Interpretation Response #PI-94-017
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
April 12, 1994
INFORMATION: Helium Plant Jurisdiction
Cesar DeLeon, DPS-10
Richard Sanders, DTI-60
Regarding your memo of February 18, 1994, we have considered whether a helium plant that receives natural gas from a 16-inch transmission line is subject to Part 192. We also considered whether natural gas pipelines entering, inside, and exiting the plant are subject to Part 192. According to your memo, the helium plant uses LNG facilities to refine natural gas to produce helium. The remaining natural gas is then returned to the 16-inch transmission line. Those plant facilities directly involved in the production of helium are not subject to Part 192, because they are not related to the transportation of gas or the treatment of gas during its transportation. Similarly, the plant"s LNG facilities are not subject to Part 193 because the facilities are not used in the pipeline transportation of gas that is subject to Part 192.
The natural gas pipeline that enters the helium plant comes under Part 192 if it is a transmission line or regulated service line. Part 192 does not apply to the entering line if it is an unregulated customer-owned service line. The pipeline exiting the plant that returns natural gas to the 16-inch transmission line comes under Part 192, since the exiting line is not a rural gathering line. Other natural gas lines inside the plant do not have to meet Part 192 as long as they do not relate to the transportation of gas or the treatment of gas during its transportation.
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