{"operation":"document","citation":"PI-16-0015","title":"Railroad Commission of Texas — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-07-12","effective_on":null,"summary":"PI-16-0015 response to Railroad Commission of Texas concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-16-0015","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/58431/rrc-texas-pi-16-0015-07-12-2018-part-1923.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue SE\nWashington DC 20590\nJUl 12 2018\nMs. Stephanie Weidman\nPHMSA Program Director\nRailroad Commission of Texas\n1701 North Congress Avenue\nP.O. BOX 12967\nAustin, Texas 78711 -2967\nDear Ms. Weidman:\nIn a September 14, 2016, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you requested an interpretation of 49 CFR Part 192. You specifically requested an\ninterpretation of§ 192.3 for a definition of a transmission pipeline.\nYou stated that \"[ o ]ver the past few years, the Commission's (RRC) Pipeline Safety program has\ncited alleged violations of the State safety regulations pertaining to pipeline permitting (T-4)\nrequirements for intrastate transmission and gathering pipelines.\" You stated that \"[c]ertain\npipeline operators have revised and transferred previously operated and regulated natural gas\ntransmission pipeline systems that operate at a hoop stress below 20% of SMYS, to a natural gas\ndistribution pipeline designation or purpose.\" You stated that \"[o]ne particular operator based on\ntheir [sic] opinion has changed over 600 miles of pipelines from a status of transmission to\ndistribution pipeline.\"\nYou provided two examples of pipeline systems the RRC considers \"to be transmission from\nhistorical and current operating conditions.\" In addition, in a November 15, 2016, email you\nprovided PHMSA summary of pipelines that the operators arbitrarily converted from\ntransmission to distribution pipelines.\nSection 192.3 defines a transmission line as:\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, storage\nfacility, or large volume customer that is not down-stream from a distribution 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 distribution\ncenter, and includes factories, power plants, and institutional users of gas.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR\n· Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nA pipeline that meets any of the three conditions listed under the definition in§ 192.3 is a\ntransmission line in accordance with 49 CFR Part 192. Therefore, a pipeline that operates at a\nhoop stress of less than 20 percent of its specified minimum yield strength, but meets either\ncondition one or three, meets the definition of a transmission line.\nPHMSA agrees, per§ 192.3, with RRC's interpretation that any pipeline system other than a\ngathering line that transports gas from a gathering line or storage facility to a distribution center\nmeets the definition of a transmission pipeline regardless of whether it operates at a hoop stress\nbelow 20 percent of SMYS. Ifwe can be of further assistance, please contact Tewabe Asebe at\n202-366-5523.\nSincerely,\nJo\nDirector, Office of Standards\nand Rulemaking\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 3>>>\n\nDA YID PORTER. C HAIRMAN\nC HRISTI C RADDICK. COMM ISS IO ER\nRYAN SITION. COMMISSIONER\nK ARI FRENCH\nD IV ISION DIRECTOR\nRAILROAD COMMISSION OF TEXAS\nOVERSIGHT AND SAFETY DIVISION\nPIPELINE SAFETY\nSepte mber 14, 20 16\nJohn Gale, Director\nOffice of Pipe line Safety (PHP-30)\nPH MS A, U.S. Departme nt of Transportation\n1200 New Jersey A venue SE.\nWashington, DC 20590-0001\nOC1 11 2016\nRe: Functi onalized Distributio n Pipe lines\nDear Mr. Gale:\nOver the past few years, the Commissio n's (RRC) Pipeline Safety program has cited alleged\nviolations of the State safety regulations perta ining to pipeline permitting (T-4) require ments for intrastate\ntrans mission and gatherin g pipelines. Certain pipeline operators have revised and transferred previous ly\noperated and regulated natural gas transmission pipeline systems that operate al a hoop stress be low 20%\nof SMYS, to a natural gas distribution pipeline designat ion or purpose. One particular operator based on\ntheir opinion has changed over 600 mi les of pipe lines from a status of transmission to distributio n.\nIncluded are two examples of pipeline systems the RRC understands to be transmi ss ion fro m\nhistorical and c urrent operating conditi ons. Per the configuration detail s on the attached maps, the\noperator considers the green lines labeled APT to be transmi ssion pipelines and the blue lines labe led\nMidTex to be di stribution pipelines. The red dots represent pressure regulator stati ons and the black dots\nrepresent gas measure ment stations. The gas for Line M primaril y fl ows north to south and deli vers gas to\napproximately 13 c ities. The gas for Line U generally fl ows south to north and provides service to about\n15 municipalities. The RRC pers pecti ve is that the ent ire pipe line syste m for both Line U and Line M\nshould continue to be designated operated, and maintained as Trans mission pipe lines.\nThe RRC's traditional dete rmination from Federal and State safety regulations, is that any\npipeline syste m that transports gas to a di stribution center (i.e. a city, town, or municipa lity) should be\nclassified as a transmission pipeline per the definition of transmission line in 49 CFR 192.3, regard less of\nthe operating hoop stress of the pipeline.\nAny guidance from PHMSA that can be provided to assist in resolving this situatio n would be\nmuch appreciated.\nRespectfully,\n; ~- ~0~ ~\nSte p ~~idm a n\nPHMSA Progra m Director\n170 1 NORTH CONGRESS AVENUE * POST OFFICE BOX 1 2967 * AUSTIN. T EXAS 787 11 -2967 * PHONE: 5 1 2/463-7058 *FAX: 512/463-73 1 9\nTDD 8001735-2989 OR TOY 5 1 2/463-7284 * AN EQUAL OPPORTUN ITY EMPLOYER * HTIP://WWW.RRC.STATE.TX.US","truncated":false,"body_characters":6639}