{"operation":"document","citation":"PI-97-0100","title":"Mr. Chuck Hudson — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1997-05-06","effective_on":null,"summary":"PI-97-0100 response to Mr. Chuck Hudson concerning 193.2001, 193.2513, 193.2621.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-0100.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-0100.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-97-0100","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1997/g97_05_16_Hudson_193.2001_olox.pdf","body":"<<<PAGE 1>>>\n\nPI-97-0100\nU.S. Department of Transportation\nResearch and Special Programs Administration\n400 Seventh Street, S W\nWashington, D.C. 20590\nMAY 6\nMr. Chuck Hudson\nSenior Pipeline Safety Engineer Utilities Division\nArizona Corporation Commission 1200 West Washington,\nPheonix, AZ 85007\nDear Mr. Hudson:\nThis is in response to your letter of March 26, 1997, in which you requested an interpretation of 49 CFR § 193.2001 in\nregard to an LNG facility shown on the drawing attached to your letter. According to your letter the transmission\npipeline that supplies the natural gas for liquefaction is owned and operated by El Paso Natural Gas. The liquefaction\nfacility and piping is owned and operated by a subsidiary of El Paso Natural Gas, and the LNG storage facility and truck\ntransfer system is operated by a company independent from El Paso. However, the land on which the storage facility\nsits is owned by El Paso Natural Gas.\nThe Research and Special Programs Administration agrees with the Arizona Corporation Commission's conclusion\nthat, regardless of who owns or operates different sections of an LNG facility, it is subject to Part 193 in its entirety.\nPart 193 covers all parts of an LNG facility from the point at which it receives gas from a Part 192 regulated gas\ntransmission pipeline through the liquefaction process, storage, and transfer into a motor carrier vehicle.\nIf we can be of further assistance in this matter, please contact me or Mr. Mike Israni of my staff at (202)366-4571.\nSincerely,\nRichard D. Huriaux\nDirector, Technology & Regulations\n\n<<<PAGE 2>>>\n\nArizona Corporation Commission\n1200 West Washington\nPhoenix, Arizona 85007\nMarch 26, 1997\nCertified Mail\nMr. Richard Felders\nDirector, Office of Pipeline Safety\nU. S. Department of Transportation\n400 7th Street S.W.\nWashington, DC 20590\nRE: CLAIRIFICATION OF PART 193\nDear Mr. Felders:\nUsing the scope of 193.2001, please identify the facilities subject to the regulations of Part 193 on the enclosed\ndrawing.\n193.2001(a) states that this part is applicable to LNG facilities used in the transportation of LNG.\n193.2001(b) states that this part does not apply to:\n(1) LNG facilities used by the ultimate consumer of LNG or Natural Gas.\nAt this facility the LNG will be trucked out to be utilized by various consumers, therefore this does not\napply.\n(2) LNG facilities used in the course of natural gas treatment or hydrocarbon extraction which do not store\nLNG.\nAt this facility there is no treatment of natural gas or extraction of hydrocarbons, therefore this does\nnot apply.\n(3) In the case of a Marine Cargo Transfer System and associated facilities.\nAt this facility there are no Marine Cargo Transfer System, therefore this does not apply.\n(4) Any LNG facility located in navigable waters.\nAt this facility there are no navigable waters, therefore this does not apply.\nThis facility will be connected to a transmission pipeline facility which is fully regulated by Part 192.\nThe LNG liquification facility is connected to the regulated pipeline and the LNG storage facility is connected to\nthe liquification facility by a pipeline.\nSection 193.2211 and 193.2213 defines how storage tanks must be constructed by referencing a Standard.\nSection 193.2231 defines how a cargo transfer area must be designed.\nSection 193.2513 defines requirements that must be met before transferring LNG from a storage facility into a\ncargo vehicle.\n\n<<<PAGE 3>>>\n\nSection 193.2621 defines test requirements for the testing of transfer hoses.\nThe transmission pipeline that supplies the natural gas for liquification is owned and operated by a transmission\npipeline company. The liquification and piping into the storage container is owned and operated by a subsidiary of the\ntransmission pipeline company and the storage containers and transfer system utilized to transfer the LNG from the\nstorage facility into a motor carrier vehicle is operated by a company independent from the other two operators.\nHowever, the land on which the storage facility sits is owned by the transmission pipeline company.\nIn review of the facts surrounding this facility the Arizona Corporation Commission's Office of Pipeline Safety\nfeels that this facility from the point where it takes natural gas from the transmission pipeline (which is fully regulated\nunder Part 192) through the liquification process, the storage facility right through the point of transfer into the motor\ncarrier vehicle is fully regulated by Part 193.\nPlease identify on the enclosed drawing which facilities that are subject to the Pipeline Safety Regulations. If you\nfind that any of the facilities on the enclosed drawing are not subject to the regulations, please provide an explanation\nas to why they are not subject to the Regulations.\nThank you for your consideration in this matter and your continued interest in Pipeline Safety. Should you have\nany questions on this matter, please contact me at (602) 542-3316.\nSincerely,\nChuck Hudson\nSenior Pipeline Safety Engineer\nUtilities Division","truncated":false,"body_characters":5031}