Interpretation Response #PI-10-0018 ([Duke Energy Field Services, LP] [Mr. David Bohn])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Duke Energy Field Services, LP
Individual Name: Mr. David Bohn
Location State: CO Country: US
View the Interpretation Document
Response text:
Mr. David Bohn
Pipeline Compliance Specialist
Duke Energy Field Services, LP
370 17th Street
Suite 2500
Denver, CO 80202
Dear Mr. Bohn:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) you requested an interpretation of the Federal pipeline safety regulation 49 CFR § 192.171(d). You provided the following background information: Duke Energy Field Services (DEFS) operates a number of gas compressor stations in gathering service that are located within city limits and, therefore, are required to comply with the Federal pipeline safety regulations at 49 CFR Part 192. At such compressor stations, certain engines may use carburetors rather than fuel gas injection valves to provide a fuel-air mixture to the engine power cylinders. DEFS believes that this section of the pipeline safety rules may mean that engines with carburetors are not required to have automatic fuel gas shut-off valves.
You stated that in certain areas, DEFS has been asked to install automatic fuel gas shut-off valves on its carbureted engines as well as its fuel gas injection engines. You asked whether § 192.171(d) requires all engines at compressor stations to be equipped with automatic fuel gas shut-off valves, or whether this requirement is limited to fuel gas injection engines?
In response to your question, § 192.171(d) does specifically refer to compressor station gas engines that operate with pressure gas injection. It does not, however, use the term "fuel gas injection." Based on the history, purpose and intent of the regulation, the term, "pressure gas injection" is a performance language term that is meant to cover all types of fuel gas delivery. The term "pressure gas injection" pre-dates Part 192 and was adopted from the wording of the Gas Transmission and Distribution Piping Systems, ASME Standard B31.8-1968. It references the fact that these engines operate using pressurized natural gas, usually taken from the compressor station"s suction or discharge headers (mainline pressure). Because this term is a general reference to the fact that these engines are fueled by gas; the source of which is line pressure and is not a reference to any particular delivery component of the engine, the required actions apply to all engines fueled by line gas.
The intention of 49 CFR § 192.171(d) is to extend safety in a manner which is not prescriptive. Therefore, it applies to all fuel gas methodologies that deliver pressurized fuel gas to all compressor station gas engines that were modified or installed after the applicable dates set forth in § 192.13. This assures the safe operation of all compressor station gas engines.
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, Division of
Standards and Rulemaking