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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #PI-16-0015

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

Interpretation Response Details

Response Publish Date:

Company Name: Railroad Commission of Texas

Individual Name: Ms. Stephanie Weidman

Location State: TX Country: US

View the Interpretation Document

Response text:

Ms. Stephanie Weidman
PHMSA Program Director
Railroad Commission of Texas
1701 North Congress Avenue
P.O. BOX 12967
Austin, Texas 78711-2967

Dear Ms. Weidman:

In a September 14, 2016, 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 stated that "[o]ver the past few years, the Commission's (RRC) Pipeline Safety program has cited alleged violations of the State safety regulations pertaining to pipeline permitting (T-4) requirements for intrastate transmission and gathering pipelines." You stated that "[c]ertain pipeline operators have revised and transferred previously operated and regulated natural gas transmission pipeline systems that operate at a hoop stress below 20% of SMYS, to a natural gas distribution pipeline designation or purpose." You stated that "[o]ne particular operator based on their [sic] opinion has changed over 600 miles of pipelines from a status of transmission to distribution pipeline."

You provided two examples of pipeline systems the RRC considers "to be transmission from historical and current operating conditions." In addition, in a November 15, 2016, email you provided PHMSA summary of pipelines that the operators arbitrarily converted from transmission to distribution 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.

A pipeline that meets any of the three conditions listed under the definition in § 192.3 is a transmission line in accordance with 49 CFR Part 192. Therefore, a pipeline that operates at a hoop stress of less than 20 percent of its specified minimum yield strength, but meets either condition one or three, meets the definition of a transmission line.

PHMSA agrees, per § 192.3, with RRC's interpretation that any pipeline system other than a gathering line that transports gas from a gathering line or storage facility to a distribution center meets the definition of a transmission pipeline regardless of whether it operates at a hoop stress below 20 percent of SMYS. If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.


John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.3 Definitions