Interpretation Response #PI-007-2012
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Mr. William G. Cope
Vice President, Operations
Southern LNG Company LLC
569 Brookwood Village, Suite 501
Birmingham, AL 35209
Dear Mr. Cope:
In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), Southern LNG Company, LLC (SLNG) requested a written interpretation concerning 49 CFR 193.2051. Specifically, SLNG asked whether an increase in the unloading flow rate at an existing liquefied natural gas (LNG) facility would be considered a "significant alteration" under § 193.2051. A "significant alteration" to the facility would require revision of SLNG"s calculations and modeling to satisfy the siting requirements of Subpart B of Part 193. SLNG believes such a change would not count as a significant alteration because the increase in flow rate would not require the replacement or modification of facilities. The only changes to the facility would be the increase in flow rate and the resulting increase in operational pressure. This change in operational pressure would be within the pipeline system"s design pressure limits.
PHMSA agrees that because this operational change is within the original design parameters and the facility would not require any further modification, an increase in flow rate would not be a significant alteration and the siting requirements of § 193.2051 and Subpart B of Part 193 would not be triggered.
I hope that this information is helpful to you. If I can be of further assistance, please contact me at 202-366-4046.
John A. Gale
Director, Office of Standards