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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-22-0012

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

Interpretation Response Details

Response Publish Date:

Company Name: IACX Roswell, LLC

Individual Name: Mr. Justin Wheeler

Location State: TX Country: US

View the Interpretation Document

Response text:

Mr. Justin Wheeler
Director of Environmental, Health and Safety
IACX Roswell, LLC
5001 LBJ Freeway
Suite 300
Dallas, TX 75244

Dear Mr. Wheeler:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), dated June 6, 2022, you requested an interpretation of the Federal pipeline safety regulations in 49 Code of Federal Regulations (CFR) Part 192 with respect to the scope of § 192.1 for your 12.750-inch diameter pipeline.

Your submitted documentation shows the pipeline named Bitter Lakes residue gas pipeline is located near Roswell, New Mexico and has the following characteristics: 3.68 miles long, 12.750-inch diameter, operated above 20 percent specified minimum yield strength (SMYS), and located in a Class 1 location. Also, the pipeline's established maximum allowable operating pressure is 1,200 pounds per square inch gauge (psig) with a nominal operating pressure of between 750 psig to 900 psig. The design pressure of the pipeline is 1,458 psig and the over pressure protection of the pipeline is through a relief valve that is set at 1,025 psig. The pipeline transports natural gas from the Bitter Lakes compressor station where the gas is treated to remove water, moisture, inert gas via membrane filtration, dew point control, liquids recovery, and compressed to flow directly to the end point where the pipeline terminates downstream at the Transwestern transmission line connection.

You believe the pipeline meets the definition of the API RP 80, Section - Incidental Gathering and should be regulated as a Type C gathering pipeline and, therefore, request PHMSA's confirmation.

PHMSA's Office of Pipeline Safety provides written clarifications of the Regulations (49 CFR Parts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts presented by the person requesting the clarification. Interpretations are not generally applicable, do not create legally-enforceable rights or obligations, are not fact-finding tools, and are provided to help the specific requestor understand how to comply with the regulations.

Based on the information you provided, PHMSA agrees that a 12.750-inch diameter, 3.68-miles long pipeline, located in a Class 1 location, and operates at above 20% SMYS meets the regulatory requirements of a Type C gathering pipeline. For regulatory requirements, please refer to the November 15, 2021, final rule published in the Federal Register [86 FR 63266] (see §§ 192.8(a)(5), 192.8(c), 192.9(e), 192.9(g), 192.452(c), 192.619(a)(3) and 192.619(c)(2)).

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
192.1 What is the scope of this part?