{"operation":"document","citation":"PI-21-0007","title":"Puget Sound Energy — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2022-04-20","effective_on":null,"summary":"PI-21-0007 response to Puget Sound Energy concerning 192.631.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-21-0007.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-21-0007.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-21-0007","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/76426/puget-sound-energy-inc-pi-21-0007-04-18-2022-part192631.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration April 18, 2022\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMs. Kaaren Daugherty\nManager, Compliance and Quality Management\nPuget Sound Energy\nP.O. Box 97034\nBellevue, WA 98009-9734\nDear Ms. Daugherty:\nIn a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated\nJune 28, 2021, Puget Sound Energy (PSE) requested an interpretation of the applicability of\ncertain sections of 49 Code of Federal Regulation (CFR) part 192 to your pipeline facilities.\nSpecifically, you requested an interpretation as to the applicability of § 192.631 to the Jackson\nPrairie natural gas storage project (Jackson Prairie) located 10 miles southeast of Chehalis,\nWashington, which is jointly owned by Puget Sound Energy, Inc., Avista Utilities, and Williams\nNorthwest Pipeline (Joint Owners).\nYou described Jackson Prairie as follows: (1) feeder lines, consisting of 4 parallel transmission\nlines, ranging in size from 14-inch to 24-inch diameter and each approximately 1.7 miles long;\n(2) storage field; (3) processing facility; and (4) a meter station. You also stated that the feeder\nlines are bi-directional and are used to inject and withdraw from the storage field. You stated\nthat the feeder lines merge into a common header that connects to the meter station piping and\nWilliams Northwest Pipeline as the operator of the meter station.\nIn addition, you stated that PSE personnel are present 24 hours, 7 days a week at Jackson Prairie,\nand have sole responsibility for operating the station equipment within the processing facility\nboundaries and the property limits of the adjacent storage field and the feeder lines. You stated\nthe Jackson Prairie operations center receives information from data points located inside the\nfence line of the processing facility to ensure equipment, such as gas and fire detectors, are\noperating safely. You stated the data point on the west header line is located within the fence\nand measures suction or discharge pressures of gas entering or exiting the compressors. You\nstated that in the event the pressure goes above or below a predetermined safe operating pressure,\nthe automatic shut-off valve on the west header pipe is programmed to close.\nYou described the Joint Owners’ functions for the gas transmission pipeline operations, farm\ntaps, and Jackson Prairie as: (1) Williams Northwest is responsible for remotely monitoring and\ncontrolling the valves and piping at the storage project delivery point meter station (located\napproximately 1.7 miles to the west of Jackson Prairie storage facility) via a Supervisory Control\nand Data Acquisition (SCADA) system from a control room. Williams Northwest personnel can\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-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nalso use the SCADA information to direct Jackson Prairie personnel to take action at the feeder\nlines or the processing facility; (2) PSE operations center is responsible for remotely monitoring\nthe safety-related operations and the inlet to the Chehalis farm tap via a SCADA system from a\nPSE control room in Redmond, WA. In addition, the PSE SCADA system collects and displays\ninformation about the Chehalis farm tap inlet pressure to dispatch pressure control personnel to\ntake action at the farm tap; and (3) other than the meter station, PSE technicians are onsite and\nlocally monitor and control operation of the processing facility equipment within the fenced\nboundary. You stated that this relationship is governed by the Jackson Prairie Gas Storage\nProject Agreement (Project Agreement), on file with the Federal Energy Regulatory Commission\n(FERC). The storage field and the feeder lines are not connected to a SCADA system and the\noperations center is limited to the processing facility. All human-machine interface data points\nare located within the fenced boundary, however you also stated that Jackson Prairie does\nreceive a duplicate screen from the Williams Northwest SCADA system at the meter station for\nnon-operational information purposes only.\nOn July 12, 2021, you provided the following additional information: (1) schematic for Chehalis\nfarm tap station; and (2) schematic for Jackson Prairie processing facility and storage field. You\nalso stated that the compressors are located within the fence of the Jackson Prairie processing\nfacility and Jackson Prairie uses the compressors for withdrawal of gas that is pushed towards\nWilliams Northwest meter station about 1.7 miles away, and for injection of gas that is pushed\ntowards the storage field. You stated that Williams Northwest has its own compressors used for\ntransportation of gas through their interstate transmission pipelines. You stated that Williams\nNorthwest controls and monitors flow of gas to the Chehalis farm tap and to Jackson Prairie’s\nprocessing facility. In addition, you stated that Williams Northwest manages the nomination of\ngas to be stored or withdrawn without the involvement of PSE’s employees located at Jackson\nPrairie. You stated Williams Northwest provides the notification to PSE’s Jackson Prairie\npersonnel when gas needs to be withdrawn or injected.\nOn September 3, 2021, PHMSA again requested additional information and, per your request, on\nOctober 22, 2021, PSE and PHMSA staff had a conference call to discuss PHMSA’s questions\nrelated to the control room responsibilities of the Jackson Prairie facility. The original Safety\nProgram Relationship (SPR) provided to PHMSA did not indicate that the gas transmission\npipeline operations control room management plan (CRM) safety program was handled by\nWilliams, but instead indicated that it was addressed by PSE. Additionally, information\nprovided to PHMSA verbally indicated that contract arrangements between Williams Northwest\nand PSE were not in alignment with that identified in the letter submitted regarding operations\nand abnormal operating response. And while duplicate screen information was available to PSE\nat Jackson Prairie, pressure information at Jackson Prairie had not been provided to Williams\nNorthwest. Verbal information communicated to PHMSA indicated that Jackson Prairie, rather\nthan Williams Northwest, made the decision about starting and stopping compressors affecting\ngas transmission pressures on withdrawal and responding to the abnormal operations.\nOn January 11, 2022, you responded to PHMSA’s questions. You indicated in this response that\nduring the October 22nd meeting, PHMSA and PSE discussed operations and maintenance of the\ngas transmission pipelines (feeder lines), including emergency response, and confirmed Jackson\nPrairie is governed by the Project Agreement. Based on the information provided and discussed,\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\n3\nPSE indicated they would make changes in the SPR related to the CRM including the gas\ntransmission operations, provide additional pressure information to Williams Northwest, modify\nthe emergency procedures, and make modifications to the Project Agreement, which would be\nfiled with the FERC.\nYour January 11, 2022 response shows that PSE did not provide procedural information that\nindicated how operations and maintenance, including aspects associated with compression and\ninstrumentation.\nThe emergency procedure information you provided illustrates that the storage facility at Jackson\nPrairie is functioning as a 49 CFR Part 192 regulated control room because the procedures\nindicated that the storage facility would turn off the gas supply source.\nPHMSA requested but did not receive the start and stop procedures for Jackson Prairie and for\nChehalis locations. Based upon this, PHMSA cannot confirm that start and stop operations\nwould be directed by Williams Northwest as indicated in the January 11, 2022, PSE response.\nThis is an important factor for understanding the applicable Part 192 control room operator.\nBased on the information provided, the storage facility at Jackson Prairie was the only location\nmonitoring mainline pressure at the end of the gas transmission pipelines for injection\noperations, and at the beginning of the pipeline for withdrawal operations. This information is a\nsignificant component in determining the presence of an abnormal operation or emergency\ncondition.\nThere are several operators involved with the gas transmission pipeline operation between\nWilliams Northwest Meter Station, and the Storage facility at Jackson Prairie with no clear\ndocumentation submitted that Williams has responsibility for control room function based on the\ninformation provided to date and as stated in the request for interpretation.\nShould PSE correct all elements that were identified in the email response of September 3, 2021,\nand the meeting on October 22, 2021, implement activities with associated records providing\nsubstantiation of the changes made, and submit those records to PHMSA for review, Williams\nNorthwest could be recognized as the control room of record on a go forward basis.\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\n4\nHowever, based on the information provided and reviewed by PHMSA, and as configured in\nSPR, a control room currently exists at the storage facility at Jackson Prairie to monitor and\ncontrol the gas transmission pipeline operation. As such, § 192.631 requirements are applicable\nto the storage facility at Jackson Prairie and associated gas transmission assets. In addition, as an\noperator of a regulated underground natural gas storage facility, you must comply with\napplicable 49 CFR Parts 191 and 192 requirements (see §§ 191.17 and 192.12).\nIf we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nSincerely,\nJohn A. Gale\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 5>>>\n\nDocuSign Envelope ID: 1ED0C908-29A4-404A-B918-D17840D08AC3\nJune 28, 2021\nBy Federal Express\nAlan K. Mayberry\nAssociate Administrator for Pipeline Safety\nOffice of Pipeline Safety\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nRE: Request for Written Interpretation -- Control Room Management (49 C.F.R. §\n192.631)\nDear Mr. Mayberry:\nPuget Sound Energy, Inc. (PSE) is the operator of three elements of the Jackson Prairie\nNatural Gas Storage Project (Jackson Prairie) and certain other natural gas facilities in the\nstate of Washington under operator identification number, OPID 22189. PSE seeks a\nwritten interpretation from the Department of Transportation Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) regarding the applicability of the Control\nRoom Management Rule (49 CFR. § 192.631 (CRM Rule)) to its operation of Jackson\nPrairie.\nI. Background and Description of Jackson Prairie\nJackson Prairie is located approximately 10 miles southeast of Chehalis, Washington and\nis jointly owned by PSE, Avista Utilities (Avista), and Williams Northwest Pipeline\n(Northwest), collectively, the Joint Owners. Jackson Prairie consists of four primary\nelements:\nA. Storage Field, including individual Storage Reservoirs, wells, and associated field\nlines. Isolation valves for the field lines that connect the Storage Field to the\nProcessing Facility are located within the fence lines of Processing Facility.\nB. Processing Facility, including all the necessary compressor, dehydration, and\nfiltration units; local piping, an operations building, and a maintenance shop.\n\n<<<PAGE 6>>>\n\nDocuSign Envelope ID: 1ED0C908-29A4-404A-B918-D17840D08AC3\nThese facilities are situated in an approximately 5 acre area surrounded by a\nfence.\nC. Feeder Lines, consisting of four (4) parallel transmission lines, ranging in size\nfrom 14” to 24” diameter and approximately 1.7 miles each. The Feeder Lines\nconnect the Processing Facility to the Meter Station at the Storage Project\ndelivery point.\nD. Meter Station, situated at the Storage Project Delivery Point, serves as the point of\ninterconnection of the Feeder Lines and Northwest’s Natural Gas Transmission\nsystem. Through bi-directional metering, the Meter Station measures and controls\nthe quantity of natural gas injected into and withdrawn from Jackson Prairie. Per\nthe Joint Owner agreement, Northwest serves as the operator of the Meter Station.\nInside the fence line of the Processing Facility, there is a normally open, manually\noperated isolation valve on each of the Feeder Lines. The Feeder Lines merge into a\ncommon (west) header inside the fence, before entering the Processing Facility. The\nwest header piping has a locally operated valve that is used to control the flow of gas into\nand out of the Processing Facility. This valve remains closed when the Processing\nFacility is not injecting or withdrawing gas.\nInside the fence line of the Meter Station, there is a normally open, manually operated\nisolation valve on each of the four Feeder Lines. The Feeder Lines merge into a common\nheader that connects to the Meter Station piping. There are multiple valves used for\noperation, including 20” and 24” tap valves from Northwest’s mainline.\nOne other nuance to Jackson Prairie is the existence of the Chehalis Farm Tap off the 14”\ntransmission line. Contractually, this farm tap is defined as a “transportation delivery\npoint from Northwest to PSE located within the Storage Project”. This Farm Tap serves\nfive (5) customers and is operated and maintained by PSE pressure control personnel that\nare not part of the Jackson Prairie staff.\nPlease refer to the schematic in Figure 1.\nII. Jackson Prairie Monitoring and Control\nPSE personnel are present 24 hours, 7 days a week at Jackson Prairie. These employees\nexclusively operate the station equipment within the Processing Facility boundaries and\nthe property limits of the adjacent Storage Field and the Feeder Lines. Per CRM FAQ\nA.20, they do not remotely monitor and control the Feeder Lines outside of the fence line.\nThe Jackson Prairie Operations Center receives information from data points located\ninside the fence line of the Processing Facility to ensure equipment, such as gas and fire\ndetectors, are operating safely. The data point on the west header line is located within\nthe fence and measures suction or discharge pressures of gas entering or exiting the\ncompressors. In the event the pressure goes above or below a predetermined safe\noperating pressure, the automatic shut-off valve on the west header pipe is programmed\nto close. Jackson Prairie also receives a duplicate screen shot from Northwest’s SCADA\nsystem at the Meter Station for non-operational information purposes only.\n- 2 -\n\n<<<PAGE 7>>>\n\nDocuSign Envelope ID: 1ED0C908-29A4-404A-B918-D17840D08AC3\nNorthwest Controllers remotely monitor the Meter Station through various data points\nconnected to their SCADA system at a CRM Rule compliant Control Room located in\nHouston, Texas. The Northwest Controllers can remotely control the 20” and 24” tap\nvalves and are able to issue injection, withdrawal and shut in commands which activates\nlogic based configuration of various other valves in the Meter Station. In the event the\nSCADA data indicates a safety related condition requiring a shut in command, the\nNorthwest Controllers would also notify Jackson Prairie personnel to take action at the\nProcessing Facility as needed. By default, the monitoring and control of the data points\nat the Meter Station by the Northwest Controllers provides defacto remote monitoring\nand control for the Feeder Lines. If an abnormal condition or emergency resulting in\nrelease of gas or overpressure was to occur on any of the Feeder Lines, the resulting\npressure change would register at the data points at the Meter Station and the Northwest\nController would take appropriate action, including contacting Jackson Prairie personnel.\nIf injection or withdrawal activities were in process at the time, the automatic shut-off\nvalve within the fence line of the Processing Facility would activate to isolate the\nProcessing Facility. Additionally, in the case of a pipeline rupture on any of the Feeder\nLines, Jackson Prairie personnel would get auditory or visual evidence of this due to the\nshort length of these lines and the local proximity to the Processing Facility.\nAny issue with the 14” transmission line that feeds the Chehalis Farm Tap, would be\npicked up by the inlet RTU that is monitored and controlled by Controllers in PSE’s\nControl Room located in Redmond, Washington.\nIn the table below, we have outlined the Jackson Prairie configuration compared to the\nCRM Rule’s definitions of Control Room, Controller, and SCADA system for easy\nreference.\nDefined Term -- 49 C.F.R. § 192.3 (emphasis\nadded).\nJackson Prairie Configuration\nControl Room: an operations center staffed by\npersonnel charged with the responsibility for\nremotely monitoring and controlling a pipeline\nfacility.\nThe operations center at Jackson Prairie is staffed by\n“boots on the grounds” technicians with the\nresponsibility to locally monitor and control operation\nwithin the fenced boundary of the Processing Facility and\nthe property limits of the adjacent Storage Field and the\nFeeder Lines.\nThe Northwest operations center in Houston, Texas, is\nstaffed by personnel charged with the responsibility for\nremotely monitoring and controlling the Meter Station\npiping at the Jackson Prairie Storage Project Delivery\nPoint.\nThe PSE operations center in Redmond, Washington is\nstaffed by personnel charged with the responsibility for\nremotely monitoring the inlet to the Chehalis Farm Tap.\n- 3 -\n\n<<<PAGE 8>>>\n\nDocuSign Envelope ID: 1ED0C908-29A4-404A-B918-D17840D08AC3\nController: a qualified individual who remotely\nmonitors and controls the safety-related\noperations of a pipeline facility via a SCADA\nsystem from a control room, and who has\noperational authority and accountability for\nthe remote operational functions of the\npipeline facility\nJackson Prairie technicians are onsite and locally monitor\nand control operation of the Processing Facility\nequipment within the fenced boundary. JP personnel\nhave operational authority and accountability exclusively\nfor the Jackson Prairie Storage Project, except for the\nMeter Station. The Storage Field and the Feeder Lines\nare not connected to a SCADA system.\nNorthwest staffs its Houston, Texas Control Room with\nqualified individuals that remotely monitor and control\nthe safety-related operations of the Meter Station via a\nSCADA system from a Control Room. Northwest\npersonnel have operational authority and accountability\nfor the remote operational functions of the valves at the\nMeter Station.\nPSE staffs its Redmond, Washington Control Room with\nqualified individuals that remotely monitor and control\nthe safety-related operations of the Chehalis Farm Tap\nvia a SCADA system from a Control Room. PSE personnel\nin Redmond have operational authority and\naccountability for the remote operational functions of\nthe Farm Tap.\nSupervisory Control and Data Acquisition\n(SCADA) system: a computer-based system or\nsystems used by a controller in a control room\nthat collects and displays information about a\npipeline facility and may have the ability to\nsend commands back to the pipeline facility\nOperations Center at Jackson Prairie is limited to the\nProcessing Facility and all HMI data points are located\nwithin the fenced boundary. The Operations Center at\nJackson Prairie is not a SCADA system used by a\nController in a Control Room as those terms are defined\nin the CRM Rule.\nThe Northwest SCADA system is used by a Controller in a\nControl Room that collects and displays information\nabout the Meter Station; this information is used to\nremotely control valves at the Meter Station. Northwest\npersonnel can also use this information to direct Jackson\nPrairie personnel to take action at the Feeder Lines or\nthe Processing Facility.\nThe PSE SCADA system is used by a Controller in a\nControl Room that collects and displays information\nabout the Chehalis Farm Tap inlet pressure; this\ninformation is used to dispatch PSE pressure control\npersonnel to take action at the Farm Tap.\n- 4 -\n\n<<<PAGE 9>>>\n\nDocuSign Envelope ID: 1ED0C908-29A4-404A-B918-D17840D08AC3\nIII. Conclusion\nPSE believes that the operations center at Jackson Prairie does not fall within the scope of\nthe CRM Rule. Jackson Prairie field technicians are onsite and locally monitor and\ncontrol the operation of the Processing Facility equipment within the fenced boundary.\nThey have operational authority and accountability exclusively for the Processing Facility\nwithin the fenced boundary, the Storage Field within the property limits, and the Feeder\nLines. Northwest has sole control over the safety related operations of the Meter Station.\nWhile nothing in the CRM Rule requires pipeline operators to implement or use a\nSCADA system to remotely operate facilities, the remote monitoring and control of the\nMeter Station by Northwest effectively covers the Feeder Lines connecting the Meter\nStation to the Processing Facility at Jackson Prairie.\nPSE appreciates the Administrator’s time in providing a written interpretation of the\nCRM Rule applicability to the unique operational setup of Jackson Prairie. Should you\nhave any questions, please contact Vidushi Raina, Gas Pipeline Safety Compliance\nProgram Manager, at 425-424-7839 or vidushi.raina@pse.com.\nSincerely,\nKaaren Daugherty\nManager, Compliance and Quality Management\nKaaren.daugherty@pse.com\nCc:\nTroy Hutson, Puget Sound Energy\nMark Carlson, Puget Sound Energy\nPat Haworth, Puget Sound Energy\nRob Harmon, Williams Northwest Pipeline\nJody Morehouse, Avista\nSean Mayo, WUTC Director Pipeline Safety\nJohn Gale, PHMSA Director Standards & Rulemaking\n- 5 -","truncated":false,"body_characters":23579}