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Interpretation Response #PI-14-0019 ([Freeport LNG] [Mr. John A. Jacobi])

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

Interpretation Response Details

Response Publish Date:

Company Name: Freeport LNG

Individual Name: Mr. John A. Jacobi

Location State: TX Country: US

View the Interpretation Document

Response text:

Mr. John A. Jacobi
G2 Partners, LLC for
Freeport LNG
10850 Richmond Avenue
Houston, TX 77042

Dear Mr. Jacobi:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) dated October 8, 2014, on behalf of Freeport LNG Development, L.P. (FLNG), you requested an interpretation of the applicability of the control room management regulations in 49 CFR 192.631 to a natural gas pipeline monitored and controlled via a control center in a liquefied natural gas (LNG) import terminal subject to 49 CFR Part 193.

You stated that FLNG owns and operates an LNG import terminal located in Quintana, TX and has a Control Center from which facility operations and warning devices are monitored as required under Part 193. You noted that the FLNG controllers are subject to the Operator Qualification (OQ) requirements under § 193.2707 and that they are similar to the Part 192 OQ requirements.

Associated with the Freeport LNG Import Terminal is a 9.7 mile intrastate 42-inch natural gas transmission pipeline (the "FLNG pipeline") that connects the terminal to the Stratton Ridge meter station for delivery or storage regulated by the Texas Railroad Comission. You stated the FLNG pipeline does not have an independent supervisory control and data acquisition (SCADA) system, an independent control room or any controllers other than those provided by the FLNG Control Center. You explained that all monitoring and control associated with the FLNG pipeline is performed by the FLNG Control Center, in which we presume those pipeline monitoring and control functions are enabled by a SCADA or similar system.

You referenced the discussion in the preamble to the Control Room Management final rule (74 FR 63310; December 3, 2009) indicating that LNG terminals should not be subject to the control room management requirements established by the rule. You expressed the view that since an LNG terminal ordinarily would not be subject to the control room management requirements, a gas transmission pipeline such as the FLNG pipeline connected to an LNG terminal also should not be subject to the control room management requirements.

As you correctly noted, the rule does not apply to LNG terminal controllers that control the operations of LNG terminal facilities and equipment. In this case, however, control of the FLNG pipeline, which departs the grounds of the terminal, is the issue. Since the FLNG pipeline is a gas transmission pipeline regulated under Part 192 and controlled by a SCADA system, the Part 192 control room management requirements do apply insofar as the terminal controllers are controlling this pipeline regardless of the fact that the location of such control happens to be on the grounds of an LNG terminal. Accordingly, in addition to meeting the control center requirements in § 193.2441 for terminal operations, the control room management requirements in § 192.631 must be met with respect to the control of the FLNG pipeline.

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



John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.631 Control room management
193.2707 Operations and maintenance