{"operation":"document","citation":"PI-17-0009","title":"Alaska Gasline Development Corp. — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2018-03-28","effective_on":null,"summary":"PI-17-0009 response to Alaska Gasline Development Corp. concerning 192.1.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0009.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0009.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-17-0009","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/56706/alaska-gasline-development-corporation-pi-17-0009-12-07-2017-part-1921.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nDEC O 7 2017\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nMr. Frank T. Richards, P.E.\nSenior Vice President, Program Management\nAlaska Gasline Development Corp.\n3201 C Street, Suite 200\nAnchorage, AK 99503\nDear Mr. Richards:\nIn a June 5, 2017, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Alaska Gasline Development Corporation (AGDC) requested an interpretation of\n49 CFR Part 192 to determine whether AGDC's Alaska LNG Gas Treatment Plant (GTP), would\nbe regulated under the Part 192 regulations.\nPHMSA has statutory jurisdiction over gas pipeline facilities and the transportation of gas.\nFurthermore, Part 192 applies to pipeline facilities that transport gas, including pipeline facilities\nand the transportation of gas within the limits of the Outer Continental Shelf ( 49 CFR\n§ 192.1 (a)). In the letter, AGDC stated that the GTP will process gas received from the Prudhoe\nBay Unit and the Point Thompson Unit to meet the Alaska LNG Pipeline Mainline inlet\nspecifications for carbon dioxide (C02), hydrogen sulfide (H2S), water, pressure, and\ntemperature. As AGDC has indicated that the function of the GTP will be to process gas before\nit enters the proposed AGDC transmission pipeline, PHMSA's interpretation is that the GTP\nwould not be regulated under Part 192.\nHowever. Part 192 requires that pipeline operators provide protection to control against\naccidental over-pressuring. For gas being treated within a processing plant and sent into a\ndownstream regulated pipeline, Part 192 regulatory oversight is applied to the outlet piping\nleaving a processing plant, including the last pressure control device before the gas enters the\nregulated pipeline. Hgure 1 GTP/Mainline High Level Process Flow Diagram identifying the\nproposed demarcation point in your June 5, 2017, letter does not provide sufficient detail to\ndetermine regulatory boundaries. In order for PHMSA to make a regulatory determination, it\nneeds the details of the specific demarcation point.\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 of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally,enforc.eable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nPHMSA' s interpretation is based on the information AGDC has provided to PHMSA as of the\nissuance of this letter, and may be subject to change if AGDC alters the planned design and\noperation of the proposed GTP as currently shared.\nIfwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\n~$,\nAssociate Administrator\nfor Pipeline Safety\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\n*\n**\nGASLINE*\n* *\n*\nD{{LOPEHT C0TIP.\n*\nMay23, 2017\nSentho K. White, P.E.\nGeneral Engineer\nPipeline and Hazardous Materials Safety Administration\nEngineering and Research\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington DC 20590\nRe: AKLNG Gas Treatment Plant (GTP) Jurisdiction\nDear Ms. White:\nDuring our meeting of March 21, 2017, we discussed the PHMSA jurisdiction of the\nproposed Gas Treatment Plant (GTP) for the Alaska LNG project. Following that\ndiscussion, AGDC received an inquiry in this regard from PHMSA, which we understood\nwas to clarify the extent of control the GTP Operational Control Center would exert over\npipeline operations, i.e. control of the pipeline beyond the start of the pipeline at the\nboundary limits of the GTP. Please be advised of the following comments regarding the\ndesign basis and operational approach for the GTP.\nThe GTP will have its own control system centered in the control room within the GTP\nfacilities that will be completely separate from control systems of the AKLNG Pipeline and\nAKLNG LNG facilities. The Pipeline will be controlled from the pipeline control center in\nAnchorage with backup controls at the pipeline operation I maintenance facility in\nFairbanks. Control of the LNG facilities will be within the Nikiski LNG facility. There will be\nno control functions of the pipeline facilities from the GTP or LNG control rooms. The\nthree control centers (GTP, Pipeline and LNG) will have the capability to notify the other\ncenters as issues may arise so that any control actions, if needed, can be taken by the\nother control centers for the areas of their responsibility.\nPipeline facilities located near the GTP, primarily metering and pig launcher, will be\nisolated from the GTP facilities. All operation, maintenance and control of those Pipeline\nfacilities will be the responsibility of the Pipeline O&M staff. The GIP O&M staff will have\nno responsibilities or authority for Pipeline facilities, Likewise, the Pipeline O&M staff will\nhave no responsibilities or authority for the GTP facilities.\nALASKA GASLINE DEVELOPMENT CORPORATION\n3201 C Street, Suite 200, Anchorage, Ataska 99503\nT&. 907-330-6300 Fax 907.330-6309 I www.agdc.us\n\n<<<PAGE 4>>>\n\nAlaska Gasline Development Corporation\nPage 2 of 2\nThis approach is outlined in the AKLNG design basis documents, e.g.:\n\"The Project shall have a dedicated control room in each of the following areas for\noperations and to control their respective facility:\n1) Gas Treatment Plant\n2) Mainline\n3) LNG/Marine\nFor each facility above, the respective control room shall have the ability to\noperate, monitor and shutdown all units, packages, processes and utilities within\ntheir plant.\nEach facility (GTP, Mainline & LNG/Marine) shall have standalone Integrated\nControl & Safety System (ICSS).\"\nIt should also be pointed out that this philosophy is consistent with the operations of the\nexisting OHSA regulated North Slope facilities.\nRegarding the Pipeline operations, control and abnormal conditions actions, please refer\nto the AKLNG submission to FERC, Resource Report 11 of April17, 2017.\nSincerely,\nFrank T. Richards, P.E.\nSenior Vice President, Program Management\nALASKA GASL.NE DEVELOPMENT CORPORATION\n3201 C Street, Suite 200. Anchorage. Alaska 99503\nTel. 907-330-6300 I Fax 907-330-6309 I ww agdc us\n\n<<<PAGE 5>>>\n\n*\nALASKA\n*\n*\n*\nGASLINE *\n**\nDEUELOPMENT CORP.\nJune 1, 2017\nSentho K. White, P.E.\nGeneral Engineer\nPipeline and Hazardous Materials Safety Administration\nEngineering and Research\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington DC 20590\nRe: Department of Transportation jurisdictional limits\nDear Ms. White:\nAGDC sent a letter (Frank Richards to White of 5/23/2017) which addressed PHMSA\njurisdiction of the proposed North Slope Gas Treatment Plant (GTP). That letter had noted\nthat the separation of Facilities from Pipeline for the proposed Alaska LNG project would\nbe consistent with ongoing North Slope jurisdiction limits.\nTo provide further explanation of AGDC's position, the public 2013 BP Annual ADR\nSurveillance and Monitoring Report is attached. Please see Appendix A, \"Pipeline\nSchematics\", that depicts the DOT jurisdictional limits on existing North Slope facilities.\nThe full, electronic document may be found at:\nhttp://dog.dnr.alaska.gov/spcs/Documents/Publications/LesseeAnnualReports/2013/2013\nAnnualReport-BP-Combined.pdf\nSincerely,\nFrank T. Richards, P.E.\nSenior Vice President, Program Management\nALASKA GASLINE\n3201 C Street, Suite 200, Anchorage, Alaska 99503\nDEVELOPMENT\nCORPORATION\nTel. 907-330-6300 | Fax 907-330-6309 | www.agdc.us\n\n<<<PAGE 6>>>\n\nJune 5, 2017\nREGULATORY JURISDICTION RATIOI\nGAS TREATMENT PLANT\nSUMMARY\nThe Pipeline Hazardous Materials and Safety Administration (PHMSA) is asserting regulatory\njurisdiction within the Alaska LNG Gas Treatment Plant (GTP). Regulatory jurisdiction for the GTP\nshould be the same as other North Slope gas and oil processing facilities which are connected to\nPHMSA jurisdictional pipelines, principally Occupational Safety and Health Administration (OSHA)\nand the State Fire Marshall. PHMSA jurisdiction would only apply to the Alaska LNG Pipeline\n(\"Mainline\") beginning at the demarcation point between pipeline and GTP facilities where\nownership, control, safety systems, maintenance, and access of the GTP and the Mainline facilities\nis transitioned. Figure 1 depicts where the transition would take place from a process perspective,\nand Figure 2 depicts the physical location of the transition point.\nACTION REQUESTED\nAGDC requires concurrence that PHMSA jurisdiction for the Alaska LNG project does not extend\nto the GTP facilities.\n\n<<<PAGE 7>>>\n\nAlaska LNG- PHMSA Regulatory Jurisdiction Rationalization\n1. BACKGROUND\nThe Alaska LNG GTP will process gas received from the Prudhoe Bay Unit and the Point Thomson\nUnit to meet the Alaska LNG Mainline inlet specifications for CO2. H2S, water, pressure and\ntemperature. The GTP will have its own control and safety systems centered in the control room\nwithin the GTP facilities that will be completely separate from control and safety systems of the\nAlaska LNG Pipeline and Plant Facilities. The Mainline will be controlled from the Mainline control\ncenter in Anchorage with backup controls at the Mainline operation/maintenance facility in\nFairbanks. Control of the LNG facilities will be within the Nikiski LNG facility. There will be no\ncontrol functions of the Mainline facilities from the GTP or LNG control rooms. The three control\ncenters (GTP, Mainline, and LNG) will have the capability to notify the other centers as issues may\narise so that any control actions, if needed, can be taken by the other control centers for the areas\nof their responsibility.\nMainline facilities located near the GTP, primarily metering and pig launcher, will be isolated from\nthe GTP facilities. All operations, maintenance, and control of those Mainline facilities will be the\nresponsibility of the Mainline operations and maintenance (O&M) staff. The GTP O&M staff will\nhave no responsibilities or authority for Mainline facilities. Likewise, the Mainline O&M staff will\nhave no responsibilities or authority for the GTP facilities. Figure 1 shows the demarcation of\nequipment from a process perspective. Figure 2 shows the physical location on pad of the\ndemarcation point.\nFigure 1. GTP/Mainhine High Level Process Flow Diagram\nHydrocarbon\nFlow C02\nPressure H2S\nGTP Control i Pipeline Control\n) From GTP Rehigeration\n-3Tu Pipeline Pig Launcher\nPipeline Metering,\nAnalyzer and\nProtective\nShutdown Valve\nSkid\nAlaska Gasline Development Corporation I 3201 C St., Suite 200, Anchorage, AK 99503 I www.agdc.us\nNOTICE -THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED\nOR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BY AGDC IN WRITING.\nRev 0\n\n<<<PAGE 8>>>\n\nAlaska LNG- PHMSA RegulatoryJurisdiction Rationalization\nFigure 2. Partial GTP Plot Plan Showing Equipment Location on the GTP Pad\nI FftTE.1 :: /\nGAS.\ncm it\nATtU\n!4in; II\nG*S -7\nDemarcation of\n) control between\nI \\ Pipeline and\nGTP\nA1\nPipeline\nFacilities on\nthe GTP pad\nTP.*SFO(RS /\n:__ L1-.--\n-\n-\n,-,\n2. CONCLUSION\nThe Alaska LNG GTP and Mainline ownership, control, safety systems, maintenance, and access\nare independent of each other, and PHMSA jurisdiction should for be over the mainline facilities\nonly, as with other North Slope facilities. Specifically, the Mainline would be regulated by PHMSA,\nbut the upstream facilities, i.e. the GTP, would not be regulated by PHMSA.\nAlaska Gasline Development Corporation I 3201 C St., Suite 200, Anchorage, AK 99503 www.agdc.us\nNOTICE-THIS DOCUMENT CONTAINS CONFIDENTIAL AND PROPRIETARY INFORMATION AND SHALL NOT BE DUPLICATED, DISTRIBUTED, DISCLOSED, SHARED\nOR USED FOR ANY PURPOSE EXCEPT AS MAY BE AUTHORIZED BYAODC IN WRITING.\nRev 0","truncated":false,"body_characters":12429}