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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-97-0100 ([Mr. Chuck Hudson] [Arizona Corporation Commission])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mr. Chuck Hudson

Individual Name: Arizona Corporation Commission

Location State: AZ Country: US

View the Interpretation Document

Response text:

PI-97-0100

U.S. Department of Transportation
Research and Special Programs Administration
400 Seventh Street, SW
Washington, D.C. 20590

MAY 6

Mr. Chuck Hudson
Senior Pipeline Safety Engineer Utilities Division
Arizona Corporation Commission 1200 West Washington,
Pheonix, AZ 85007

Dear Mr. Hudson:

This is in response to your letter of March 26, 1997, in which you requested an interpretation of 49 CFR § 193.2001 in regard to an LNG facility shown on the drawing attached to your letter. According to your letter the transmission pipeline that supplies the natural gas for liquefaction is owned and operated by El Paso Natural Gas. The liquefaction facility and piping is owned and operated by a subsidiary of El Paso Natural Gas, and the LNG storage facility and truck transfer system is operated by a company independent from El Paso. However, the land on which the storage facility sits is owned by El Paso Natural Gas.

The Research and Special Programs Administration agrees with the Arizona Corporation Commission's conclusion that, regardless of who owns or operates different sections of an LNG facility, it is subject to Part 193 in its entirety. Part 193 covers all parts of an LNG facility from the point at which it receives gas from a Part 192 regulated gas transmission pipeline through the liquefaction process, storage, and transfer into a motor carrier vehicle.

If we can be of further assistance in this matter, please contact me or Mr. Mike Israni of my staff at (202)366-4571.

Sincerely,

Richard D. Huriaux
Director, Technology & Regulations

Regulation Sections

Section Subject
193.2001 Scope of part
193.2513 Transfer procedures
193.2621 Testing transfer hoses