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Interpretation Response #PI-21-0007

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

Interpretation Response Details

Response Publish Date:

Company Name: Puget Sound Energy

Individual Name: Kaaren Daugherty

Location State: WA Country: US

View the Interpretation Document

Response text:

Ms. Kaaren Daugherty
Manager, Compliance and Quality Management
Puget Sound Energy
P.O. Box 97034
Bellevue, WA 98009-9734

Dear Ms. Daugherty:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated June 28, 2021, Puget Sound Energy (PSE) requested an interpretation of the applicability of certain sections of 49 Code of Federal Regulation (CFR) part 192 to your pipeline facilities. Specifically, you requested an interpretation as to the applicability of § 192.631 to the Jackson Prairie natural gas storage project (Jackson Prairie) located 10 miles southeast of Chehalis, Washington, which is jointly owned by Puget Sound Energy, Inc., Avista Utilities, and Williams Northwest Pipeline (Joint Owners).

You described Jackson Prairie as follows: (1) feeder lines, consisting of 4 parallel transmission lines, ranging in size from 14-inch to 24-inch diameter and each approximately 1.7 miles long; (2) storage field; (3) processing facility; and (4) a meter station. You also stated that the feeder lines are bi-directional and are used to inject and withdraw from the storage field. You stated that the feeder lines merge into a common header that connects to the meter station piping and Williams Northwest Pipeline as the operator of the meter station.

In addition, you stated that PSE personnel are present 24 hours, 7 days a week at Jackson Prairie, and have sole responsibility for operating the station equipment within the processing facility boundaries and the property limits of the adjacent storage field and the feeder lines. You stated the Jackson Prairie operations center receives information from data points located inside the fence line of the processing facility to ensure equipment, such as gas and fire detectors, are operating safely. You stated the data point on the west header line is located within the fence and measures suction or discharge pressures of gas entering or exiting the compressors. You stated that in the event the pressure goes above or below a predetermined safe operating pressure, the automatic shut-off valve on the west header pipe is programmed to close.

You described the Joint Owners’ functions for the gas transmission pipeline operations, farm taps, and Jackson Prairie as: (1) Williams Northwest is responsible for remotely monitoring and controlling the valves and piping at the storage project delivery point meter station (located approximately 1.7 miles to the west of Jackson Prairie storage facility) via a Supervisory Control and Data Acquisition (SCADA) system from a control room. Williams Northwest personnel can also use the SCADA information to direct Jackson Prairie personnel to take action at the feeder lines or the processing facility; (2) PSE operations center is responsible for remotely monitoring the safety-related operations and the inlet to the Chehalis farm tap via a SCADA system from a PSE control room in Redmond, WA. In addition, the PSE SCADA system collects and displays information about the Chehalis farm tap inlet pressure to dispatch pressure control personnel to take action at the farm tap; and (3) other than the meter station, PSE technicians are onsite and locally monitor and control operation of the processing facility equipment within the fenced boundary. You stated that this relationship is governed by the Jackson Prairie Gas Storage Project Agreement (Project Agreement), on file with the Federal Energy Regulatory Commission (FERC). The storage field and the feeder lines are not connected to a SCADA system and the operations center is limited to the processing facility. All human-machine interface data points are located within the fenced boundary, however you also stated that Jackson Prairie does receive a duplicate screen from the Williams Northwest SCADA system at the meter station for non-operational information purposes only.

On July 12, 2021, you provided the following additional information: (1) schematic for Chehalis farm tap station; and (2) schematic for Jackson Prairie processing facility and storage field. You also stated that the compressors are located within the fence of the Jackson Prairie processing facility and Jackson Prairie uses the compressors for withdrawal of gas that is pushed towards Williams Northwest meter station about 1.7 miles away, and for injection of gas that is pushed towards the storage field. You stated that Williams Northwest has its own compressors used for transportation of gas through their interstate transmission pipelines. You stated that Williams Northwest controls and monitors flow of gas to the Chehalis farm tap and to Jackson Prairie's processing facility. In addition, you stated that Williams Northwest manages the nomination of gas to be stored or withdrawn without the involvement of PSE's employees located at Jackson Prairie. You stated Williams Northwest provides the notification to PSE's Jackson Prairie personnel when gas needs to be withdrawn or injected.

On September 3, 2021, PHMSA again requested additional information and, per your request, on October 22, 2021, PSE and PHMSA staff had a conference call to discuss PHMSA's questions related to the control room responsibilities of the Jackson Prairie facility. The original Safety Program Relationship (SPR) provided to PHMSA did not indicate that the gas transmission pipeline operations control room management plan (CRM) safety program was handled by Williams, but instead indicated that it was addressed by PSE. Additionally, information provided to PHMSA verbally indicated that contract arrangements between Williams Northwest and PSE were not in alignment with that identified in the letter submitted regarding operations and abnormal operating response. And while duplicate screen information was available to PSE at Jackson Prairie, pressure information at Jackson Prairie had not been provided to Williams Northwest. Verbal information communicated to PHMSA indicated that Jackson Prairie, rather than Williams Northwest, made the decision about starting and stopping compressors affecting gas transmission pressures on withdrawal and responding to the abnormal operations.

On January 11, 2022, you responded to PHMSA's questions. You indicated in this response that during the October 22nd meeting, PHMSA and PSE discussed operations and maintenance of the gas transmission pipelines (feeder lines), including emergency response, and confirmed Jackson Prairie is governed by the Project Agreement. Based on the information provided and discussed, PSE indicated they would make changes in the SPR related to the CRM including the gas transmission operations, provide additional pressure information to Williams Northwest, modify the emergency procedures, and make modifications to the Project Agreement, which would be filed with the FERC.

Your January 11, 2022 response shows that PSE did not provide procedural information that indicated how operations and maintenance, including aspects associated with compression and instrumentation.

The emergency procedure information you provided illustrates that the storage facility at Jackson Prairie is functioning as a 49 CFR Part 192 regulated control room because the procedures indicated that the storage facility would turn off the gas supply source.

PHMSA requested but did not receive the start and stop procedures for Jackson Prairie and for Chehalis locations. Based upon this, PHMSA cannot confirm that start and stop operations would be directed by Williams Northwest as indicated in the January 11, 2022, PSE response. This is an important factor for understanding the applicable Part 192 control room operator.

Based on the information provided, the storage facility at Jackson Prairie was the only location monitoring mainline pressure at the end of the gas transmission pipelines for injection operations, and at the beginning of the pipeline for withdrawal operations. This information is a significant component in determining the presence of an abnormal operation or emergency condition.

There are several operators involved with the gas transmission pipeline operation between Williams Northwest Meter Station, and the Storage facility at Jackson Prairie with no clear documentation submitted that Williams has responsibility for control room function based on the information provided to date and as stated in the request for interpretation.

Should PSE correct all elements that were identified in the email response of September 3, 2021, and the meeting on October 22, 2021, implement activities with associated records providing substantiation of the changes made, and submit those records to PHMSA for review, Williams Northwest could be recognized as the control room of record on a go forward basis.

However, based on the information provided and reviewed by PHMSA, and as configured in SPR, a control room currently exists at the storage facility at Jackson Prairie to monitor and control the gas transmission pipeline operation. As such, § 192.631 requirements are applicable to the storage facility at Jackson Prairie and associated gas transmission assets. In addition, as an operator of a regulated underground natural gas storage facility, you must comply with applicable 49 CFR Parts 191 and 192 requirements (see §§ 191.17 and 192.12).

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

Sincerely,

John A. Gale
Director, Office of Standards
and Rulemaking

Regulation Sections

Section Subject
192.631 Control room management