Interpretation Response #PI-17-0009
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Alaska Gasline Development Corp.
Individual Name: Mr. Frank T. Richards
Location State: AK Country: US
View the Interpretation Document
Response text:
December 7, 2017
Mr. Frank T. Richards, P.E.
Senior Vice President, Program Management
Alaska Gasline Development Corp.
3201 C Street, Suite 200
Anchorage, AK 99503
Dear Mr. Richards:
In a June 5, 2017, letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), Alaska Gasline Development Corporation (AGDC) requested an interpretation of 49 CFR Part 192 to determine whether AGDC's Alaska LNG Gas Treatment Plant (GTP), would be regulated under the Part 192 regulations.
PHMSA has statutory jurisdiction over gas pipeline facilities and the transportation of gas. Furthermore, Part 192 applies to pipeline facilities that transport gas, including pipeline facilities and the transportation of gas within the limits of the Outer Continental Shelf (49 CFR § 192.1(a)). In the letter, AGDC stated that the GTP will process gas received from the Prudhoe Bay Unit and the Point Thompson Unit to meet the Alaska LNG Pipeline Mainline inlet specifications for carbon dioxide (CO2), hydrogen sulfide (H2S), water, pressure, and temperature. As AGDC has indicated that the function of the GTP will be to process gas before it enters the proposed AGDC transmission pipeline, PHMSA's interpretation is that the GTP would not be regulated under Part 192.
However, Part 192 requires that pipeline operators provide protection to control against accidental over-pressuring. For gas being treated within a processing plant and sent into a downstream regulated pipeline, Part 192 regulatory oversight is applied to the outlet piping leaving a processing plant, including the last pressure control device before the gas enters the regulated pipeline. Figure 1 GTP/Mainline High Level Process Flow Diagram identifying the proposed demarcation point in your June 5, 2017, letter does not provide sufficient detail to determine regulatory boundaries. In order for PHMSA to make a regulatory determination, it needs the details of the specific demarcation point.
PHMSA's interpretation is based on the information AGDC has provided to PHMSA as of the issuance of this letter, and may be subject to change if AGDC alters the planned design and operation of the proposed GTP as currently shared.
If we can be of further assistance, please contact Tewabe Asebe at 202-366-5523.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Regulation Sections
| Section | Subject |
|---|---|
| 192.1 | What is the scope of this part? |