Is it a Transmission Line?

Recently the Railroad Commission of Texas asked for an interpretation of “transmission line” as defined in §192.3.  Operators in Texas had revised the classification of pipelines operating below 20% SMYS from transmission to distribution.

Read PHMSA’s response below:

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Determining MAOP

The current NPRM for Safety of Gas Transmission and Gathering Pipelines will likely change some of the processes for determining MAOP. However the following interpretation provides additional insight into establishing MAOP.

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Part 195 Gathering Lines

Part 195 has several criteria used to determine if a gathering line is regulated or not.  Pipe diameter, distance from an unusually sensitive area, and pressure are all factors in making the determination.

Additionally, low stress pipelines have differing requirements depending on size and proximity to unusually sensitive areas.

The following interpretation discusses a multi-diameter pipeline, its pressures and how these regulations would apply.

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Determining if Control Room Management Applies

Control Room Management regulations are applicable to both gas and hazardous liquid pipelines.  How the pipeline operations are controlled must be examined closely to determine if the control room management regulations apply.  This is critical when the pipeline is associated with refining or gas processing plants that have control rooms for controlling processes within those facilities.  Do these control rooms monitor and control the pipeline as well?  Are the control room personnel tasked with any operational authority or actions regarding the pipeline?

The following interpretation helps explain this situation.

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195.1, Onshore to an Island. Is it a regulated pipeline?

Code section §195.1 Which pipelines are covered by this part? identifies those pipelines that are and are covered by Part 195.  A key determination operators must first make is if their pipeline is used in “transportation” as defined in §195.2 Definitions.  If the answer is “yes”, then the criteria in §195.1 must be considered.

One operator questioned whether it’s pipeline was subject to the regulations.  The pipeline starts at the operator’s onshore facility, crosses a body of water and terminates at the operator’s facility on an island.

PHMSA has provided an answer in the following interpretation.

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It is the operator’s responsibility

The federal pipeline safety regulations, as well as state regulations, are written in both specification language and performance language. Specification language describes actions that must be taken, such as using a formula or following a process in a referenced standard.

Performance language usually describes a goal but without detailed specifics on how to achieve that goal.  Operators must control corrosion on the their pipeline, and can do it in several different ways.  But the bottom line is verifying that the method chosen meets the goal in the regulations.

The following interpretation is a discussion on how to meet requirements in 192.112(b).  PHMSA states it is the operator’s responsibility to ensure the methods chosen are appropriate to meet the regulatory requirements.

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