Division Of Public Utilities and Carriers — Pipeline Safety Interpretation

Page 1May 20, 1999 Mr. James J. Malachowski Administrator Division Of Public Utilities and Carriers 100 Orange Street Providence, RI 02903 Dear Mr. Malachowski: This is in response to your letters of July 19 and September 6, 1996, concerning proposed changes to the existing Algonquin Liquefied Natural Gas (ALNG) facility in Providence, Rhode Island. You requested the Office of Pipeline Safety (OPS) to review ALNG’ s plans for facility modifications, and advise your office whether these modifications constitute a “ significant alteration.” Review of the site plans and description of the ALNG modifications to the existing LNG facility in Providence, RI, indicate that the following modifications and inspections ALNG proposes to undertake: (1) addition of pumps and vaporizers for high pressure sendout, (2) replacement of the existing low pressure vaporizers, (3) inspection of the existing LNG tank, (4) addition of a gas liquefaction system. Rules governing the applicability of the siting, design, installation, and construction standards are set forth in 49 CFR §193.2005. Under that section, the new vaporizers and liquefaction facilities proposed by ALNG would be subject to Part 193. However, the current Part 193 requirements for siting, design and construction may not be applied to ALNG’ s existing storage tank. The storage tank is not being replaced or relocated, nor is the proposed work on the tank “ significant.” Furthermore, OPS is not in a position to comment on the significance of the alterations to ALNG facility in relation to the applicability of the “ Building Officials and Code Administrators International, Inc.” (BOCA) standards, because the Department of Transportation has not adopted the BOCA code. If we can be of further assistance in this matter, please#

Page 2contact me or Mr. Mike Israni of my staff at (202)366-4046. Sincerely, Richard B. Felder Associate Administrator for Pipeline Safety#