# Arizona Corporation Commission — Pipeline Safety Interpretation

- **operation:** document
- **citation:** PI-91-0103
- **title:** Arizona Corporation Commission — Pipeline Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 1991-05-30
- **effective on:** Not available
- **summary:** PI-91-0103 response to Arizona Corporation Commission concerning 192.3.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-91-0103.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-91-0103.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-pi-91-0103
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1991/g91_05_30_Weaklend_192.3_Main_nlmx.pdf
**body:**

<<<PAGE 1>>>

PI-91-0103
Mr. Dan H. Weaklend
Chief, Pipeline Safety
Arizona Corporation Commission
1200 W. Washington
Phoenix, AZ 85007
Dear Mr. Weaklend:
I am responding to your letter of March 4, 1991, concerning the classification of pipelines under
49 CFR 192 as transmission lines or mains. You asked about four pipelines shown as #1, #2, #5,
and #6 on enclosures. You also asked if pressure reduction points shown as #3 and #4 on the
enclosures are pressure limiting or regulating stations.
The Part 192 regulations contain the following definitions that re relevant to this discussion:
Distribution line means a pipeline other than a gathering or transmission line.
Main means a distribution line that serves as a common source of supply for more than one
service line.
Transmission line means a pipeline, other than a gathering line, that:
(a) Transports gas from a gathering line or storage facility to a distribution center or
storage facility;
(b) Operates at a hoop stress of 20 percent or more SMYS; or
(c) Transports gas within a storage field.
Comprehension of the term, "distribution center," is essential to use of the transmission line
definition. As we apply the term, it is the point where gas enters piping used primarily to deliver
gas to customers who purchase it for consumption as opposed to customers who purchase it for
resale.
Line #1, which operates at less than 20 percent of SMYS, begins at a pressure limiting and
metering station on an interstate natural gas transmission pipeline. From there the line extends to
a series of pressure reduction points, beyond which the gas is distributed to consumers. Because
there does not appear to be any transfer of gas to customers for resale beyond the pressure
limiting and metering station, this station marks a distribution center under the above description.
Line #1 is, therefore, a distribution line, or main, as it is a common source of supply for more
than one service line.
192.3 DISTLINE 1

<<<PAGE 2>>>

Line #2 runs between the last pressure reduction point on Line #1 and another pressure reduction
point. It is an extension of Line #1 and is, thus, a main.
Lines #6 and #6 are like Line #1, except they extend to fewer pressure reduction points than Line
#1, and, on Line #6, two of these points are on connecting laterals. Since these dissimilarities to
Line #1 are not relevant for the purpose of classification, Lines #5 and #6 are mains.
As for pressure reduction points #3 and #4, Part 192 does not define pressure limiting or
regulating stations, though we have a rulemaking project to create a Part 192 definition for these
terms. Terms used in Part 192 that are not defined in Part 192 have the ordinary meaning in the
industry. We rely on the definitions in the B31.8 Code as indicative of the ordinary meaning of
such terms in the industry. Based on the B31.8 definitions of pressure limiting or regulating
station and of service regulator, point #3 is a pressure limiting or regulating station and point #4
is a service regulator.
Please call me if you need any further help in this matter.
Sincerely,
/signed/
Cesar DeLeon
Director for Pipeline Safety
Regulatory Programs
192.3 DISTLINE 2
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