March 25, 2010

Ms. Dianne R. Phillips, Esq.
Holland & Knight
lOSt. James Avenue
Boston, Massachusetts 02116

Re: Application of the Siting Requirements in Subpart B of 49 C.F.R. Part 193 to the Mount Hope Bay Liquefied Natural Gas Transfer System

Dear Ms. Phillips:

As counsel for the City of Fall River, Massachusetts (Fall River), you have asked the Pipeline and Hazardous Materials Safety Administration (PHMSA)I for a written interpretation2 on the application of the Siting Requirements in Subpart B of 49 C.F.R. Part 193 to the Mount Hope Bay Liquefied Natural Gas (LNG) Transfer System (MHB Transfer System). The MHB Transfer System is a proposed addition to the waterfront LNG plant that Weav...[more]

Mr. William G. Cope
Vice President, Operations
Southern LNG Company, LLC
569 Brookwood Village, Suite 501
Birmingham, AL 35209

Dear Mr. Cope:

On March 24, 2011, Southern LNG Company, LLC (SLNG) filed a request with the Office of Pipeline Safety (OPS), Pipeline and Hazardous Materials Safety Administration (PHMSA), for a written interpretation of the minimum Federal safety standards for liquefied natural gas (LNG) facilities (49 CFR Part 193).  Specifically, SLNG asked whether certain modifications to the truck loading facilities at its Elba Island LNG Import Terminal (Elba Island Terminal) would be considered a replacement, relocation, or significant alteration of an existing LNG facility and ...[more]

Interpretation 193.2001 5

January 14, 1993

TO ALL STATE PIPELINE SAFETY PROGRAM MANAGERS

Enclosed, for your information, is a copy of correspondence related to the formation of a committee to develop proposals for revising regulations applicable to mobile LNG facilities. This information is being provided to you so that you might use the waiver process to take interim action on these types of facilities.

Also enclosed is a copy of a memorandum from Cesar De Leon regarding the application of regulations to these facilities (this memorandum was sent to you earlier in a pipeline safety information mailing -SR-92-136).

Sincerely,

G. Tom For...[more]

Interpretation # PI-10-0025

Mr. Randall S. Rich
Counsel for Maine Liquid Methane Fuels, LLC
Pierce Atwood LLP
900 17^th Street, N.W.
Suite 350
Washington, D.C. 20006

RE:     Request for Interpretation of 49 CFR 193.2001

Dear Mr. Rich:

On December 21, 2010, you submitted a request for written interpretation of the minimum federal safety standards for liquefied natural gas (LNG) facilities in 49 CFR Part 193.  Specifically, you asked whether a proposed liquefaction and trucking facility in Brewer, Maine, would be subject to those standards under § 193.2001.

The Office of Pipeline Safety (OPS) has concluded ...[more]

July 31, 2009

Mr. Jeff C. Wright
Director
Office of Energy Projects
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426

Dear Mr. Wright:

The Federal Energy Regulatory Commission (FERC) has asked whether the Siting Requirements in Subpart B, Part 193, Title 49, Code of Federal Regulations apply to a liquefied natural gas (LNG) transfer system with the following components: (l) an offshore marine berth with unloading piping located in Mount Hope Bay, Massachusetts, and (2) an interconnected pipe-inpipe (PIP) transfer system that includes processing equipment and extends 4.25 miles from the berth, through the waters and into the lands beneath the Bay and Taunton Rive...[more]

Ms. Lisa M. Tonery
Fulbright & Jaworski L.L.P.
666 Fifth Avenue, 31 st Floor
New York, NY 10103-3198

Dear Ms. Tonery:

As counsel for Downeast LNG, Inc. (Downeast or the Company), you have asked for a written interpretation on two questions related to your client's proposal to build a liquefied natural gas (LNG) import terminal in the town of Robbinston, Maine (Robbinston LNG Import Terminal or the Terminal). Specifically, you have asked whether Downeast may use its alternative source term model (DLNG Source Term Model) to comply with the vapor-gas exclusion zone requirements in 49 C.F .R. § 193.2059 . You have also asked whether the Company must examine the effects of jetting and flashing to comply with th...[more]

This responds to your letter of May 22, 1984, regarding the proposed construction of a Wilding at the Eau Claire LNG plant site. The building would house five LNG plant personnel and serve as a gas/electric meter maintenance shop.
In our opinion, the regulations in 49 CPR Part 193 do not prohibit construction of the building at the Eau Claire LNG plant site. It is important to not, however, that if the building is. to be toed in relation to any of the LNG plant processes, it would qualify as an "LNG facility" under the definition of that term in Part 193, and be subject to applicable Part 193 requirements. Moreover, even if the proposed building is not an "LNG facility", since it is to be located on the LNG plant site, it would be su...[more]

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,...[more]

January 14, 1993

TO ALL STATE PIPELINE SAFETY PROGRAM MANAGERS

Enclosed, for your information, is a copy of correspondence related to the formation of a committee to develop proposals for revising regulations applicable to mobile LNG facilities. This information is being provided to you so that you might use the waiver process to take interim action on these types of facilities.

Also enclosed is a copy of a memorandum from Cesar De Leon regarding the application of regulations to these facilities (this memorandum was sent to you earlier in a pipeline safety information mailing -- SR-92-136).

Sincerely,

G. Tom Fortner
Office of Pipeline Safety Compliance

Enclosures

TO: Chris Bour...[more]

PHMSA Interpretation #PI-10-0017

PHMSA Response Letter

December 22, 2010

Ms. Lisa Tonery
Fulbright & Jaworsky L.L.P.
666 Fifth Avenue, 31^st Floor
New York, NY 10103-3198

RE: Interpretation of the Flammable Vapor-Gas Dispersion Protection Requirements for Liquefied Natural Gas Facilities in 49 CFR § 193.2059

Dear Ms. Tonery:

By letter dated June 25, 2010, you requested an interpretation of 49 CFR § 193.2059, the regulation that prescribes the flammable vapor-gas dispersion protection requirements for liquefied natural gas (LNG) facilities.  Specifically, you asked whether Freeport LNG Development, L.P. (Freeport LNG or the Company) can use a particular so...[more]