{"operation":"document","citation":"PI-11-0013","title":"New Mexico Gas Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2023-03-13","effective_on":null,"summary":"PI-11-0013 response to New Mexico Gas Company concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-11-0013.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-11-0013.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-11-0013","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/77146/new-mexico-gas-company-pi-11-0013-05-22-2012-part1923.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMAY I I 2012\nMs. Deborah Brunt P.E.\nDirector, Engineering\nNew Mexico Gas Company\nP.O. Box 97500\nAlbuquerque, NM 87199-7 500\nDear Ms. Brunt:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you asked\nfor interpretation regarding classification of your pipelines. Specifically, you asked whether the\nfollowing four pipelines are transmission or distribution lines.\nYour Intel VHP line originates at a regulator station on your Alameda transmission line in the\nmiddle of your Albuquerque Metro distribution center. The Alameda transmission line operates\nabove 20 percent of the specified minimum yield strength (SMYS) at a gauge pressure of 466\npound per square inch gauge (psig) and the Intel VHP line operates at 175 psig at 5.9 percent of\nSMYS. The Intel VHP line delivers gas to the Albuquerque Metro 60 psig distribution system\nand to the Intel factory (a large volume customer). All of the gas that travels through the\nAlameda transmission line and the Intel VHP line is delivered to customers who purchase the gas\nfor consumption. You believe that the Intel VHP line is a distribution line because it delivers gas\ndownstream of the Albuquerque distribution center and does not operate at a hoop stress of\n20 percent or more of SMYS.\nYour Santa Fe south feed line originates at a regulator station on your Santa Fe transmission line\non the south side ofyour Santa Fe distribution center. The Santa Fe transmission line operates at\nabove 20 percent SMYS at 600 psig and the Santa Fe South feed line operates at 250 psig or 18.8\npercent ofSMYS. The Santa Fe south feed line delivers gas to the Santa Fe 60 psig distribution\nsystem. All ofthe gas that travels through the Santa Fe South feed line is delivered to customers\nwho purchase it for consumption. You believe that the Santa Fe south feed line is a distribution\nline because it delivers gas downstream of the Santa Fe distribution center and does not operate\nat a hoop stress of 20 percent or more of SMYS.\nYour Gallup east feed starts at the East El Paso Natural Gas transmission line at the Gallup city\ngate station. The transmission line operates at 300 psig or 13.7 percent of SMYS. The Gallup\nEast feed delivers gas to the Gallup 60 psig distribution system. All of the gas that travels\nthrough the Gallup east feed is delivered to customers who purchase it for consumption. You\nbelieve that the Gallup East feed line is a distribution line because it delivers gas downstream of\nthe Gallup distribution center and does not operate at a hoop stress of 20 percent or more of\nSMYS.\nThe Pipeline and Hazardous Materials Safety Administration. Office 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 ofthe regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-entorceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nYour Ambrosia Lake line originates at a regulator station on the Grants transmission line on the\nnorth side of your Grants distribution center. The Grants transmission line operates at above 20\npercent SMYS of 720 psig and the Ambrosia Lake line operates at 180 psig or 10.1 percent\nSMYS. The Ambrosia Lake line delivers gas to the Grants 50 psig distribution system and to\nseveral farm taps. All ofthe gas that travels through the Ambrosia Lake line is delivered to\ncustomers who purchase it for consumption. You believe that the Ambrosia Lake line is a\ndistribution line because it delivers gas downstream ofthe Grants distribution center and does\nnot operate at a hoop stress of 20 percent or more of SMYS.\nWe contacted you with a request to provide us with mileage information of these pipelines and\nyou responded with an October 12, 201 L email. Also, we were able to get the information from\nthe New Mexico Public Regulation Commission. The responses regarding the pipelines are as\nfollows:\nThe Intel VHP line begins at a regulator station on New Mexico Gas Company's (NMGC's)\nAlameda transmission line where pressure is reduced from 466 psig to 175 psig. The pipeline\nruns approximately 1.1 miles to a regulator station located at Intel Corporation where it delivers\nnatural gas to Intel's manufacturing facility (a large volume customer) and the Albuquerque\nMetro 60 psig distribution system. The pipeline has no service lines or farm taps upstream of its\ndelivery to Intel's manufacturing facility and the natural gas distribution system.\nThe Santa Fe South feed line begins at a regulator station on NMGC's Santa Fe transmission line\nwhere pressure is reduced from 600 psig to 250 psig. The pipeline runs approximately 11 miles\nto a regulator station on the south end of Santa Fe where pressure is reduced to 60 psig to supply\nthe Santa Fe distribution system. This pipeline segment was part of the Santa Fe transmission\nline and operated at 600 psig until a loop/bypass line was installed a couple of years ago. The\npipeline has no service lines upstream of its delivery to the Santa Fe distribution system.\nThe Gallup east feed begins at NMGC's East Gallup El Paso Natural Gas Company's PNG\nbackup regulator station at EPNG's transmission line and transports natural gas from the EPNG\ntransmission line to NMGC's East Gallup border regulator station. NMGC's primary supply for\nthe Gallup distribution system is its Gallup/Grants mainline which delivers natural gas at the East\nGallup border regulator station. This pipeline serves as a back-up supply and also delivers\nnatural gas at the East Gallup border regulator station. The pipeline has no service lines or farm\ntaps upstream of its delivery to the East Gallup border regulator station.\nThe Ambrosia Lake line begins at a regulator station on NMGC's Gallup/Grants transmission\nline where pressure is reduced from 720 psig to 180 psig. The pipeline transports natural gas\napproximately 27 miles to NMGC's grants distribution system where pressure is reduced to\n50 psig.\nThe Pipeline and Hazardous Materials Safety Administration. Ot1lce of Pipeline Safety provides written clarifications of the Regulations\n(49 CFR Parts 190-199) in the tonn of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations {]o not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\nThe definition for \"transmission line\" per§ 192.3 is reprinted below:\nTransmission line means a pipeline, other than a gathering line, that:\n(1) Transports gas from a gathering line or storage facility to a distribution center,\nstorage facility, or large volume customer that is not down-stream from a\ndistribution center;\n(2) Operates at a hoop stress of 20 percent or more of SMYS; or\n(3) Transports gas within a storage field.\nNOTE: A large volume customer may receive similar volumes of gas as a\ndistribution center, and includes factories, power plants, and institutional users of\ngas.\nBased on the information you and the New Mexico Public Regulation Commission provided, we\nbelieve that these pipelines downstream of the custody transfer point between the interstate\ntransmission pipeline and the local distribution company are distribution lines. I hope that this\ninformation is helpful to you. If I can be of further assistance, please contact me at\n(202) 366-0434.\nSincerely,\nDirector, Office of Standards\nand Rulemaking\ncc: New Mexico Public Regulation Commission\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations\n( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the\nspecific facts presented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and\nare provided to help the public understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nfi:-lf ·00(1\nNew Mexico\nGAS COMPANY\nAUG 09 2011\nAugust 3, 2011\nJeffrey D. Wiese\nAssociate Administrator\nOffice of Pipeline Safety\nPipeline and Hazardous Materials Administration\nU. S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nRE: Interpretation of Transmission Lines\nDear Mr. Wiese:\nNew Mexico Gas Company (NMGC), is a local distribution company serving approximately\n500,000 customers in the state ofNew Mexico. NMGC would like to request a formal\ninterpretation of transmission lines as related to our company and system.\nThe confusion around the transmission definition relates to the lack of a written definition for a\ndistribution center. Based on previous PHMSA interpretations it is NMGC's understanding that\na distribution center commonly refers to that point where gas enters piping primarily to deliver\ngas to customers who purchase it for consumption as opposed to customers who purchase it for\nresale. Since the vast majority of the gas in NMGC' s piping is delivered to customers who\npurchase it for consumption, we believe the distribution center can typically be represented by\nthe point of transfer between an interstate pipeline and NMGC such as a city gate station or a\nregulator station unless the downstream piping operates at a hoop stress of 20 percent or more of\nSMYS. NMGC does not transport gas from a gathering line or storage facility and does not\ntransport gas within a storage field.\nFour specific examples are our Intel VHP line, our Santa Fe South Feed line, our Gallup East\nEPNG Feed, and our Ambrosia Lake line. The Intel VHP line originates at a regulator station on\nour Alameda transmission line in the middle of our Albuquerque Metro distribution center. The\nAlameda transmission line operates above 200/o of SMYS at 466 psig and the Intel VHP line\noperates at 175 psig at 5. 9% of SMYS. The Intel VHP line delivers gas to the Albuquerque\nMetro 60 psig distribution system and to the Intel factory (a large volume customer). Attached is\na map showing the Alameda transmission line, the Intel VHP line, and a portion of the\nAlbuquerque Metro 60 psig distribution system. All of the gas that travels through the Alameda\ntransmission line and the Intel VHP line is delivered to customers who purchase it for\nconsumption. NMGC's interpretation of the pipeline safety regulations is that the Intel VHP line\nis a distribution line because it delivers gas downstream of the Albuquerque distribution center\nand does not operate at a hoop stress of 20 percent or more of SMYS. We would appreciate an\ninterpretation regarding whether the Intel VHP line is a distribution line.\nThe second example, the Santa Fe South Feed line, is similar to the first. The Santa Fe South\nFeed line originates at a regulator station on our Santa Fe transmission line on the south side of\nP .O . B ox 97500 Albuq ue rq ue, N M 87 199-7500 p: 888 NMGASCO www.nmgco.c om\n\n<<<PAGE 5>>>\n\nour Santa Fe distribution center. The Santa Fe transmission line operates above 20% of SMYS\nat 600 psig and the Santa Fe South Feed line operates at 250 psig at 18.SO/o ofSMYS. The Santa\nFe South Feed line delivers gas to the Santa Fe 60 psig distribution system. Attached is a map\nshowing the Santa Fe transmission line, the Santa Fe South Feed line, and a portion of the Santa\nFe 60 psig distribution system. All of the gas that travels through the Santa Fe South Feed line is\ndelivered to customers who purchase it for consumption. NMGC's interpretation of the pipeline\nsafety regulations is that the Santa Fe South Feed line is a distribution line because it delivers gas\ndownstream of the Santa Fe distribution center and does not operate at a hoop stress of 20\npercent or more of SMYS. We would also appreciate an interpretation regarding the Santa Fe\nSouth Feed line.\nThe third example is the Gallup East EPNG Feed. The East EPNG Feed originates at the Gallup\ncity gate station where NMGC takes delivery of gas from an interstate pipeline. The East EPNG\nFeed operates at 300 psig at 13.7% ofSMYS. The East EPNG Feed delivers gas to the Gallup\n60 psig distribution system. Attached is a map showing the East EPNG Feed and a portion of the\nGallup 60 psig distribution system. All of the gas that travels through the East EPNG Feed is\ndelivered to customers who purchase it for consumption. NMGC's interpretation of the pipeline\nsafety regulations is that the East EPNG Feed line is a distribution line because it delivers gas\ndownstream of the Gallup distribution center and does not operate at a hoop stress of 20 percent\nor more of SMYS. We would also appreciate an interpretation regarding the East EPNG Feed\nline.\nThe fourth example is the Ambrosia Lake line. The Ambrosia Lake line originates at a regulator\nstation on the Grants transmission line on the north side of our Grants distribution center. The\nGrants transmission line operates above 20% of SMYS at 720 psig and the Ambrosia Lake line\noperates at 180 psig at 10.1 % of SMYS. The Ambrosia Lake line delivers gas to the Grants 50\npsig distribution system and to several farm taps. Attached is a map showing the Ambrosia Lake\nline along with portions of the Grants 50 psig system and portions of the Grants and Gallup\ntransmission lines. All of the gas that travels through the Ambrosia Lake line is delivered to\ncustomers who purchase it for consumption. NMGC' s interpretation of the pipeline safety\nregulations is that the Ambrosia Lake line is a distribution line because it delivers gas\ndownstream of the Grants distribution center and does not operate at a hoop stress of 20 percent\nor more of SMYS. We would also appreciate an interpretation regarding the Ambrosia Lake line.\nIf you have any questions regarding this matter, please call me at (505) 697-3585.\ncc: John Gale- PHMSA\nJason Montoya - PSB\nKen Oostman- NMGC\nTom Bullard - NMGC\nGary Roybal- NMGC\n\n<<<PAGE 6>>>\n\n[overview of NMGC Transmission System I\nJ 7 -w R <1C$~ p ~ ~{t a t 1~i ~ r\n--·- ··~--- -- ---~--..J\n,, --- ~\n··-\n-...-~~··l§ ~ :!~~ ~ --- ~? _ . ~: 1~ - W;!llams\n~-\n. I' +~ ~ ...\n'\"'· t t .\n-\n_\n\"-;,.;u--R ~· ~ \" fh ~ t a-, !!;>!J,;:> J\nLocati. Qrr'of; _\nSanti F.e So¢h F~ed Une\nLoM1io.n of:\nAmbrosia\" L.ake System\nU:tgcnd\n--\"\"\"' NMGC Transmisslon\nlines\n_\nEl Pas.o Na, tu ral Gas Pipe)ines\nTranswestern Pipelines\nc=J Al,buqfjergue-DLsfribulioo System\n.' c=J Santa- F' e Distrioution System.\nc=J Gallup DlstributionA System\nc::::J MilaJl & Gtartts Dist,tibution System\n[:==J Farmingtcn Dtstrrbution Sy~1ein\nOther tiMGC Distribution SystE:ms\n~ -- .... '-.! -\nEPr-1G \"'r;d T \\1\\1\n~r~ f'~jr ; ,t ' i~ ahi 'l \\1.5 I\n~ .,1.-l;,; •\n__ t l.j ••\n... :;;;-'•-.;, ,- ~ ... ~...-~· , - .:...:- . :.....J \\\n\n<<<PAGE 7>>>\n\nFuel Gas Deivary Regulator:\nTake-08 Valve Seting at Santa Fe Junction\nAlameda Transmission Line\nM Water Wes No. 3 Tep\nLos Suscos Barde\nWar Sos Hongal\nRo Rancho Border Station No. 1\nWest Side Heaptal (ou St\nFake Sering\nOt Vivo Seting\nGibois Border Station\nRo Ranche Pigman: Contra\nIntel VHP Line\n\n<<<PAGE 8>>>\n\nSanta Fe Transmission Line\nEV Pate Too\nHighery 500 Border Station\n•Town. Border Station\nSonia Fa Series Cutor\nRegulator Station\nRegutator Statica\nRegulator Station\nAgniny 09s Heather\nRoguintor Statica) Regulator Siason\nRegulator Station\nBlock Valve Staton Regulate Stason\nRegurator Station\nRogulater Stason\nReguiator Station\nRegular Station Regulator Summon\nRegulator Station\nRegulator Staton\nSanta Fe South Feed Line\n\n<<<PAGE 9>>>\n\nEl Paso Natural Gas Interstate Pipeline\nGallup East EPNG Feed\nGallup Transmission Line\nGalup East Daret Regules Se\nGalup Derde Solten No. 2\nGalan East Tako-ot\nIndian Plaza Regulato: Station\nMenuing Sinton\n\n<<<PAGE 10>>>\n\nOdaricer Sados\nEl Paso Natural Gas Interstate Pipeline\nMear Staton\nGallup Transmission Line\nBock Vairo Setting\nEPNG Recept Station\nBorde Saten\nDiabet Regalhice\nMartine TAp\nMinino ing Marine Top\nMeter Season\nAsnine Tup\nBordir Staien\nBock Wike Seting\nMinina Tip Munica Teo\nBesde Statien\nMaicine Tap\nEPNG Recept Station\nBlock Yake Sesing\nMentre Top\nHectios\nAmbrosia Lake System\nGrants Transmission Line\n\n<<<PAGE 11>>>\n\nNew Mexico\nGAS COMPA N Y\nOctober 12, 2011\nMr. Tewabe Asebe\nOffice of Pipeline Safety\nPipeline and Hazardous Mateirals Administration\nU.S. Department of transportation\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nRE: Interpretation of Transmission Lines\nDear Mr. Asebe,\nOn September 21, 2011, you telephoned me and requested additional information with regard to the\nrequest for interpretation submitted by New Mexico Gas Company (NMGC). As I understand it, you\nrequested the following for each of the line in question:\n• Distance from the supplier's transmission line to the city gate.\n• Distance from the city gate to the distribution system.\n49 CFR 192.3 defines a transmission line as follows:\nTransmission line means a pipeline, other than a gathering line, that: (1) transports gas from a gathering\nline or storage facility to a gas distribution center, storage facility, or large volume customer that is not\ndown-stream from a gas distribution center; {2) operates at a hoop stress of 20 percent or more of\nSMYS; or (3) transports gas within a storage field.\nNMGC does not transport gas from a gathering line or storage facility so that part of definition (1) does\nnot apply. NMGC also does not transport gas within a storage field so definition (3) does not apply. The\nonly portions of the definition which could apply to NMGC are the portion of definition (1) relating to\nlarge-volume customers not downstream of a distribution center and definition (2) for lines that operate\nat a hoop stress of 20 percent or more of SMYS.\nNew Mexico Gas Company's definition of a distribution center, based on previous PHMSA\ninterpretations and general industry interpretations, is either a city gate station or the point in which gas\nflows into piping that is primarily delivered to customers who have purchased the gas for consumption.\nIn most instances, NMGC's city gate stations are at the point of transfer between the interstate pipelines\nwhich supply our gas and NMGC's system, thus the distribution center is all of the systems downstream\nof those points of transfer. All lines within the NMGC'S distribution center are distribution lines, unless\nthey operate at above 20% SMYS. NMGC's distribution centers typically consist of multiple distribution\nsystems which operate at various pressures.\nNMGC receives gas for its NW systems at three primary locations. These locations are two interstate\npipelines (EI Paso Natural Gas and TransWestern) at the Rio Puerco Receipt Station, the tailgate of the\nP.O. Box 97500 • Albuquerque, NM 87199-7500 p: 888 NMGASCO www.nmgco.com\n\n<<<PAGE 12>>>\n\nKutz processing plant in Bloomfield, NM (Kutz Receipt Station), and the tailgate of the lybrook\nprocessing plant in lybrook, NM (lybrook Receipt Station. NMGC lines within the distribution center\nthen bring this gas to NMGC's Santa Fe Junction, northwest of Albuquerque. Santa Fe Junction is the\nbeginning of the Albuquerque Metro area distribution center and where the Santa Fe Mainlines head\nnorth towards Santa Fe.\nDistance from the supplier's transmission line to the city gate\nThe Intel VHP line is within the Albuquerque Metro distribution system. The distance from the suppliers'\npipelines to the city gate (Santa Fe Junction) is 35 miles for the Rio Puerco Receipt Station,\napproximately 135 miles for the Kutz Receipt Station, and approximately 89 miles for the lybrook\nreceipt Station.\nThe Santa Fe South Feed line is within the Santa Fe distribution system. The Santa Fe distribution system\nis served from Santa Fe Junction through the Santa Fe Mainlines to the Santa Fe city gate at the Highway\n599 Regulator Station. The distance from Santa Fe Junction to the Santa Fe city gate (Highway 599\nRegulator Station) is approximately 48 miles. So the distance from the suppliers' pipelines to the city\ngate is approximately 83 miles for the Rio Puerco Receipt Station, approximately 183 miles for the Kutz\nReceipt Station, and approximately 137 miles for the lybrook Receipt Station.\nThe Gallup East EPNG Feed line is within the Gallup distribution system. The Gallup distribution system is\nserved by the El Paso Natural Gas (EPNG) interstate pipeline. Since all of the gas provided by our\nsuppliers is for customers' consumption and not for resale, the distribution center begins at the point of\ntransfer from the supplier's transmission line. Thus the distance from the EP NG pipeline to the Gallup\ncity gate is zero.\nThe Ambrosia lake line is within the Grants area distribution center. The Ambrosia lake city gate is the\nAmbrosia Border Station. This area is served from NMGC's transmission system which runs from\nnorthwest New Mexico. Since all of the gas provided by our suppliers is for customers' consumption and\nnot for resale, the distribution center begins at the point of t ransfer from the suppliers' transmission\nlines. Thus the distance from t he suppliers' pipelines to the city gate is zero.\nDistance from the city gate to the distribution system\nFor the Intel VHP line, the applicable city gate is Santa Fe Junction. The distance from Santa Fe Junction\nto the distribution system at Cibola Border Station is approximately 6 miles. The length of the Intel VHP\nline is 1.4 miles and it operates at 175 psig (5.9% SMYS)\nFor t he Santa Fe South Feed line, the city gate is the Highway 599 Regulator Station. The distance from\nthe Highway 599 Regulator Station to the next regulator station (Santa Fe Airport distribution system)\non the Santa Fe South Feed line is less than 1 mile. The length of the Santa Fe South Feed line is 11\nmiles. This line operates at 250 psig (18.8% SMYS).\nFor the Gallup East EPNG Feed, the city gate is the EPNG Gallup City Gate #2. The distance from the city\ngate t o the distribution system is 1.1 miles. The Gallup East EPNG Feed operates at 300 psig (13.7%\nSMYS).\nFor the Ambrosia lake line, t he applicable city gate is the Ambrosia lake Border Station. The distance\nfrom the Ambrosia l ake Border Station to the Milan distribution system is approximately 17 miles. The\nlength of the Ambrosia lake line is 27 miles and it operates at 180 psig (10.1% SMYS).\n\n<<<PAGE 13>>>\n\nI have attached a map of our northwest system showing the distribution syst ems and receipt points. I\nhope that this answers your questions. If not, please contact me at 505-697-3585 or\ndeborah.brunt@nmgco.com\nSincerely,\nDirector of Engineering\ncc: Ken Oostman- NMGC\nTom Bullard- NMGC\nGary Roybal- NMGC\nJason Montoya- NMPSB\n\n<<<PAGE 14>>>\n\nI Overview of NMGC Transmission System I\n•\n~ EPNG, TW and Williams Kutz Receipt Stations\n•\nLocation of:\nAmbrosia Lake System\nLegend\n- NMGC Transmission_lines\nEl Paso Natural Gas Pipelines\n- Transwestern Pipelines\nc=J Albuquerque Distribution System\nc=J Santa Fe Distribution System\nc:::J Gallup Distribution System\nCJ Milan & Grants Distribution System\nc=J Farmington Distribution System\nOther NMGC Distribution Systems\nEPNG Receipt Station Location of:\nIntel VHP Line\nEPNG and TW Receipt Stations","truncated":false,"body_characters":23422}