{"operation":"document","citation":"PI-99-0104","title":"Illinois Power Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-11-04","effective_on":null,"summary":"PI-99-0104 response to Illinois Power Company concerning 192.11.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0104.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0104.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-99-0104","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/1999/g99_11_04_HAMMOND_192.11_lmX.pdf","body":"<<<PAGE 1>>>\n\nPI-99-0104\n11/04/99\nMs. Amy L. Hammond\nAir Specialist\nIllinois Power Company\nP.O. Box 511\nDecatur, IL 62525-0511\nDear Ms. Hammond:\nThis is in response to your request for an interpretation of the federal jurisdiction over Illinois Power Company's (IPC)\npropane storage facility in Freeburg, Illinois. You request a determination of the applicability of 49 CFR §192.11 to the\npropane surge tank and the refrigerated storage sphere from which gas flows into the natural gas system for peak-\nshaving purposes.\nAll such \"pipeline facilities\" are within jurisdiction of the Natural Gas Pipeline Safety Act of 1968. A \"pipeline facility” is\ndefined in the Act to include “without limitation ... any equipment, facility, or building used in the transportation of gas\nor the treatment of gas during the course of transportation\" (49 U.S.C. 1671(4)). In the regulations for gas pipelines,\nSection 192.11(a) states:\nEach plant that supplies petroleum gas by pipeline to a natural gas distribution system must meet the requirements of\nthis part and ANSI/NFPA 58 and 59.\nPeak-shaving facilities are an interrelated and often essential part of a gas distribution system and fall within the\nintended coverage of the term \"\"pipeline facilities.\" Consequently, a propane air peak-shaving facility is in its entirety\nsubject to the jurisdiction of the Act.\nIf you have any questions regarding this matter, please contact Mike Israni at (202)366-4571 or Buck Furrow at (202) 3\n66-4559.\nSincerely,\nRichard D. Huriaux, P.E.\nManager, Regulations\nOffice of Pipeline Safety\n\n<<<PAGE 2>>>\n\nIllinois Power Company\nP.O. Box 5511\nDecatur, IL 62525-0511\nMay 24, 1999\nALH9910\nMr. Richard D. Huriaux\nManager of Regulations\nOffice of Pipeline Safety\nDepartment of Transportation\n400 7t\" Street, SW\nWashington, DC 20590\nDear Mr. Huriaux:\nIllinois Power Company submitted a request to the Department of Transportation on March 3, 1999 for a letter stating\nthat propane storage at Freeburg, Illinois is regulated by DOT §192.11(a). As mentioned in the original request, Illinois\nPower uses the propane from our Freeburg gas storage field to supplement our natural gas supply.\nAs I have not received a response to my letter, I would like to inquire about the status of this request. Please call me at\n217/424-8386 if you need any additional information to respond to this request. Thank you for your time.\nSincerely,\nILLINOIS POWER COMPANY\nAmy L. Hammond\nAir Specialist\n\n<<<PAGE 3>>>\n\nIllinois Power Company\nP.O. Box 5511\nDecatur, IL 62525-0511\nMarch 3, 1999\nMr. Richard D. Huriaux\nManager of Regulations\nOffice of Pipeline Safety\nDepartment of Transportation\n400 7t\" Street, SW\nWashington, DC 20590\nDear Mr. Huriaux:\nIllinois Power Company owns and operates a gas storage filed in Freeburg, Illinois that is used for peak-shabing\npurposes. At this storage field, we supplement natural gas with propane through the pipeline system. The propane is\nbrought in by truck and then transferred to a surge tank. From the surge tank, the propane is transferred to a large\nrefrigerated storage sphere, where it is piped into the natural gas system. The stored propane is used solely for the\npipeline system.\nI want to be sure that both the surge tank and the large storage sphere are covered under the Department of\nTransportation regulations. I spoke with Mr. Lloyd Ulrich on March 1, 1999, and asked him this same question. His\nresponse to me was that the propane storage is under jurisdiction of DOT regulations §192.11(a). Mr. Ulrich referred\nme to you when I requested a written document that supports this response. This information will allow Illinois Power\nto determine the applicability of the Environmental Protection Agency’s 112(r) rule to our natural gas facility.\nI would appreciate very much if you would fulfill this request and send me a letter or document stating that storage of\npropane, under these circumstances, is covered under the DOT regulations. If I can provide any additional information,\nplease call em at 217/424-8386. Thank you for your time.\nSincerely,\nIllinois Power Company\nAmy L. Hammond\nAir Specialist","truncated":false,"body_characters":4107}