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Interpretation Response #PI-16-0013


Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 10-15-2019
Company Name: MarkWest Javelina Pipeline Company, LLC    Individual Name: Ms. Leanne M. Meyer
Location state: CO    Country: US

View the Interpretation Document


Response text:

Ms. Leanne M. Meyer
VP Environmental, Safety, Pipeline Integrity
and Operations Support Services
MarkWest Javelina Pipeline Company, LLC
1515 Arapahoe Street, Tower 1, Suite 1600
Denver, CO 80202-2137

Dear Ms. Meyer:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you requested an interpretation of 49 CFR Part 192. You specifically requested an interpretation of §192.3 for a definition of a transmission pipeline. You requested an interpretation for your eight intrastate pipeline systems that transport off-gas (consisting of non-condensable vents from various refinery process units containing light hydrocarbon components) from six refineries to your Javelina facility located in Corpus Christi, Texas. You requested these eight intrastate lines to be reclassified from transmission lines to Type B regulated gathering lines.

You provided the following information about the pipeline systems: the pipelines range from 0.2 to 1.54 miles in length and from 16 to 24 inches in diameter with a maximum allowable operating pressure (MAOP) of 99 psig, and the percentage specified minimum yield strength (SMYS) ranges from 9 to 14 percent. You also provided a summary table of the characteristics of the eight pipelines.

Furthermore, in an email you provided maps and additional information. You stated that the Javelina facility receives the off-gas from 6 refineries, separates the products into valuable components, and sends the residue gas back to the refineries to be used as fuel.

Gas gathering pipelines in §192.3 are defined as pipelines that transport gas from a production facility to a transmission line or main. Generally, gathering pipelines collect gas from natural gas wells and transport them to a processing facility, refinery or a transmission pipeline. 49 C.F.R. §§ 192.3 and 192.8. Transporting off-gas from refineries does not qualify the pipelines in question as gathering pipelines.

Section 192.3 defines a transmission line as:

Transmission line means a pipeline, other than a gathering line, that: (1) Transports gas from a gathering line or storage facility to a distribution center, storage facility, or large volume customer that is not down-stream from a distribution center; (2) operates at a hoop stress of 20 percent or more of SMYS; or (3) transports gas within a storage field.

NOTE: A large volume customer may receive similar volumes of gas as a distribution center, and includes factories, power plants, and institutional users of gas.

The Javelina facility is a large volume customer because it is a manufacturing facility that processes refinery off-gas, and with all six refineries on line, the Javelina facility can process up to 142 mmscfd of off-gas. The Javelina facility uses this off-gas as chemical and plastic feedstocks and sends residue gas back to the refineries. Under the Federal pipeline safety regulations, these pipelines are considered transmission lines because they are downstream of gathering systems and transport gas from refineries to a large volume customer that is not downstream from a distribution center. Therefore, per the first definition of a transmission line in §192.3, the eight pipelines transport off-gas to the Javelina facility as transmission pipelines and must remain regulated as transmission lines. In addition, you stated by follow up email that the residue gas is transported by pipelines back to the refineries to be used as fuel. Under the Federal pipeline safety regulations, the pipelines that transport the residue gas from the Javelina facility back to the refineries are also regulated under Part 192 as transmission lines.

If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.

Sincerely,

John A. Gale
Director, Office of Standards
and Rulemaking


Regulation Sections

Section Subject
§ 192.3 Definitions