{"operation":"document","citation":"PI-92-013","title":"Attorney for Phillips Alaska Natural Gas Corporation — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1992-03-27","effective_on":null,"summary":"PI-92-013 response to Attorney for Phillips Alaska Natural Gas Corporation concerning 193.2005.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-013.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-013.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-92-013","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1992/PI92013.pdf","body":"<<<PAGE 1>>>\n\nMar 27 1992\nMr. Larry Pain\nAttorney for Phillips Alaska\nNatural Gas Corporation\n1256 Adams Building\nBartlesville, OK 74004\nDear Mr. Pain:\nThis letter responds to your petition dated August 26, 1991, regarding the Kenai LNG Plant (Docket No.\nP-47). Although you filed the petition under 49 CFR 193.2015, we are treating the petition as a request\nfor information. Section 193.2015 is a procedural rule governing petitions for findings or approvals that\nare specifically authorized by substantive rules in Part 193, such as § 193.2059(e). Your petition does\nnot request such a finding or approval.\nYou asked whether modifications (described in the petition) that are planned for the Kenai LNG Plant\nwould cause the plant to lose its grandfather status under the siting, design, installation, and construction\nrequirements of Part 193. The modifications that are planned would not cause the entire Kenai LNG\nPlant to lose its grandfather status under the siting, design, installation, and construction requirements of\nPart 193.\nWhile the entire plant may not lose its grandfather status, § 193.2005(b) provides that LNG facilities\n(defined in § 193.2007) that are replaced, relocated, or significantly altered are subject to Part 193\nstandards governing siting, design, installation, and construction (with certain exceptions). Thus, if an\nLNG facility at the Kenai LNG Plant is replaced, relocated, or significantly altered by the planned\nmodifications, that facility would lose its grandfather status to the extent prescribed by § 193.2005(b). In\ncontrast, grandfathered LNG facilities at the Kenai LNG Plant that are not replaced, relocated, or\nsignificantly altered are not covered by § 193.2005(b), and would retain their grandfather status.\nIt appears that of the planned modifications in your petition, the replacement of one or both existing LNG\ntransfer pumps is the only LNG facility that will be replaced, relocated, or significantly altered and would\nlose its grandfather status to the extent prescribed by § 193.2005(b). However, this modification would\nnot have to meet the siting requirements since, in accordance with § 193.2005(b)(1), only an LNG\nstorage tank that is relocated or significantly altered by increasing the original storage capacity would\nhave to meet the siting requirements.\nYour petition indicates that the planned modifications may include installation or construction of new\ncomponents that do not constitute replacements or significant alterations of grandfathered facilities. If\nso, these new components would be subject to all applicable requirements governing siting, design,\ninstallation, and construction.\nYou also asked us to determine that the designs for the planned modifications are consistent with 49 CFR\nPart 193 or are otherwise acceptable. The Part 193 regulations allow operators to construct and operate\nLNG facilities without prior approval by this agency. We normally do not review operators’ design and\nconstruction plans except during, or in preparation for, routine compliance inspections, which are handled\nby our regional offices. Therefore, we are not at this time determining whether the planned modifications\ncomply with Part 193 or would otherwise be acceptable.\n193.2005 193.2005\n92-03-27.doc 193.2007\n\n<<<PAGE 2>>>\n\nI apologize for the tardiness of this response. concerns about the Part 193 regulations.\nDo not hesitate to contact us again if you have further\nSincerely,\nCesar De Leon, Director\nRegulatory Programs\nOffice of Pipeline Safety\n193.2005 193.2005\n92-03-27.doc 193.2007","truncated":false,"body_characters":3557}