{"operation":"document","citation":"PI-09-0013","title":"Pipeline Safety Interpretation PI-09-0013","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-06-02","effective_on":null,"summary":"PI-09-0013 concerning 193.2401.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0013.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0013.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0013","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2009/PI-09-0013.pdf","body":"<<<PAGE 1>>>\n\nu.s. Department\nof Transportation\nPIpeline and Hazardous\nMaterials Safety\nAdminlstratfon\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nJUN - 2 2009\nMr. Eric Amundsen\nVice President, Technical Services\nPanhandle Energy\n5444 Westheimer Road\nHouston, TX 77056\nRef. No. PHP08-00 16\nDear Mr. Amundsen:\nOn February 6, 2009, you wrote to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA) on behalf of Trunkline LNG Company, LLC (TrunkIine) to request an interpretation of\nPHMSA's safety regulations on liquefied natural gas (LNG) facilities in 49 CFR Part I 93 for the\ndesign, manufacture, installation, and sizing of relief valves that protect remotely heated vaporizers\nat Trunkline's new LNG vaporization facility in Lake Charles, Louisiana. Current pipeline safety\nregulations require the operator of each LNG vaporization facility to comply with NFPA Standard\n59A (2001 edition), which is incorporated by reference in § 193.2013.\nPHMSA is pleased to provide Trunkline with this clarification regarding your inquiry. We\ninterpret § 193 .240 1 to require that vaporizer safety relief valves comply with all provisions in the\nNFPA 59A standard including but not limited to Chapters 1,5, 12, Section 5.2.1, and Section\n5.4.1 (a). Accordingly, Trunkline must design, size, install, operate, and maintain vaporizer safety\nrelief valves with a maximum pressure accumulation that is consistent with the NFPA standard\n59A, the ASME Boiler and Pressure Vessel Code (1992 edition), Section VIII, Division 1 (which\nis incorporated by reference in NFPA 59A), as well as 49 CFR Part 193. Where a conflict exists\nbetween NFP A and ASME with respect to vaporizer safety relief valves, the incorporated NFP A\nstandard prevails.\nI hope that this infonnation is helpful to you. If I can be of further assistance, please contact me\nat (202) 366-3015.\nSincerely,\n(;)~ )Lx /aJ\nJohn k.1Ialer/ /VZv\nDirector, Office of Regulations\nT Asebe:jrnd:64046:05127 108\ncc:PHP-30:PHP- I 00-500:TQ: Webpage:Official File\nT:PHP-30:Interps:Trunkline\n\n<<<PAGE 2>>>\n\nHouston, TX 77056~5306\n~Yrt~ Trunkline LNG 5444 Westhelmer Road\nPO, Box 4967\nA Southem Union Company\nHouston, TX 77210-4967\n713,989,7000\nFebruary 17,2009\nMr. Jeffrey Wiese\nAssociate Administrator\nOffice of Pipeline Safety (PHP-30)\nPHMSA\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nDear Mr. Wiese:\nRe: Request for Interpretation\nPursuant to the availability of guidance and interpretive assistance described in 49 CFR\n190.11 (b), Trunkline LNG (TLNG) requests the concurrence of the Pipeline and Hazardous\nMaterials Administration (PHMSA) that TLNG's interpretation ofa particular code requirement\nregarding relief valve capacity is correct.\nTLNG is in the final stages of construction leading toward commissioning of new facilities that\nadd to the capacity and efficiency of its LNG tenninal near Lake Charles, Louisiana. It is\nrequired by 49 CFR 193.2101 that these new facilities must comply with the requirements of Part\n193 and ofNFPA 59A. During an inspection of the construction project by the FERC, the staff\nquestioned the apparent capacity of the vaporizer relief valves. As a result of subsequent\ndiscussions and the submittal of a detailed engineering analysis regarding the relief valve sizing,\nFERC requested that TLNG seek concurrence from PHMSA on its regulatory and engineering\nbasis for the reliefvalve sizing. Two particular sections ofNFPA 59A are relevant and are\nreproduced below.\n1.2 Nothing in this standard is intended to prevent the use of systems, methods, or\ndevices of equivalent or superior quality, strength, fire resistance, effectiveness,\ndurability, and safety over those prescribed by this standard.\n5.4.1 Each vaporizer shall be provided with a safety reliefvalve(s) sized in accordance\nwith either of the following requirements.\n(a) The relief valve capacity of heated or process vaporizers shall be such that\nthe relief valve(s) discharges 110 percent of rated vaporizer natural gas flow\ncapacity without allowing the pressure to rise more than 10 percent above\nthe vaporizer maximum allowable working pressure.\n(b) The relief valve capacity for ambient vaporizers shall be such that the relief\nvalve(s) discharges at least 150 percent of rated vaporizer natural gas flow\ncapacity (as specified for standard operating conditions) without allowing\nthe pressure to rise more than 10 percent above the vaporizer maximum\nallowable working pressure.\n\n<<<PAGE 3>>>\n\nThe safety system analysis and design for the LNG vaporization process incorporates provisions\nand safety features that minimize the relief valve capacity requirements in the event of an upset\ncondition. This total system approach produces an equivalent level of protection as would be\nprovided by strict incorporation of the requirements ofNFPA 59A § 5.4.1. The applicable\ncalculations were conducted in accordance with API 521 - Guide for Pressure-Relieving and\nDepressuring Systems. The materials designed and installed for this overpressure protection\nservice are of equivalent quality, strength, fire resistance, effectiveness and durability as would\nhave been provided by larger relief valves and vent systems. The system design provides optimal\nservice by minimizing the relief valve capacity requirement thus minimizing the amount of\nfugitive emissions in the event of activation. This design also minimizes the sizing of the vent\nsystem and conserves resources so required.\nThe vaporizers use a potassium formate heat transfer fluid to vaporize the LNG. This fluid is\nthen rewarmed by passing through ambient air heat exchangers. While the maximum rated flow\nrate through the vaporizers is on the order of 1,000,000 lb/hr, studies and analysis of conditions\nunder which pressure relief could conceivably be required showed the maximum relieving\ncapacity requirement to be 100,000 Iblhr. This is a \"blocked in\" case. A thorough review and\nconsideration of other scenarios led to this conclusion. Those studies, calculations and results are\ndetailed in the attached document, which has also been provided to your technical staff.\nStandard analytical methods were used. TLNG concluded that sizing the relief valves for the\nmaximum relief requirement rather than based on a flow rate is an acceptable method and results\nin an equivalent level of safety, and is therefore consistent with the provisions ofNFPA 59A\n§ I .2, cited above.\nTLNG respectfully requests PHMSA consideration and concurrence in that interpretation. In\naddition to providing the technical information to your staff, it has also been provided to the\nFERC. We are available to answer any additional questions you may have on this matter or to\nmeet with you or your representatives. TLNG also requests that this review and interpretation be\nexpedited to the extent possible, as these facilities need to be commissioned within approximately\nthe next three months. The FERC staff has indicated they are relying on PHMSA's resolution of\nthis matter before they issue the operating permit.\nYou may contact me at any time at the above address, by telephone at 713.989.7460 or by email\nat Eric.Amundsen@sug.com.\nThank you for your consideration.\nEric J. Amundsen\nVice President, Technical Services\nEne!.\nCc: R. Seeley - PHMSA\nJ. Jacobi - PHMSA\nA. Mayberry - PHMSA\n20f2\n\n<<<PAGE 4>>>\n\n%'''\\\nTrurikline LNG\n5444 Westhemler Road\nHouston, TX 77056,5306\nPO Box 4967\nHouston, TX 772104967\n713,989,7000\nCONTAINS \"CEIl\"\n(DO NOT RELEASE)\nDecember 22, 2008\nVia e-Filing\nMs. Kimberly D. Bose, Secretary\nFederal Energy Regulatory Commission\n888 First Street, N.E.\nWashington, D.C. 20426\nRe: Infrastructure Enhancement Project (IEP)\nDocket No. CP06-102-000\nFERC Data Request OEP/DG2EILNGC\nDear Ms. Bose:\nEnclosed herewith for filing with the Federal Energy Regulatory Commission\n(\"Commission\") is Trunkline LNG Company, LLC's (\"Trunkline LNG\") response to the\nCommission's December 1,2008 request related to the IEP Construction Inspection in the subject\nproceeding. Pursuant to the Commission's Filing Guide dated June 24,2008, Trunkline LNG\nsubmits herewith this transmittal letter and data response identified as \"PUBLIC\" information.\nIn addition, under separate cover is this transmittal letter and data response with Attachments\nidentified as \"CRITICAL ENERGY INFRASTRUCTURE INFORMATION\" (\"CEIl\").\nTrunkline LNG respectfully requests that only the information submitted as \"Public\" be\nplaced on the internet\nAny questions regarding this submittal should be directed to the undersigned.\nRespectfully submitted,\nTRUNKLINE LNG COMPANY, LLC\n/s/ Stephen T Veatch\nBy ________________________ __\nStephen T. Veatch\nSr. Director, Certificates and Tariffs\nEnclosures\ncc wlEnc: Mr. Andrew Kohout (FERC)\ncc wlo Enc: Mr. Chris Zerby (FERC)","truncated":false,"body_characters":8786}