{"operation":"document","citation":"PI-93-001","title":"Memo: External — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1993-01-14","effective_on":null,"summary":"PI-93-001 response to Memo: External concerning 193.2001.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-001","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93001.pdf","body":"<<<PAGE 1>>>\n\nJanuary 14, 1993\nTO ALL STATE PIPELINE SAFETY PROGRAM MANAGERS\nEnclosed, for your information, is a copy of correspondence\nrelated to the formation of a committee to develop proposals for\nrevising regulations applicable to mobile LNG facilities. This\ninformation is being provided to you so that you might use the\nwaiver process to take interim action on these types of\nfacilities.\nAlso enclosed is a copy of a memorandum from Cesar De Leon\nregarding the application of regulations to these facilities\n(this memorandum was sent to you earlier in a pipeline safety\ninformation mailing -- SR-92-136).\nSincerely,\nG. Tom Fortner\nOffice of Pipeline Safety Compliance\nEnclosures\ndal\\193\\2001\\93-01-14\n1\n\n<<<PAGE 2>>>\n\n1993\nTO: Chris Bourne, MA\nPaul Grieco, RI\nStanley Kastanas, Colonial Gas Company\nRichard Marini, NH\nPhilip Sher, CT\nThis memorandum is in regard to the December 11, 1992, letter\nfrom Chris Bourne to Richard Marini about regulation of mobile\nLNG facilities.\nRather than establishing a moratorium on enforcement of 49 CFR\nPart 193 with respect to mobile LNG facilities, I believe it\nwould be preferable for those adversely affected by application\nof Part 193 to mobile LNG facilities to seek relief through the\nwaiver process. For those mobile LNG facilities that are subject\nto state regulatory authority, the LNG operators must apply for a\nwaiver from the state agency; and if a waiver is granted, the\nResearch and Special Programs Administration (RSPA) would have 60\ndays to affirm or reject the waiver. For mobile LNG facilities\nsubject to Federal regulatory authority, the LNG operators must\napply to RSPA for a waiver.\nWhile we applaud the initiative to form a committee to submit\nproposals for revisions to the regulations applicable to mobile\nLNG facilities, we cannot sponsor such a committee and request\nthat it not be characterized as a \"DOT LNG Committee.\" The\nFederal Advisory Committee Act of 1972 establishes specific\nrequirements for committees to advise government agencies that\nmake it difficult for RSPA to sponsor such a committee. Instead,\nwe suggest that your committee be a state-sponsored effort, and\nbe identified as such.\nIf you need further advice on this matter, please call Tom\nFortner at 202-366-4564.\nSincerely,\nGeorge W. Tenley, Jr.\nAssociate Administrator for\nPipeline Safety\ndal\\193\\2001\\93-01-14\n2\n\n<<<PAGE 3>>>\n\nNov 2, 1992\nINFORMATION: Mobile LNG facilities\nCesar De Leon, Director\nPipeline Safety Regulatory Programs, DPS-10\nRichard Sanders, Manager\nPipeline Safety Division, DMA-607\nYour memo of June 17, 1992, describes a unit consisting of LNG\nstorage cylinders, a vaporizer, and connection devices all\nmounted an a tractor-trailer. Operators temporarily connect such\nunits to gas pipeline distribution systems to furnish gas when\nthe normal supply is disrupted. You asked whether the unit is a\npipeline facility subject to 49 CFR Part 192.\nBecause the unit is used in the transportation of gas by pipeline\nthat is regulated by Part 192, the unit is an LNG facility\nsubject to the safety standards in 49 CFR Part 193\n(?193.2001(a)). Amendments 192-36 and 193-2 (45 FR 70390;\nOctober 23, 1990) repealed the application of Part 192 to LNG\nfacilities, except as provided by ?193.2005(C). Under that\nsection, an operator may elect to comply with Part 192 and NFPA\n59A (1972 edition), instead of Part 193, with regard to siting,\ndesign, installation, and construction of certain existing\nfacilities. So the unit would not be subject to Part 192 unless\nit's covered by ?193.2005(c) and the operator has elected to\ncomply with Part 192.\nWe recognize that compliance with the siting requirements of Part\n193 may be difficult or overly burdensome for some mobile LNG\nfacilities, considering the temporary nature of their use at\nparticular sites. In this regard, we invite your comments as to\nhow the siting requirements might be changed to lighten the\ncompliance burden without sacrificing safety. Keep in mind that\nsome existing mobile facilities may be except from those\nrequirements to the extent provided by the grandfather provisions\nof ?193.2005. Also, when mobile LNG facilities are in transit or\nare otherwise not being used in the pipeline transportation of\ngas, the Part 193 requirements do not apply.\n#\ndal\\193\\2001\\93-01-14\n3","truncated":false,"body_characters":4293}