{"operation":"document","citation":"PI-84-0102","title":"Pipeline Safety Interpretation PI-84-0102","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1984-06-01","effective_on":null,"summary":"PI-84-0102 concerning 193.2001.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0102.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0102.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-84-0102","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1984/g84-06-01_Beacon_193.2001-olox.pdf","body":"<<<PAGE 1>>>\n\nPI-84-0102\nJune 1, 1984\nMr. V. E. Beacon\nVice President\nCommereial and Division Operations\nNorthern States Power Company\n100 North Barstow Street\nP. O. Box 8\nEau Claire, Wisconsin 34702\nDear Mr. Beacon:\nThis responds to your letter of May 22, 1984, regarding the proposed construction of a Wilding at the Eau\nClaire LNG plant site. The building would house five LNG plant personnel and serve as a gas/electric meter\nmaintenance shop.\nIn our opinion, the regulations in 49 CPR Part 193 do not prohibit construction of the building at the Eau Claire\nLNG plant site. It is important to not, however, that if the building is. to be toed in relation to any of the LNG\nplant processes, it would qualify as an \"LNG facility\" under the definition of that term in Part 193, and be\nsubject to applicable Part 193 requirements. Moreover, even if the proposed building is not an \"LNG facility\",\nsince it is to be located on the LNG plant site, it would be subject to the gas monitoring and alarm\nrequirements of 81.93.2819(f).\nWe do not think that the mere housing of-ING plant personnel during the course of non-LNG related meter\nrepair duties would be a usage sufficiently connected to LNG plied processes to qualify the building as in \"LNG\nfacility.\" A more direct connection to LNG processes would be required. For example, your letter said the\npersonnel may perform security and operational response functions. If in so doing they use communication,\ncontrol, or monitoring equipment that is located in the building, the building would provide a direct link to\nplant processes that would qualify the building as an \"LNG facility.\" Examples of other usages that would make\nthe building an \"LNG facility's would be the housing of emergency equipment, maintenance vehicles, or\nmaintenance materials.\nWe hope this information is helpful to you.\nSincerely,\nOriginal signed by\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\n\n<<<PAGE 2>>>\n\nNorthern States Power Company\n100 North Barstow Street\nP.O. Box 8\nEau Claire, Wisconsin 54702\nMay 22, 1984\nMr. Richard Beam\nAssociate Director for Pipeline Safety Regulation\nMaterials Transportation Bureau\n400 Seventh Street S.W.\nWashington, DC 20590\nDear Mr. Beam:\nOn Tuesday, May 15, 1984, our Engineer in Gas Operations, Perry Kuznar, spoke with your associate, Walt\nDennis, on our proposal to build a combination gas/electric meter shop/maintenance building on our Eau\nClaire, Wisconsin LNG Plant site. Our concern was that the existing 193 Code would disallow its construction\non that site for reasons within the Code. Upon talking with Mr. Dennis, however, it was decided that the\nproposed building could be built on our site due to the following:\n1. Eau Claire LNG Plant was built in 1968 and put into production on September 2, 1969. This preceded\nthe introduction of the 49 CFR Part 193 rules. The plant was built under the rules of NFPA 59A, 1967 edition.\nThere were no provisions for the regulation of new buildings on site at this time.\n2. The proposed shop will house 5 LNG operators. These operators will have dual ratings in LNG operation\nand in electric or gas meter repair. Having these men on site will give the following advantages:\na. Operators on site for at least 8 hours per day versus the approximate 2 hours per day at\npresent. Security of both the plant and its functions are greatly enhanced.\nb. Response to plant alarms or malfunctions can be handled quickly by men on site versus calling\nmen in from a distant source.\nc. Operators will be exposed more to the plant and thus remain more familiar with it than\nsomeone who works there on a rotating basis (as we do now).\nAs was discussed with Mr. Dennis, we plan to make this new facility as safe as possible for the occupants who\nwork in it. We realize that although our plant is grandfathered, we still must try to conform to the highest\nsafety standards possible for our given situation.\nIn conclusion, we'd like to thank Mr. Dennis for his time to give us this information. Walt had said to keep on\nfile all information necessary on our plant and the codes it was built under for future reference, if needed, by\nyour office. We, therefore, are going to actively pursue the building of this combination meter shop\nmaintenance building on the Eau Claire LNG Plant site. If, for any reason you have exception to this proposed\nbuilding, we ask that you inform us of such in writing by June 30, 1984. After that time we will commence with\nthe construction of the building.\nThank you very much for your help.\nSincerely,\nV. E. Beacom\nVice President\nCommercial and Division Operations","truncated":false,"body_characters":4646}