{"operation":"document","citation":"PI-92-011","title":"National Gas and Oil Corporation — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1992-03-12","effective_on":null,"summary":"PI-92-011 response to National Gas and Oil Corporation concerning 192.167.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-011","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1992/PI92011.pdf","body":"<<<PAGE 1>>>\n\nMarch 12, 1992\nMr. John B. Hartnett\nVice President and Chief Operating Officer\nNational Gas and Oil Corporation\n1500 Granville Road\nP.O. Drawer AF\nNewark, Ohio 43055-0693\nDear Mr. Hartnett:\nThis responds to your letter of December 13, 1991, asking for our interpretation of 49 CFR\n192.167(a). National Gas and Oil Corporation (National) operates two natural gas compressors\nat the Perry Storage site. Compressors No. 1 and No. 5 are rated at 415 and 634 horsepower,\nrespectively. The compressors are located in separate buildings approximately 35 feet apart.\nPerry Storage is a gas storage field where gas is injected in the off season and withdrawn for use\nin periods of high demand. You ask for our interpretation whether an emergency shutdown\nsystem is required for Perry Storage pursuant to 49 CFR 192.167(a).\nSection 192.167(a) states: \"Except for unattended field compressor stations of 1,000 horsepower\nor less, each compressor station must have an emergency shutdown system. . . .\" You describe the\nPerry Station as unattended with a continuously manned control center for your entire pipeline\nsystem located 92 feet from the nearest compressor. Although personnel are not assigned to the\ncompressors during operation, we view the station as being attended, because personnel are\nimmediately available to respond to problems that may arise at the station.\nThe Research and Special Programs Administration (RSPA) interprets \"field compressor stations\"\nin § 192.167(a) to mean temporary installations operating in rural areas. These compressors are\noften skid mounted for ease in moving from site to site as the need arises. Field compressor\nstations usually do not have electricity available to power emergency shutdown systems. In such\ncases, it is not practical to install emergency shutdown systems. Because National's Perry\ncompressors are permanently installed, they do not qualify as field compressors.\nYou state that the term \"field compressor stations of 1,000 horsepower or less\" is unclear\nregarding whether each compressor horsepower rating should be considered individually or if the\nhorsepower ratings of all compressors in a station should be added when making a determination.\nSince both of National's compressors boost pressures for injecting natural gas into the Perry\nStorage, the horsepower is additive. The total compressor capacity at National's Perry Station is\n1,049 horsepower.\njt\n192.167/92-03-12\n\n<<<PAGE 2>>>\n\nBecause National's compressors are attended, permanently installed and overall compressor\ncapacity exceeds 1,000 horsepower National's Perry Station is not excluded from complying with\nthe provisions of § 192.167(a). We trust that this responds sufficiently to your request.\nSincerely,\nCesar De Leon\nDirector, Regulatory Programs\nOffice of Pipeline Safety\njt\n192.167/92-03-12","truncated":false,"body_characters":2833}