Interpretation Response #PI-09-0017
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
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Country: US
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Response text:
September 10, 2009
Mr. William H. Penniman
Sutherland Asbill & Brennan LLP
1275 Pennsylvania Avenue, NW
Washington, DC 20004-2415
Dear Mr. Penniman:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated March 4,2009, you requested an interpretation of the applicability of the Federal pipeline safety regulations in 49 CFR Part 195 to a Questar Gas Management Company (QGM) in the State of Wyoming.
In your letter and subsequent communication, you provided the following information:
1. On December 27,2006, you requested a determination as to the jurisdiction of QGM's No. 61 1 gathering line.
2. Based on the information provided, on June 4,2007, PHMSA indicated that QGM's No.6 I I gathering line was not regulated by the agency under Part 195.
3. In 2008, QGM connected its No. 611 pipeline to its l.l mile lateral pipeline. The 1.1 mile lateral pipeline receives petroleum (natural gas condensate liquids) from a truckunloading facility owned by Plains Marketing, L.P. (The 1.1 lateral pipeline parallels to the No. 611 pipeline before connecting with it because Plains marketing'S truckunloading facility needed to be next to a road and because QGM had a pre-existing valve available for the interconnection 1.1 miles from the unloading facility.)
4. The 1.1 mile lateral pipeline has a nominal diameter of 6518 inches.
5. The 1.1 mile lateral pipeline interconnects with the No. 611 pipeline at a point approximately 12.7 miles downstream from the start of the No. 611 gathering line.
6. The maximum operating pressure is 2, I 00 psig, the operating pressure ranges from 1,000 psig to 1350 psig, and the pump is rated at 1,400 psig.
7. The pipeline is operated above 20 percent of specified minimum yield strength (SMYS).
You expressed your view that even with the connection of the 1.1 mile lateral pipeline, the entire No. 611 gathering line should remain unregulated by Part 195 along with the lateral. You further stated that ifPHMSA determines that the transportation of petroleum received from the truckunloading facility via the lateral alters the June 4, 2007, determination, then Part 195 should only apply to (a) the lateral line or (b) the lateral line and the portion ofQGM's No. 611 line downstream of the point at which the lateral line connects to the No. 611 gathering line. Based on the information you provided, PHMSA' s determination is that the 1.1 mile lateral line and the No. 611 gathering line downstream from the connection point would be regulated under Part 195 since these lines are operated at greater than 20% SMYS. The Part 195 regulations do not apply to the No.6 I 1 gathering line upstream of the point at which it connects to the 1.1 mile lateral pipeline at this time. However, should a new unusually sensitive area be identified along this portion of the pipeline, the status may change.
If I can further assist you with this or any other pipeline safety regulatory matter, please contact me at (202) 366-4046.
Sincerely,
John A. Gale
Director, Office of Regulations