Interpretation Response #PI-10-0016 ([City of Glendale Water & Power] [Steven G. Lins])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: City of Glendale Water & Power
Individual Name: Steven G. Lins
Location State: CA Country: US
View the Interpretation Document
Response text:
March 8, 2011
Mr. Steven G. Lins
Assistant General Manager - Supply
City of Glendale Water & Power
141 North Glendale Avenue, Level 4
Glendale, CA 91206-4496
Dear Mr. Lins
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated June 9, 2010, you requested an interpretation regarding the applicability of 49 CFR Part 192 of the Federal Pipeline Safety Regulations to a pipeline used to transport landfill gas in the City of Glendale, California. You described your system as follows:
"At the Scholl Canyon Landfill in Los Angeles, California, landfill gas is collected through a network of extraction wells and suction pipelines, in order to control surface emissions and underground emissions migration in accordance with the requirements of the South Coast Air Quality Management District. Initially the landfill gas was flared. Since 1994 the landfill gas has been compressed and treated at the landfill and sent to the Grayson Power Plant ("GPP") via the Glendale LFG Pipeline. The Glendale LFG Pipeline is approximately 5.5 miles long, is composed of 14-inch high-density polyethylene, and has a hoop stress of approximately 11.38 percent. It originates at the compression plant at the landfill and terminates at the GPP. The GPP uses the landfill gas as fuel to generate electricity.
"The City of Glendale is the primary owner of the Scholl Canyon landfill site, and also owns the wells and suction pipelines, the compressor plant, the Glendale LFG Pipeline, and the GPP."
For purposes of this letter, the term "suction pipelines" refers to the portion of your pipeline system which transports gas from the extraction wells to the compressor station and the term "Glendale LFG Pipeline" refers to the portion of your pipeline system that transports gas from the treatment station to the Grayson Power Plant.
In your letter, you state that the Glendale LFG Pipeline cannot be a gathering line because it does not terminate at a transmission line or main. You state that because the suction pipelines are exempt from regulation under Part 192 they cannot be gathering lines, and therefore, the Glendale LFG Pipeline cannot be a transmission line because it does not transport gas from a gathering line. You state that the Glendale LFG Pipeline must therefore be a distribution line and ask PHMSA to confirm this interpretation.
As indicated in your letter, the pipeline safety requirements in Part 192 do not apply to the onshore gathering of gas through pipelines such as the suction pipelines which operate at less than 0 psig due to the exemption in § 192.1 (b)( 4). The definition of gathering lines in § 192.3 is "a pipeline that transports gas from a current production facility to a transmission line or main." The suction pipelines are unregulated because they satisfy the exemption in § 192.1 (b)( 4), but they still meet the definition of gathering lines under both § 192.3 and § 192.8.
The exception in 49 CFR § 192.1 (b)( 4) does not apply once the pipeline becomes a transmission line. The point at which the compressor becomes part of the transmission facility, and therefore is regulated by Part 192, will depend upon the nature of the compressor facilities and the definition in API RP80 Section 2.2 (49 CFR § 192.8). The definition of a transmission line under 49 CFR § 192.3 is "a pipeline, other than a gathering line, that ... (t)ransports gas from a gathering line or storage facility to a distribution center, storage facility, or large volume customer that is not downstream from a distribution center .... "
The Glendale LFG pipeline transports gas from the compressor station to the Grayson Power Plant (GPP). The GPP is a large volume customer of the pipeline because it receives the services of the pipeline. The Glendale LFG Pipeline meets the definition of a gas transmission line because it transports gas from the gathering lines (suction pipelines) to a large volume customer that is not downstream from a distribution center (the GPP). The fact that the pipeline is a transmission line precludes the pipeline from meeting the definition of a distribution line.
In summary, we conclude that (1) the suction pipelines, up to the point where the gas is treated at the compressor station, are unregulated gathering lines under Part 192 and (2) the Glendale LFG Pipeline from the treatment facility to the GPP is a transmission line regulated under Part 192.
I hope that this information is helpful to you. If I can be of further assistance, please contact me at (202) 366-4046.
Sincerely,
John A. Gale
Director,
Office of Standards and Rulemaking