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Interpretation Response #PI-11-0013


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

Interpretation Response Details

Response Publish Date: 03-13-2023
Company Name: New Mexico Gas Company    Individual Name: Ms. Deborah Brunt
Location state: NM    Country: US

View the Interpretation Document


Response text:

Ms. Deborah Brunt, P.E.
Director, Engineering
New Mexico Gas Company
P.O. Box 97500
Albuquerque, NM 87199-7500

Dear Ms. Brunt:

In a letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA), you asked for interpretation regarding classification of your pipelines. Specifically, you asked whether the following four pipelines are transmission or distribution lines.

Your Intel VHP line originates at a regulator station on your Alameda transmission line in the middle of your Albuquerque Metro distribution center. The Alameda transmission line operates above 20 percent of the specified minimum yield strength (SMYS) at a gauge pressure of 466 pound per square inch gauge (psig) and the Intel VHP line operates at 175 psig at 5.9 percent of SMYS. The Intel VHP line delivers gas to the Albuquerque Metro 60 psig distribution system and to the Intel factory (a large volume customer). All of the gas that travels through the Alameda transmission line and the Intel VHP line is delivered to customers who purchase the gas for consumption. You believe that the Intel VHP line is a distribution line because it delivers gas downstream of the Albuquerque distribution center and does not operate at a hoop stress of 20 percent or more of SMYS.

Your Santa Fe south feed line originates at a regulator station on your Santa Fe transmission line on the south side of your Santa Fe distribution center. The Santa Fe transmission line operates at above 20 percent SMYS at 600 psig and the Santa Fe South feed line operates at 250 psig or 18.8 percent of SMYS. The Santa Fe south feed line delivers gas to the Santa Fe 60 psig distribution system. All of the gas that travels through the Santa Fe South feed line is delivered to customers who purchase it for consumption. You believe that the Santa Fe south feed line is a distribution line because it delivers gas downstream of the Santa Fe distribution center and does not operate at a hoop stress of 20 percent or more of SMYS.

Your Gallup east feed starts at the East El Paso Natural Gas transmission line at the Gallup city gate station. The transmission line operates at 300 psig or 13.7 percent of SMYS. The Gallup East feed delivers gas to the Gallup 60 psig distribution system. All of the gas that travels through the Gallup east feed is delivered to customers who purchase it for consumption. You believe that the Gallup East feed line is a distribution line because it delivers gas downstream of the Gallup distribution center and does not operate at a hoop stress of 20 percent or more of SMYS.

Your Ambrosia Lake line originates at a regulator station on the Grants transmission line on the north side of your Grants distribution center. The Grants transmission line operates at above 20 percent SMYS of 720 psig and the Ambrosia Lake line operates at 180 psig or 10.1 percent SMYS. The Ambrosia Lake line delivers gas to the Grants 50 psig distribution system and to several farm taps. All of the gas that travels through the Ambrosia Lake line is delivered to customers who purchase it for consumption. You believe that the Ambrosia Lake line is a distribution line because it delivers gas downstream of the Grants distribution center and does not operate at a hoop stress of 20 percent or more of SMYS.

We contacted you with a request to provide us with mileage information of these pipelines and you responded with an October 12, 2011, email. Also, we were able to get the information from the New Mexico Public Regulation Commission. The responses regarding the pipelines are as follows:

The Intel VHP line begins at a regulator station on New Mexico Gas Company's (NMGC's) Alameda transmission line where pressure is reduced from 466 psig to 175 psig. The pipeline runs approximately 1.1 miles to a regulator station located at Intel Corporation where it delivers natural gas to Intel's manufacturing facility (a large volume customer) and the Albuquerque Metro 60 psig distribution system. The pipeline has no service lines or farm taps upstream of its delivery to Intel's manufacturing facility and the natural gas distribution system.

The Santa Fe South feed line begins at a regulator station on NMGC's Santa Fe transmission line where pressure is reduced from 600 psig to 250 psig. The pipeline runs approximately 11 miles to a regulator station on the south end of Santa Fe where pressure is reduced to 60 psig to supply the Santa Fe distribution system. This pipeline segment was part of the Santa Fe transmission line and operated at 600 psig until a loop/bypass line was installed a couple of years ago. The pipeline has no service lines upstream of its delivery to the Santa Fe distribution system.

The Gallup east feed begins at NMGC's East Gallup El Paso Natural Gas Company's PNG backup regulator station at EPNG's transmission line and transports natural gas from the EPNG transmission line to NMGC's East Gallup border regulator station. NMGC's primary supply for the Gallup distribution system is its Gallup/Grants mainline which delivers natural gas at the East Gallup border regulator station. This pipeline serves as a back-up supply and also delivers natural gas at the East Gallup border regulator station. The pipeline has no service lines or farm taps upstream of its delivery to the East Gallup border regulator station.

The Ambrosia Lake line begins at a regulator station on NMGC's Gallup/Grants transmission line where pressure is reduced from 720 psig to 180 psig. The pipeline transports natural gas approximately 27 miles to NMGC's grants distribution system where pressure is reduced to 50 psig.

The definition for "transmission line" per § 192.3 is reprinted below:

Transmission line means a pipeline, other than a gathering line, that:

(1) Transports gas from a gathering line or storage facility to a distribution center, storage facility, or large volume customer that is not down-stream from a distribution center;

(2) Operates at a hoop stress of 20 percent or more of SMYS; or

(3) Transports gas within a storage field.

NOTE: A large volume customer may receive similar volumes of gas as a distribution center, and includes factories, power plants, and institutional users of gas.

Based on the information you and the New Mexico Public Regulation Commission provided, we believe that these pipelines downstream of the custody transfer point between the interstate transmission pipeline and the local distribution company are distribution lines. I hope that this information is helpful to you. If I can be of further assistance, please contact me at (202) 366-0434.

Sincerely,

John A. Gale
Director, Office of Standards
and Rulemaking

cc: New Mexico Public Regulation Commission


Regulation Sections

Section Subject
§ 192.3 Definitions