{"operation":"document","citation":"PI-01-002","title":"Tennessee Regulatory Authority — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-08-17","effective_on":null,"summary":"PI-01-002 response to Tennessee Regulatory Authority concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-002.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-002.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-002","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/01-08-17_%20Blanton_192%203_Transmission.pdf","body":"<<<PAGE 1>>>\n\nU.S.Department of Transportation\n400 Seventh Street, S,W, Washington, D.C. 20590\nResearch and Special Programs Administration\nMr. Glynn Blanton\nChief, Gas Pipeline Safety Division\nTennessee Regulatory Authority\n460 James Robertson Parkway\nNashville, TN 37243\nDear Mr. Blanton:\nThis refers to your enclosed letter of January 22, 2001, in which you ask whether the\nStone Mountain Pipeline Company (Stone Mountain) project, as described below, is\njurisdictional to our agency.\nAccording to the information provided, Stone Mountain currently has 63 miles of\npipelines extending from Kentucky to Virginia which the Federal Energy Regulatory\nCommission (FERC) regards as a gathering system and does not regulate. However,\nStone Mountain has started a project which will add a ten-inch pipeline from the south\nend of the ten-inch Martins Fork to Rose Hill pipeline to a proposed Rogersville\nCompressor Station .. This pipeline will be used to deliver gas gathered from many fields,\nthrough as many as 62 wells, into the East Tennessee system at an interconnection\ndownstream of the Rogersville Compressor Station, East Tennessee will build a lateral to\nthe proposed site of the interconnection pursuant to its blanket authority from FERC.\nAccording to Stone Mountain, some of the lines feeding into the ten-inch pipeline will be\nseveral miles long and will act as \"backbone\" pipelines that will collect gas from\nnumerous feeding lines along their length.\nOnshore gathering lines are not subject to 49 CFR Part 192 if they lie outside of the limits\nof an incorporated or unincorporated city, town, or village or any designated residential\nor commercial area. Assuming that the Stone Mountain project will lie entirely outside of\nthese areas, the issue is whether the ten-inch pipeline that is being constructed between\nRose Hill, Virginia, and the proposed Rogersville Compressor Station, is classified as a\ngathering line or a transmission line.\n49 CFR. § 192.3 explains that a gathering line ends at a transmission line, and a\ntransmission line is a pipeline that transports gas from a gathering line to a distribution\n\n<<<PAGE 2>>>\n\ncenter, storage facility or large volume customer that is not downstream from a\ndistribution center.\nAccordingly, the Office of Pipeline Safety (OPS) historically has selected the appropriate\nend point on a case-by-case basis, primarily using four points. These four points include\n(I) the outlet of a processing plant; (2) ifthere is no upstream processing plant, the outlet\nof a main compressor; (3) if there is no processing plant or compressor station, then the\npoint where two or more well lines converge; and ( 4) if no other point is appropriate, the\npoint where there is a change in ownership of the pipeline. In addition, once designated\nas a transmission line, no portion of the line may be redesignated as a gathering line even\nif further commingling of gas occurs downstream.\nStone Mountain believes that FERC will continue to classify their entire system as a\ngathering system. However, OPS is not bound by FERC's classification of gathering lines\nunder the Natural Gas Act (15 U.S.C. § 717 et seq.), 49 U.S.c. § 60101 (b)(I)(B)(ii),\nThis. means that although FERC may continue to classify the Stone Mountain system as\na gathering system, OPS is not required to do so.\nAlthough the Stone Mountain project clearly does not contain a processing plant, it will\nhave three compressor stations, located at Martins Fork and Rose Hill, Virginia, and\nRogersville, Tennessee. As used in our four-point test, a main compressor is one that has\nthe main function of moving gas in transportation even if it also enhances the production\nprocess. Because the Rose Hill Compressor Station is not currently being used to gather\ngas from the existing upstream facilities, it appears that it will be used to move gas\nthrough the proposed ten-inch line from Rose Hill to Rogersville. Therefore, this is the\nlast logical end point far the gathering line and, therefore, the point at which the\ntransmission line begins. Because this line becomes a transmission line no further\ndownstream than Rose Hill, Virginia, it cannot be redesignated a gathering line in\nTennessee, even if it receives additional gas from other gathering lines.\nThe Stone Mountain ten-inch pipeline from Martins Fork to Rose Hill and continuing to\nthe Rogersville Compressor Station is expected to receive and commingle gas from as\nmany as 62 wells located in multiple fields. Moreover, this line currently serves four\nmarket delivery points, including a federal prison, and Stone Mountain anticipates an\nadditional delivery point to the Hawkins County Utility District, The ten-inch pipeline\nappears to be transporting gas from the incoming gathering lines to its delivery points\nand, finally, to the East Tennessee interconnect. Therefore, OPS characterizes the ten-\ninch line from the proposed Rose Hill Compressor Station to the proposed Rogersville\nCompressor Station as a transmission line.\nInterstate transmission lines are subject to the jurisdiction of OPS. Intrastate transmission\nlines are subject to the jurisdiction of the state under its Section 60105 certification.\nAccording to 49 U.S.C. § 60101 (a), an interstate pipeline must be subject to the\njurisdiction ofFERC under the Natural Gas Act and intrastate pipelines are not subject to\nthe jurisdiction of FERC. Therefore, the determination of whether this is a interstate or\nintrastate pipeline is based on whether FERC has jurisdiction over the pipeline. Because\n\n<<<PAGE 3>>>\n\nthis segment is not certificated by FERC, it is an intrastate transmission line and,\ntherefore, it is subject to jurisdiction by the Tennessee Regulatory Authority under its\nSection 60105 certification.\nIf we can be of further assistance in this matter, please contact me at (202) 366-4565.\nSincerely yours,\nRichard D. Huriaux, P.E. Manager, Regulations Office of Pipeline Safety\nEnclosure\nBILLING CODE 491O-60-P","truncated":false,"body_characters":5964}