,134 ft1 Even in the event of a 10 minute spill\nfrom a guillotine cut of the 42-inch unloading line at 62,000 gpm, the required containment volume\nwould be 122,533 ft3\n. Retention Area # 1 is approximately 150,000 fr\"' so it meets the test for adequate\ncontainment for a worst case scenario on even the largest downstream line.\nAccording to 49 CFR Part 193.2051 ''Each LNG facility designed, constructed, replaced, relocated or\nsignificantly altered after March 31. 2000 must be provided with siting requirements in accordance with\nthe requirements ofthis part and ofNFPA 59A .. .''\nThe purpose of this request for a written interpretation is to confirm SLNG 's interpretation of the DOT\nRegulations that the proposed increase in the unloading rate from 50,000 gprn to 62,000 gpm would not\nbe considered to be a ''significant alteration,'' and thus would not require any revisions to its calculations\nor modeling for siting purposes as required in 49 CFR Pati 193.2051. Because SLNG does not have to\nmake any facility modifications or change the design of the facilities, SLNG believes that this operational\nchange in flow rate does not manifest itself to be a significant alternation under the DOT Regulations.\nPlease advise us that our interpretation is correct or provide us with any feedback if you do not agree with\nthis interpretation. If you have any questions, please contact Steve Heard, LNG Terminal Manager at\n(912) 944-3806 or ~eve~bea.r~l 1lJelpaso.com.\nWe thank you for your guidance in this matter.\nVery truly yours,\nSouthern LNG Company,\nWilliam G. Cope\nVice President Operations","truncated":false,"body_characters":7618}