{"operation":"document","citation":"PI-13-0010","title":"City of Susanville — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-03-12","effective_on":null,"summary":"PI-13-0010 response to City of Susanville concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-13-0010.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-13-0010.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-13-0010","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2015/City_of_Susanville_PI_13_0010_10_30_2013_Part_192.3.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\nMAR 12 Z015\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nMr. Craig Platt\nPublic Works Director\nCity of Susanville\n66 North Lassen Street\nSusanville, CA 9613 0-3 904\nDear Mr. Platt:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated\nOctober 23, 2013, you requested an interpretation concerning the applicability ofthe Federal\npipeline safety regulations to a natural gas pipeline operated by the City of Susanville (City).\nYour letter essentially asked whether PHMSA considers the City's 6-inch, 10. 75-mile-long\npipeline to be a transmission line or a distribution line.\nYou stated that the City takes delivery of natural gas from Tuscarora Gas Transmission\nCompany at a custody transfer meter station located approximately 10.75 miles north of\nSusanville. At this location, the City district regulator station reduces the line pressure down to\n350 psig to feed the Susanville 6-inch pipeline. From the Tuscarora custody transfer meter, the\npipeline travels approximately 3 miles to a pressure regulator station where the gas pressure is\nreduced from 350 psig to 90 psig for a branch running to a state correctional facility and to\n60 psig for another branch running to a cogeneration power plant. From the pressure regulator\nstation controlling delivery pressure to the correctional facility and the power plant, the pipeline\nextends an additional 7.75 miles to the City of Susanville gate station where gas pressure is\nfurther reduced from 350 psig to 50 psig to feed the City's PE distribution piping system and all\nof this piping transports odorized gas.\nA pipeline is classified as a \"transmission line\" if it meets any one of the three conditions in the\ndefinition of \"transmission line\" at § 192.3.\nSection 192.3 defines a gas \"Transmission line\" as:\n[A] pipeline, other than a gathering line, that: ( 1) transports gas from a gathering line or\nstorage facility to a distribution center, storage facility, or large volume customer that is\nnot down-stream from a distribution center; (2) operates at a hoop stress of 20 percent or\nmore of SMYS; or (3) transports gas within a storage field.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nNOTE: A large volume customer may receive similar volumes of gas as a distribution center, and includes\nfactories, power plants, and institutional users of gas.\nThe City may be currently operating the line at 350 psig, but it has an established Maximum\nAllowable Operating Pressure (MAOP) of 1000 psig. This MAOP was verified by Dan Newton,\nInterim Public Works Director/City Engineer for the City of Susanville, in an email to\nMr. Jason Dunphy ofPHMSA's Western Region Office dated June 9, 2014. Under Part 192\nregulations, the MAOP is used to calculate the percentage of Specified Minimum Yield Strength\n(SMYS) at which the pipeline is allowed to operate. Based on the information you provided, the\npipeline is allowed to operate at 36 percent of SMYS, which exceeds 20 percent of SMYS.\nTherefore, the City of Susanville pipeline appears to be a transmission pipeline per the definition\nof \"transmission line\" at § 192.3.\nI hope this information is helpful. Ifwe can be of further assistance, please contact\nTewabe Asebe, Transportation Specialist, Standards and Rulemaking Division, by phone at\n(202) 366-5523 or by email at tewabe.asebe@dot.gov.\nSincerely,\nA~. t'to ~ ,\n~ ivrt'::/:i\nDeputy Associate Administrator\nfor Policy and Programs\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written\nclarifications of the Regulations ( 49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect\nthe agency's current application of the regulations to the specific facts presented by the person requesting the\nclarification. Interpretations do not create legally-enforceable rights or obligations and are provided to help the\npublic understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\nCity of Susanville\n(530) 257-1000 • 66 North Lassen Street • Susanville, CA 96130-3904\nOctober 23, 2013\nJeffrey D. Wiese\nAssociate Administrator\nOffice ofPipeline Safety\nPipeline and Hazardous Materials Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590-0001\nOtl S 0 2013\nRE: Interpretation of Transmission Lines\nDear Mr. Wiese:\nThe City of Susanville (located in Northeast California) operates a municipal natural gas\ndistribution system, Operator ID No. 31599. This natural gas distribution system began\noperation on September 13, 2001. The Susanville natural gas system is currently serving\n3,000 customers including a cogeneration power plant and a State of California correctional\nfacility.\nPursuant to discussions in the matter of natural gas transmission facilities vs. natural gas\n. . .\ndistribution facilities with the PHMSA Western Region office, the City of Susanville\nrespectfully requests a formal interpretation of transmission line as related to our natural gas\nsystem.\nThe City of Susanville takes delivery of natural gas from Tuscarora Gas Transmission\nCompany at a custody transfer meter station located approximately 10.75 miles north of\nSusanville. At this location, the City district ·regulator· station reduces the Tuscarora line\npressure down to 350 psig to feed the Susanville 6-inch coated steel distribution feeder\nmainline. From the Tuscarora custody transfer meter and the City of Susanville district\nregulator station the City 6-inch high pressure mainline travels approximately 3 miles to a\nbranch connection serving a State of California correctional facility and a cogeneration\npower plant, where gas pressure is further regulated from the 350 psig mainline pressure\ndown to 90 psig and 60 psig respectively to serve these customers. At the furthest point of\nthe 6-inch steel feeder mainline, approximately 10.75 miles downstream of the custody\ntransfer station gas pressure, is regulated from 350 psig down to 50 psig at .the City of\nSusanville gate station feeding the City's PE distribution piping system serving local\nresidential and small commercial customers.\n' .\n'' '\nRod E. DeBoer\nMayor\nBrian R. Wilson\nMayor pro tern\nCoundlmembers:\nLino P. Callegari\nCheryl L. McDonald\nNicholas McBride\nwww. cit yOf susan vi 11 e ~or~\n\n<<<PAGE 4>>>\n\nThe City of Susanville 6-inch high pressure steel feeder mainline operates at 350 psig,.\napproximately 12.6% of SMYS.\nIt is our understanding, based on previous PHMSA interpretation that a distribution center\ncommonly refers to that point where gas enters piping primarily to deliver gas to customers\nwho purchase it for consumption as opposed to customers who purchase gas for resale. All of\nthe gas distributed through the City of Susanville system is delivered to customers who\npurchase it for their own consumption, including the correctional facility and the\ncogeneration power plant. We believe that the distribution center can typically be represented\nby the point of transfer between the interstate pipeline, Tuscarora Gas Transmission\nCompany and the City of Susanville. The City of Susanville does not transport gas directly\nfrom a gathering line or storage facility and does not transport gas within a storage field.\nWe await your interpretation in this matter. Should you have any questions please do not\nhesitate to contact me at (530) 257-1041 or by e-mail at cplatt@cityofsusanville.org.\nSincerely\nCraig Platt\nPublic Works Director\nCity of Susanville\nCc: Christopher Hoidal\nDirector Western Region\nPipeline & Hazardous Materials Administration\n12300 W. Dakota Avenue, Suite 100\n·Lakewood, CO 80228","truncated":false,"body_characters":8159}