{"operation":"document","citation":"PI-93-027","title":"Memo: Internal — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1993-06-03","effective_on":null,"summary":"PI-93-027 response to Memo: Internal concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-027.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-027.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-93-027","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1993/PI93027.pdf","body":"<<<PAGE 1>>>\n\nJune 3, 1993\nSUBJECT: DOT JURISDICTION - BOILERS\nTO: I. Huntoon\nFROM: R. J. Lecznar\nAs we discussed last Friday, attached is a summary of various uses of process heat\nat our compressor stations. Simply stated, the compressor stations can not operate\nwithout the steam/hot boilers. We believe that our boilers are used in the \"transportation\nof gas\" and therefore, are \"pipeline facilities.\" Also, our compressor stations are subject to\nthe jurisdiction of the Federal Energy Regulatory Commission (FERC) and, therefore are\n\"interstate transmission facilities.\"\nANR Pipeline currently operates pipeline facilities in sixteen states and includes\ninspection/maintenance requirements for boilers in our O & M Manual. These\nrequirements apply to all boilers regardless which state the boilers is located.\nHopefully, the information will be useful in your discussions of boilers at your\nmeeting next week.\ndal\\192.3\\93-06-03\n\n<<<PAGE 2>>>\n\nJune 2, 1993\nNatural Gas Compressor Station\nGas Fired Steam and Hot Water Boilers\nANR Pipeline Company utilizes either natural gas fired steam or hot water boilers\nat its gas compression facilities for the following uses:\na) Process heating of the incoming gas stream in the fuel gas system to raise\nthe gas temperature above the predicted hydrate formation temperature prior to regulating\nthe pressure from the higher pipeline pressure to the lower fuel gas system operating\npressure. If a hydrate formed, the \"freeze off\" would block the flow of gas through the\nfuel system, and the station would cease to operate. Fuel gas is used by the\nengine/compressor units, generator sets, gas fired water bath heaters, gas fired glycol\nregenerators, boilers, etc.\nb) Process heating of the Compressor Engine lubricating oil, prior to engine\nstart-up. Lubricating oil is preheated and pumped through the engine/compressor unit to\nassure proper lubrication of all metal to metal contact points, ie.[sic] crank and rod\nbearings, cylinder walls, turbochargers, etc. Allowing the oil to reach its proper viscosity\nalso provides for an easier roll of the engine and faster engine starts.\nc) Process heating of the engine coolant prior to engine start-up. Like the\nlubricating oil preheat, preheating the coolant provides for easier starts of the engine\ncompressor units and allows the unit to come up to operating temperature more quickly.\nd) Building heat for personnel and equipment.\nGas compression facilities within the ANR system that have boilers, regardless of\nlocation, use them for both heating of the fuel gas (item a) and building heat (item d) .\nNorthern locations, in addition to items a and d above, also use the boilers for items b and\nc to assure proper and timely starting during peak winter heating periods. While there are\nother substitute pieces for most of the above processes, ie. [sic] catalytic heaters, electrical\ninsertion or immersion heaters, etc., it would be difficult to provide a safe and effective\nalternative for fuel gas preheating. The steam/hot water boiler system has thus far proven\nto be the best arrangement for providing a heating medium source for ANR Pipeline.\ndal\\192.3\\93-06-03\n\n<<<PAGE 3>>>\n\nPART 192 - TRANSPORTATION OF NATURAL AND OTHER GAS BY PIPELINE:\nMINIMUM FEDERAL SAFETY STANDARDS\n§ 192.13 General.\n(a)\n(b)\n(c) Each operator shall maintain, modify as appropriate, and follow the plans,\nprocedures, and programs that it is required to establish under this part.\n[35 FR 13257, Aug. 19, 1970, as amended by Amdt. 192-27, 41 FR 34605, Aug. 16,\n1976; Amdt. 192-30, 42 FR 60148, Nov. 25, 1977]\n§ 192.603 General provisions.\n(a) No person may operate a segment of pipeline unless it is operated in accordance\nwith this subpart.\n(b) Each operator shall establish a written operation and maintenance plan meeting the\nrequirements of this part and keep records necessary to administer the plan.\n(c) The Administrator or the State Agency that has submitted a current certification\nunder section 5(a) of the Natural Gas Pipeline Safety Act with respect to the pipeline\nfacility governed by an operator's plans and procedures may, after notice and\nopportunity for hearing as provided in 49 CFR 190.237 or the relevant State procedures,\nrequire the operator to amend its plans and procedures as necessary to provide a\nreasonable level of safety.\n[Amdt. 192-66, 56 FR 31090, July 9, 1991]\n§ 192.605 Essentials of operating and maintenance plan.\nEach operator shall include the following in its operating and maintenance plan:\n(a) Instructions for employees covering operating and maintenance procedures during\nnormal operations and repairs.\n(b) Items required to be included by the provisions of Subpart M of this part.\n(c) Specific programs relating to facilities presenting the greatest hazard to public\nsafety either in an emergency or because of extraordinary construction or maintenance\nrequirements.\n(d) A program for conversion procedures, if conversion of a low-pressure distribution\nsystem to a higher pressure is contemplated.\n(e) Provision for periodic inspections to ensure that operating pressures are\nappropriate for the class location.\ndal\\192.3\\93-06-03\n\n<<<PAGE 4>>>\n\n(f) Instructions enabling personnel who perform operation and maintenance activities to\nrecognize conditions that potentially may be safety-related conditions that are subject to\nthe reporting requirements of § 191.23 of this subchapter.\n[Amdt. 192-59, 53 FR 24950, July 1, 1988]\ndal\\192.3\\93-06-03\n\n<<<PAGE 5>>>\n\nJuly 8, 1985\nMr. A. D. Simpson, III\nAttorney at Law\nTennessee Gas Pipeline\nDivision of Tenneco Inc.\nTenneco Building\nP. O. Box 2511\nHouston, Texas 77001\nDear Mr. Simpson:\nThis responds to your letter of January 22, 1985, transmitting a November 13, 1984, letter\njointly submitted by you and Guy N. Rogers of the Mississippi State Department of\nHealth, which describes three categories of gas compressor station facilities operated by\nyour company in Mississippi. You ask for a ruling and interpretation on whether, under\nthe Natural Gas Pipeline Safety Act of 1968, as amended (NGPSA) (49 U.S.C. 1671 et\nseq.), the facilities are \"pipeline facilities,\" whether they are \"used in the transportation of\ngas,\" and whether they are preempted from State safety regulation. The Department of\nTransportation has no mechanism for issuing formal rulings or interpretations on the issue\nof preemption under the NGPSA.\nThe gas pipeline safety standards (49 CFR Part 192) issued pursuant to the NGPSA are\napplicable, with enumerated exceptions, to pipeline facilities and the transportation of gas.\nThe term \"pipeline facilities,\" as used in both the NGPSA and the standards (49 U.S.C.\n1671(4) and 49 CFR 192.3), includes gas pipelines, rights-of-way, and any equipment,\nfacility, or building used in the transportation of gas or the treatment of gas during the\ncourse of transportation. Many of the standards are written in terms that apply to\nparticular kinds of pipeline facilities, including compressor stations. Others apply to\npipeline facilities in general. Part 192 does not contain standards that are particularly\napplicable to boilers or air receivers. Nevertheless, if such equipment is used in the\ntransportation of gas by pipeline, it would have to meet applicable Part 192 regulations\nthat govern pipeline facilities in general.\nUse in gas transportation is not defined. However, in light of the NGPSA's safety\npurpose, we view the circumstances under which a facility is used in gas transportation\nbroadly. Thus, pipeline facilities includes not only equipment that is used directly or\nphysically connected to the movement of gas, but also equipment that is related to the\ntransportation process. Equipment in this latter category would include, for example, fire\nprotection facilities and fencing located at compressor stations because their purpose is\nrelated to the gas carrying facilities. It also would include boilers and air receivers located\nin shops, yards, or offices at compressor stations when the purpose of the equipment is\ntransportation related. Whether particular boilers or air receivers at compressor stations\nare sufficiently related to the transportation of gas to be pipeline facilities would depend\non the circumstances surrounding their use.\ndal\\192.3\\93-06-03\n\n<<<PAGE 6>>>\n\n2\nIn regard to the three categories of facilities of concern to you, their general descriptions\nand drawings indicate that the air tanks and boilers each bear a substantial relation to\noperation of gas compressors. We think, therefore, it is reasonable to view these facilities\nas \"used in the transportation of gas\" and, thus, \"pipeline facilities.\" Furthermore,\nassuming that the lines to which these facilities appertain are interstate, that is, subject to\nthe jurisdiction of the Federal Energy Regulatory Commission, we consider these facilities\nto be interstate transmission facilities.\nAs to the question of preemption, the NGPSA restricts the application of State laws to\npipeline facilities as follows:\n\"Any State agency may adopt additional or more stringent safety standards for\nintrastate pipeline transportation if such standards are compatible with the Federal\nminimum standards. No State agency may adopt or continue in force any such\nstandards applicable to interstate transmission facilities, after the Federal minimum\nstandards become effective.\" (49 U.S.C. 1672(2))\nWe trust that this letter is helpful to you. A similar letter is being mailed to Guy N.\nRogers. The individual compressor station drawings are being returned to you separately.\nSincerely,\nRichard L. Beam\nAssociate Director for\nPipeline Safety Regulation\nMaterials Transportation Bureau\ndal\\192.3\\93-06-03","truncated":false,"body_characters":9666}