{"operation":"document","citation":"PI-98-0103","title":"All American Pipeline Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-09-14","effective_on":null,"summary":"PI-98-0103 response to All American Pipeline Company concerning 192.3.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-0103.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-0103.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-98-0103","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1998/g98_09_14_Janak_192.3_Transmission%20Line_nlmx.pdf","body":"<<<PAGE 1>>>\n\nPI-98-0103\n9/14/98\nMr. Jordan R. Janak\nDirector, Regulatory Compliance\nAll American Pipeline Company\nPO Box 40160\nBakersfield CA 93384-0160\nDear Mr. Janak:\nThank you for your letter of April 8, 1998, regarding a low-stress 6-inch, 6.5-mile pipeline\nowned by your company that transports gas from a meter at an intrastate transmission line solely\nfor use at your company’s Cadiz pump station. You asked if the line, which you consider\ncustomer piping, must be reclassified as a transmission line.\nThe question arises because the line was the subject of a Final Order (CPF 52006), which found\nthat it did not meet the pre-1996 definition of “transmission line” under 49 CFR 192.3. But the\norder suggested the line would meet the revised definition because the line links a transmission\nline to a power plant.\nUnder the present definition of “transmission line,” the only relevant consideration in classifying\nthe line as transmission is whether the Cadiz pump station is a large volume customer. The\ndefinition describes such a customer as one that receives a volume of gas similar to that received\nby a distribution center, and gives as examples factories, power plants, and institutional users of\ngas. While we agree that the Cadiz pump station is not a power plant, the data you furnished\nabout the volume of gas the line transported last year (23 mcfd on average, maximum 60 mcfd)\nindicate that the station receives volumes similar to that received by a distribution center serving\na small community. Although these volumes may be far less than volumes received by towns\nand plants in the area of the Cadiz pump station, the transmission line definition refers to\ndistribution centers in general. Therefore, as long as the line continues to transport gas in\nvolumes similar to that received by a distribution center, the line must be classified as a\ntransmission line.\nSincerely,\nRichard D. Huriaux, P.E.\nRegulations Manager\nOffice of Pipeline Safety\nLMFurrow:jmd:64046:8-13-98\ncc: DPS-1,2,10,20,TSI.,StateMailing\n192.3 TRANSMIL 1","truncated":false,"body_characters":2046}