{"operation":"document","citation":"PI-01-0102","title":"Washington Utilities and Transportation Commission — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-02-15","effective_on":null,"summary":"PI-01-0102 response to Washington Utilities and Transportation Commission concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0102.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0102.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-01-0102","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2001/g01-02-15_Lloyd_192.3_Transmission_Line-nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-01-0102\nFebruary 15, 2001\nMr. Dennis E. Lloyd\nPipeline Safety Division\nWashington Utilities and Transportation Commission\n1300 S. Evergreen Park Drive, S.W.\nOlympia. WA 98504-7250\nDear Mr. Lloyd:\nThank you for your letter of December 14, 2000, (Ref. No. 4-1319), regarding the definition of\ntransmission pipelines in 49 CFR § 192.3 and the application of this definition to gas pipelines\nserving industrial facilities.\nSpecifically, you ask whether a 10-inch intrastate natural gas pipeline connecting a transmission\nline directly to the Fort James paper mill in Camas, Washington meets the definition of\ntransmission line. The company claims that this line is not a transmission line (and therefore not\nsubject to the pipeline safety regulations) because it operates at less than 20% of specified\nminimum yield strength.\nYour staff reviewed the definition of transmission lines at 49 CFR § 192.3 and the preamble of\nthe most recent change in this regulation (June 6, 1996; 61 FR 28770) and concluded that the\nbypass gas line serving Fort James is a transmission line.\nThe plain language of the regulation at § 192.3 is as follows:\nTransmission line means a pipeline, other than a gathering line, that;\n(a) Transports gas from a gathering line or storage facility to a distribution center, storage\nfacility, or a large volume customer that is not downstream from a distribution center;\n(b) Operates at a hoop stress of 20 percent or more of SMYS; or\n(c) Transports gas within a storage field.\nA large volume customer may receive similar volumes of gas as a distribution center, and\nincludes factories, power plants, and institutional users of gas.\nIf a company meets any one of these three conditions, it is a transmission line. Fort James is a\nfactory, which is clearly a large volume customer. The fact that the pipeline operates at less than\n20 percent of SMVS does not negate this fact.\nThis conclusion is supported by the language of the Final Rule issued June 6, 1996 (61 FR\n28770), which states in the preamble that:\nA long-standing RSPA interpretation holds that the definition of “transmission line ” in\n§ 192.3\n\n<<<PAGE 2>>>\n\nencompasses lines that link gathering lines or transmission lines to large volume customers, such\nas factories or power plants…Given our long-standing interpretation and the ASME B3 1.8 code\ndefinition, we find it reasonable to add “large volume customer” to the definition of transmission\nline…\nTherefore, we concur with your conclusion that the Fort James gas pipeline is a transmission line\nand is subject to the pipeline safety regulations under 49 CFR Part 192.\nIf you require farther information on this issue, please contact me at (202) 366-4565.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety","truncated":false,"body_characters":2790}