{"operation":"document","citation":"PI-09-0016","title":"Pipeline Safety Interpretation PI-09-0016","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-09-10","effective_on":null,"summary":"PI-09-0016 concerning 192.620.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0016.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0016.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-09-0016","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/Pipeline/2009/PI-09-0016.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, 0 C 20590\nSEP 1 0 2009\nMr. Gregory P. Bilinski\nVice President\nSpectra Energy\nP.O. Box 1642\nHouston, TX 7725 I -1642\nDear Mr. Bilinski:\nOn December 22, 2008, you wrote to the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) to request an interpretation of §§ 192.620(c)(6), (d)(5)(ii), (d)(lO)(iii)\nand (d)( 11 )(ii)(A).\nPursuant to Chapter 601, Title 49, United States Code. PHMSA has responsibility for protecting\nagainst risks to life, property, and the environment posed by pipelines. In carrying out its\nresponsibilities, PHMSA has established design, construction, operation, and maintenance\nstandards and regulations for gas pipelines and has responsibility for enforcing these\nrequirements.\nOur interpretations to your requests are as follows:\nQuestion: Texas Eastern Transmission, LP (TETLP) reads the § 192.620(c)(6) language as\napplying to construction commencing after the effective date of the [maximum allowable\noperating pressure (MAOP)] Final Rule and not to construction prior to the effective date on\nexisting pipelines. TETLP requests an interpretation clarifying that § 192 .620( c)( 6) does not\napply retroactively to the existing segments ofTETLP's Lines 1 and 2 covered by the proposed\nspecial permit.\nResponse: All construction tasks associated with implementing alternative MAOP must comply\nwith § 192.620( c )(6), regardless of when the task was performed. In cases where previously\ncompleted construction tasks do not fully comply with § J92.620(c)(6), such as pipelines\nconstructed prior to the effective date of the rule. operators may apply for a special permit in\norder to get relief from this requirement.\nQuestion: On § 192.620(d)(5)(ii» - TETLP is reviewing customer separation equipment for\nreceipt points on the pipelines covered by the proposed special permit. TETLP requests an\ninterpretation from PHMSA clarifying that properly designed separation equipment operated by\nTETLP's customers will satisfy this requirement.\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, provides written clarification of the Regulations (49 eFR\nParts 190-199) in the fonn of interpretation letters, These letters reflect the agency's curren! application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 2>>>\n\n2\nResponse: Part 192 applies to operators of pipelines. This includes design, construction,\noperational, maintenance, integrity management, operator qualification, and all other\nrequirements. All requirements must be implemented by pipeline operators. Customers of the\noperator who are not themselves pipeline operators are not obligated to comply with Part 192\nand PHMSA has no enforcement authority over them. TETLP is directly responsible for\ncompliance with 192.620( d)(5)(ii) as it applies to its pipelines and must document the monitoring\nit conducts to ensure that contaminants that could contribute to corrosion are not present in its\npipeline. If separation equipment owned and operated by one of TETLP's customers was\noperated improperly or otherwise failed to perform adequately resulting in contaminants entering\nthe pipeline, TETLP would be obligated to correct the problem by addressing the situation with\nthe customer, but PHMSA would hold TETLP responsible for the circumstances leading to and\nresulting from the failure to protect against any corrosion occurring in its pipeline.\nQuestion: On § 192.620e d)(l O)(iii» - TETLP requests an interpretation from PHMSA to clarify\nthat direct examination techniques are acceptable alternatives to external corrosion direct\nassessment (\"ECDA\") or internal corrosion direct assessment (\"ICDA\") for non-piggable\nsegments operating at the alternate design factors. TETLP believes that direct examination\ntechniques can be more effective and provide a better assessment than ECDA and ICDA for\nshort segments of non-piggable lines.\nResponse: In accordance with National Association of Corrosion Engineers (NACE) 0502-2002,\nSection 3.4.1.3, 100 percent direct examination is an acceptable method and complies with\n§ 192.925. American Society for Testing and Materials (ASME) B3 I .8S, Section 6.1 also\nindicates that operators may choose to conduct direct examination of the entire length of the\nsegment being assessed. To address external corrosion and dents, operators must make detailed\nmeasurements and/or maps of the metal loss and/or indentation. To address internal corrosion,\noperators must examine the pipe for internal metal loss by Non-Destructive Evaluation (NDE)\nmethods such as ultrasonic testing. To address stress corrosion cracking (SCC), operators must\nexamine the pipe for SCC by NDE methods such as magnetic particle inspection. (See also\n§ 192.939 as it relates to the maximum intervals for each of the different reassessment methods.)\nQuestion: In the rule, § 192.620(d)(lJ)(ii)(A) requires that a dent discovered during the baseline\nassessment for integrity under paragraph (d)(9) that meets the criteria in § 192.309(b) be\nrepaired. In the preamble of the Final Rule, PHMSA states,\n\"With respect to dents, the repair criteria of§J92.309(b) apply only for dents found\nduring construction baseline assessments (i.e., for new pipelines). PHMSA notes that this\nsection already requires repair of two percent dents for pipelines over J 2-314 inches in\ndiameter. The criteria for repairing dents on existing pipelines and subsequent\nassessments on new pipelines and existing pipelines are in § J92.933(d).\" (73 FR 62165)\nTETLP agrees with PHMSA's stated intent, however, points out that the language in the Final\nRule does not reflect this intent. The Final Rule language could be interpreted to require dents in\nexisting lines to be remedied in accordance with § I 92.309(b) and § 192.933(d). TETLP\nrequests an interpretation from PHMSA to clarify that § 192.309(b) is applicable only to new\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety, provides written clarification of the Regulations (49 CFR\nParts 190-199) in the form of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 3>>>\n\n3\npipelines, and that dents identified by baseline assessments for existing pipelines are to be\nremedied in accordance with § 192.933(d).\nResponse: The excerpt of the preamble of the final rule cited in the question merely\nacknowledges that the pre-existing § 192.309(b) applied to new pipelines under construction and\nthat the pre-existing § 192.933(d) applied to existing operational pipelines. As stated in the\ninitial paragraph of the response ....\n\"PHMSA recognizes that the repair criteria in this rule are more stringent than those in\nsubpart 0. PHMSA considers this appropriate. A pipeline that will operate under\nalternative MA OP is subject to more stress and has less wall thickness margin to failure\nthan most pipelines operating under subpart 0 (with the exception of some grandfathered\nlines). \"\nThe repair criteria in § 192.620( d)(ll )(ii) are intended to require that dents in existing lines\nimplementing alternative MAOP must be repaired if they meet criteria in either § 192 J09(b)\n[per § 192.620(d)(lI)(ii)(A)] or § 192.933(d) [per § 192.620(d)(lI)(ii)(B)]. This is intended to\nassure that existing pipelines that will be operated at stress levels allowed by the alternative\nMAOP rule are in \"like new\" condition with respect to dent defects.\nI hope that this infonnation is helpful to you. If I can further assist you with this or any other\npipeline safety regulatory matter, please contact me at (202) 366-4046.\nSincerely,\nDirector, Office of Regulations\nThe Pipeline and Hazardous Materials Safety Administration. Office of Pipeline Safety. provides written clarification of the Regulations (49 CFR\nParts 190-199) in the fonn of interpretation letters. These letters reflect the agency's current application of the regulations to the specific facts\npresented by the person requesting the clarification. Interpretations do not create legally-enforceable rights or obligations and are provided to\nhelp the public understand how to comply with the regulations.\n\n<<<PAGE 4>>>\n\nTexas Eastern Transmission, LP\n5400 Westheimer Court\nHouston, TX 77056-5310\n713.627.5400 main\nMailing Address;\nP.O. Box 1642\nHouston, TX 77251-1642\nSpectii'J)\nEnerg~\nJAN 0 '1 20tJ9\nDecember 22, 2008\nMr. Jeff Wiese\nAssociate Administrator for Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave., S.E., East Building\nWashington, D.C. 20590\nRE: Docket No. PHMSA-2008-0257\nPetition for Special Permit\nTexas Eastern Transmission, L.P.\nDear Mr. Wiese,\nOn September 11, 2008, Texas Eastern Transmission, L.P. (\"TETLP\") petitioned the\nPipeline and Hazardous Materials Safety Administration (\"PHMSA\") for a special permit\nto increase the maximum allowable operating pressure (\"MAOP\") of a portion of its\npipeline system in Pennsylvania from 1,000 psig to 1,112 psig. The special permit\npetition requested a waiver under Section 60118(c) of the United States Federal Code\nfrom the requirements of Sections 192.111, 192.201, 192.611, and 192.619 of Title 49 of\nthe Code of Federal Regulations to allow this MAOP increase.\nSince the petition was filed, PHMSA has issued a final rule, \"Pipeline Safety: Standards\nfor Increasing the Maximum Allowable Operating Pressure for Gas Transmission\nPipelines\" (\"Final Rule\"), that provides regulations for operation of new and existing\npipelines using higher design factors. In the preamble of the final rule, PHMSA indicated\nthey would no longer process special permit requests as operators would be expected to\ncomply with the Final Rule to increase their MAOP. TETLP has reviewed the Final\nRule, and has determined that segments of TETLP's Lines 1 and 2 substantially meet\nmost of the requirements of the Final Rule. TETLP Lines 1 and 2 do not retroactively\nmeet a limited number of the specified requirements in the Final Rule, such as the those\nrequirements regarding pipe and coating manufacturing testing and inspection,\nconstruction inspection, and operator qualification requirements for previous\nconstruction. In some cases, the specified requirements were not yet recognized as \"best\npractice\", in other cases, the specified requirements were substantially met but supporting\ndocumentation does not exist.\nThrough the course of several discussions, PHMSA has indicated to TETLP that PHMSA\nwould consider a special permit to waive specific requirements of the Final Rule, and\nwww.spectraenergy.com\n\n<<<PAGE 5>>>\n\nDocket No. PHMSA-2008-0257\nTETLP Request for Special Pennit\nDecember 22, 2008\nPage 2 of II\nrecommended that TETLP to submit a letter requesting a modification to TETLP's\nSeptember 11, 2008 special permit petition. TETLP hereby requests its special permit\npetition for segments of TETLP Lines 1 and 2 be amended as detailed in this letter to\nrequest a limited number of specific requirements of the Final Rule be waived to allow\nthe proposed MAOP uprate.\nSpecifically, TETLP requests a limited Special Permit that waives the requirements of the\nfollowing sections:\n• 49 CFR 192.l12( a) (1 )\n• 49 CFR 192.1 12(c)(l)\n• 49 CFR 192.l12(c)(2)(i)\n• 49 CFR 192.1 12(c)(2)(ii)\n• 49 CFR 192.112( c )(2)(iii)\n• 49 CFR 192.l12(d)(2)(i)\n• 49 CFR 192.112(f)(1)\n• 49 CFR 192.620(d)(5)(iii)\nIn addition, TETLP requests an interpretation of the requirements of the following\nsections of the rule as they pertain to existing pipelines:\n• 49 CFR 192.l12( d)(l)\n• 49 CFR 192.112(d)(2)\n• 49 CFR 192.620(c)(6)\n• 49 CFR 192.620(d)(5)(ii)\n• 49 CFR 192.620( d)(7)(i)\n• 49 CFR 192.620( d)(7)(ii)\n• 49 CFR 192.620( d)(l O)(iii)\n• 49 CFR 192.620(d)(ll)(ii)(A)\nBACKGROUND\nThe proposed special permit would apply to TETLP's 36-inch Lines 1 and 2 from its\nUniontown, P A compressor station to a mainline regulating station approximately 7 miles\nwest of its Lambertville, NJ compressor station (See Appendix A for a map of the TETLP\npipeline system and Appendix B for a schematic showing the scope of the proposed\nuprate). The MAOP uprate is part of two proposed pipeline capacity expansion projects,\ncalled the TEMAX and TIME III Projects (See Appendix C for a TEMAX and Time III\nfacilities map). These proposed projects will increase U.S. natural gas transportation and\nsupply reliability by connecting natural gas from the Rocky Mountains to growing\nmarkets throughout Pennsylvania and the Northeast region. TETLP has commenced with\nthe FERC pre-filing process for the TEMAX and TIME III Project FERC under Docket\n#PF08-27.\n\n<<<PAGE 6>>>\n\nDocket No. PHMSA-2008-0257\nTETLP Request for Special Permit\nDecember 22, 2008\nPage 3 of 11\nUnder the increased pressure of 1,112 psig, these pipeline segments would operate as\nhigh as 80% of specified minimum yield strength (\"SMYS\") in Class 1, 67% of SMYS in\nClass 2 and 56% of SMYS in Class 3 areas. There are currently no Class 4 areas on the\nsystem, and TETLP does not propose to include any future Class 4 areas under this\nspecial penn it. Additionally, TETLP does not propose to operate the compressor stations\nor meter stations under the alternate design factors specified in the Final Rule.\nTETLP has perfonned a thorough evaluation of the pipeline segments covered by the\nproposed special pennit and has concluded that these segments can safely and reliably\noperate at the higher MAOP. This evaluation included reviews of the pipeline design,\nfracture control, materials and construction, as well as their operating and maintenance\nhistory. This evaluation also included recommendations for any additional integrity\nmanagement activities needed to ensure improved pipeline safety at the higher operating\npressures. The original special pennit petition includes details of this evaluation. As a\nresult of TETLP's review of the Final Rule, TETLP is proposing additional integrity\nmanagement activities beyond those proposed in the September 11, 2008 petition to\naddress specific issues in the Final Rule. The proposed integrity management activities\nare summarized later in this letter.\nMODIFIED SPECIAL PERMIT REQUEST\nTETLP has reviewed the Final Rule, and has detennined the pipelines covered by the\nproposed MAOP increase do not retroactively meet a limited number of the specified\nrequirements of the Final Rule. TETLP largely agrees with the technical conditions\nspecified for construction of new pipelines to operate at 80% SMYS, however these same\nconditions applied to existing pipelines are not realistically achievable in every case.\nSpecifically, some of the detailed requirements regarding pipe fabrication, inspection and\ntesting have been applied only very recently as \"best practices\" and are not typical for\npipelines constructed at the time of TETLP Lines 1 and 2. In other case, documentation\nis difficult to produce to demonstrate full compliance that all specified conditions are\nmet. However, in many cases, documentation exists to demonstrate that requirements are\nsubstantially met.\nTETLP hereby modifies its original special pennit petition filed on September 11, 2008\nto request PHMSA to waive the requirements of the sections of the Final Rule specified\nbelow. Each section of the Final Rule to be included in the modified special pennit\nrequest is shown in italics, followed by a description of the specific requirement for\nwhich TETLP requests a special pennit. In some cases, TETLP is requesting an\ninterpretation of the Final Rule language rather than a special pennit.\n\n<<<PAGE 7>>>\n\nDocket No. PHMSA-2008-0257\nTETLP Request for Special Penn it\nDecember 22, 2008\nPage 4 of II\n49 CFR J92.112(a)(l)\nThe plate. skelp. or coil used for the pipe must be micro-alloyed. fine grain, fully killed.\ncontinuously cast steel with calcium treatment.\nThe plate used for the pipe is continuous cast, micro-alloyed, fine grain, and fully killed.\nThe micro-alloy content is demonstrated by the presence of titanium, vanadium and\nniobium in the mill test report documentation. The silicon composition of 0.2%\n(nominal) demonstrates that the material was fully killed. Calcium treatment was applied\nfor a large majority of the pipe, but documentation is not available for each individual\npipe supplier.\nThe original purpose of calcium addition as a sulfide shape control element became\nobsolete by the time TETLP Lines 1 and 2 were constructed due to the already low levels\nof sulfur in the steel composition. Calcium treatment is now primarily used to increase\npipe toughness. Since each pipe supplier achieved adequate toughness to meet the ductile\nfracture arrest conditions specified by PHMSA in the Final Rule, TETLP believes it has\nmet the intent of this provision and requests the proposed special permit include a waiver\nfrom the requirement for calcium treatment for existing segments of its Lines 1 and 2\ncovered by the proposed MAOP increase. Appendix L of the special permit petition\ndated September 11,2008, \"Design Basis for the CRP Fracture Control Plan\" documents\ncompliance with the requirements of a fracture control plan.\n49 CFR 192.1 12(c)(l)\nThere must be an internal quality management program at all mills involved in\nproducing steel, plate, coil, skelp, and/or rolling pipe to be operated at alternative\nMAOP. These programs must be structured to eliminate or detect defects and inclusions\naffecting pipe quality.\nThe requirement for a quality management program at the steel, plate, coil, skelp and/or\nroIling mills was not a standard industry practice at the time the pipe was manufactured,\nnor was it a requirement or recommended practice of any applicable consensus standard.\nEach pipe supplier had a longstanding relationship with the individual plate\nmanufacturer. TETLP implemented a quality assurance program at the pipe mills.\nTETLP believes the integrity of the pipeline is validated by the pipe mill inspections and\nhydrostatic testing, the weld seam and girth weld non-destructive examination (\"NDE\"),\nthe post construction hydrostatic testing and the safe operating history of these pipelines.\nTETLP requests a special permit waiving the requirements of the internal quality\nmanagement program for the mills producing steel, plate, coil, skelp, and/or rolling pipe\nfor existing segments of Lines 1 and 2 covered by the proposed special permit.\n49 CFR 192.l12(c)(2)\nA mill inspection program or internal quality management program must include (i) and\neither (ii) or (iii): '\n\n<<<PAGE 8>>>\n\nDocket No. PHMSA-2008-0257\nTETLP Request for Special Permit\nDecember 22, 2008\nPage 5 of 11\nSee comments to each individual subsection below.\n49 CFR 192.112(c)(2)(i)\nAn ultrasonic test of the ends and at least 35 percent of the surface of the platelcoil or\npipe to identify imperfections that impair serviceability such as laminations, cracks, and\ninclusions. At least 95 percent of the lengths of pipe manufactured must be tested For all\npipelines designed after [the effective date of the final rule j, the test must be done in\naccordance with ASTM A5781A578M Level B, or AP15L Paragraph 7.8.10 (incorporated\nby reference, see §I92. 7) or equivalent method, and either\nFor the pipe covered by this proposed special pennit, ultrasonic testing was required at\neach end of each pipe to inspect for mid-wall laminations. Pipe seam weld inspections\nwere also performed for all of the pipe covered by the proposed special permit. Pipe\nbody UT inspection was specified in the purchase orders for a majority of the pipe\nproduced, but not 100%. In some cases, the pipe body UT inspection may not have\nachieved 35% coverage of the pipe body. TETLP requests a special permit waiving the\nrequirement for pipe or plate surface UT inspection.\nTETLP believes the primary benefit of pipe body UT inspection is to check for\nlaminations that could cause welding problems in longitudinal seam or girth weld. Once\nthe pipeline has been installed with 100% NDE of seam and girth welds, laminations are\nof minimal concern to pipeline integrity.\n49 CFR 192.112(c)(2)(ii)\nA macro etch test or other equivalent method to identify inclusions that may form\ncenterline segregation during the continuous casting process. Use of sulfur prints is not\nan equivalent method The test must be carried out on the first or second slab of each\nsequence graded with an acceptance criteria of one or two on the Mannesmann scale or\nequivalent; or\nMacro etch testing of the continuous cast slabs was not conducted during steelmaking for\nTETLP Lines 1 and 2 This process was established as an industry practice much later,\nand applied to continuous cast slabs used for gas transmission pipes only very recently.\nMacro etch testing is primarily performed to prevent laminations in the finished pipe. As\nnoted above, TETLP believes the primary benefit of pipe body UT inspection is to check\nfor laminations that could cause seam or girth weld defects. Once the pipeline has been\ninstalled with 100% NDE of seam and girth welds, laminations are of minimal concern to\npipeline integrity. TETLP requests a special permit waiving the requirement for macro\netch testing.\n49 CPR 192.1 12(c)(2)(iii)\nA quality assurance monitoring program implemented by the operator that includes\naudits of (a) all steelmaking and casting facilities, (b) quality control plans and\nmanufacturing procedure specifications, (c) equipment maintenance and records of\n\n<<<PAGE 9>>>\n\nDocket No. PHMSA-2008-0257\nTETLP Request for Special Permit\nDecember 22, 2008\nPage 6 of II\nconformance, (d) applicable casting superheat and speeds, and (e) centerline segregation\nmonitoring records to ensure mitigation of centerline segregation during the continuous\ncasting process.\nThe requirement for a Company quality assurance monitoring program as specified was\nnot a standard industry practice at the time the pipe was manufactured, nor was it a\nrequirement or recommended practice of any applicable consensus standard. TETLP did\nnot perform this type of quality assurance monitoring program for the pipe covered by the\nproposed special permit. Each pipe supplier had a longstanding relationship with the\nindividual plate manufacturer. TETLP implemented a quality assurance program at the\npipe mills. TETLP believes the integrity of the pipeline is validated by the pipe mill\ninspections and hydrostatic testing, the weld seam and girth weld non-destructive\nexamination (\"NDE\"), the post construction hydrostatic testing and the safe operating\nhistory of these pipelines, and requests a special permit waiving the requirements for a\nquality management program as specified in this section.\n49 CFR 192.1 12(d)(l)\nThere must be a quality assurance program for pipe seam welds to assure tensile strength\nprovided in API Specification 5L (incorporated by rejerence, see §i92. 7) for appropriate\ngrades.\nThe line pipe for Lines 1 and 2 was manufactured in conformance with the edition of API\n5L in effect at the time of the pipe orders. TETLP requests an interpretation clarifying\nseam tensile strength testing for existing pipelines must have been performed in\naccordance with the DOT referenced version of API 5L in effect at the time of the pipe\norder.\n49 CFR 192.1 12(d)(2)\nThere must be a hardness test, using Vickers (Hv i 0) hardness test method or equivalent\ntest method, to assure a maximum hardness of280 Vickers of the following:\nFor original CRP pipe, Rockwell seam hardness testing was applied with a specification\nlimit equivalent to HRC equal to 22 max. An HRC value of 22 is approximately\nequivalent to a value of 245 on the Vickers scale; substantially below the PHMSA\nrequirement of 280. Any Rockwell hardness results above HRC = 22 or equivalent were\nevaluated using the Vickers test method. Subsequent loops included seam weld Vickers\ntesting compliant with the PHMSA requirements. TETLP requests an interpretation from\nPHMSA clarifying TETLP's Rockwell hardness testing is adequate to meet the\nrequirements of § 192.112( d)(2).\n49 CFR 192.l12(d)(2)(i)\nA cross section of the weld seam of one pipe from each heat plus one pipe from each\nwelding line per day,' and\n\n<<<PAGE 10>>>\n\nDocket No. PHMSA-2008-0257\nTETLP Request for Special Permit\nDecember 22,2008\nPage 7 of 11\nThe requirement for weld seam inspection testing at the stated frequency was not an\nindustry standard practice, nor was this a recommended practice or requirement of any\napplicable consensus standard at the time the pipe was manufactured. TETLP typically\nspecified a testing frequency of once per welding machine per day. TETLP believes the\nintegrity of the pipeline is validated by the post construction hydrostatic test and the safe\noperating history of the lines covered by the special permit. TETLP requests a special\npermit waiving the frequency requirements stated in §I92.112(d)(2)(i).\n49 CFR 192.1 12(f)(l)\nThe pipe must be protected against external corrosion by a non-shielding coating.\nThe pipe covered by the proposed special permit is coated with FBE. Girth welds are\ncoated primarily with field applied FBE or 2-part epoxy coatings. Records indicate the\nuse of shrink sleeves at tie-in and repair welds for some of the construction from 1992\nthrough 1995. Approximately 56 miles of pipeline was installed in this period of time.\nTETLP has identified a number of locations where shrink sleeves were installed. TETLP\nproposes to evaluate MFL data to identify any detectable indications of external corrosion\nnear girth welds. Locations with detectable indications of external corrosion at girth\nwelds will be identified, excavated and examined. Shrink sleeves in these locations will\nbe removed. TETLP also proposes to excavate a limited number of locations where\nshrink sleeves are known to be present and ILl logs do not indicate metal loss. TETLP\npersonnel will remove the coating and evaluate the condition of the pipe. The absence of\ndetectable metal loss on the ILl log indicates that the girth weld coating system is intact\nand SCC would be highly unlikely.\nGiven the presence of the shrink sleeves, TETLP requests that this section be included in\na special pennit with a conditions that require excavation and examination of a limited\nnumber of known locations with shrink sleeves and the evaluation of high-resolution\nMFL data at girth welds to identify measureable indications of metal loss as a possible\nindicator of the presence of a failed shrink sleeve.\n49 CFR 192.620(c)(6)\nIf the performance of a construction task associated with implementing alternative\nMAOP can affoct the integrity of the pipeline segment, treat that task as a \"covered\ntask\", notwithstanding the definition in §J92.80J(b) and implement the requirements of\nsubpart N as appropriate.\nTETLP reads this language as applying to construction commencing after the effective\ndate of the Final Rule and not to construction prior to the effective date on existing\npipelines. TETLP requests an interpretation clarifying that §192.620(c)(6) does not apply\nretroactively to the existing segments ofTETLP's Lines 1 and 2 covered by the proposed\nspecial permit.\n\n<<<PAGE 11>>>\n\nDocket No. PHMSA-200S-0257\nTETLP Request for Special Permit\nDecember 22, 200S\nPage S of 11\n49 CFR 192.620(d)(5)(ii)\nAt points where gas with potentially deleterious contaminants enters the pipeline, use\nfilter separators or separators and gas quality monitoring equipment.\nTETLP is reviewing customer separation equipment for receipt points on the pipelines\ncovered by the proposed special permit. TETLP requests an interpretation from PHMSA\nclarifying that properly designed separation equipment operated by TETLP's customers\nwill satisfy this requirement.\n49 CFR 192.620(d)(5)(iii)\nUse gas quality monitoring equipment that includes a moisture analyzer, chromatograph,\nand periodic hydrogen sulfide sampling.\nTETLP is reviewing currently installed gas quality monitoring equipment. TETLP has\nseveral small volume receipt points (Jess than 15 mmcfd) delivering gas into the\nsegments of pipeline covered by the proposed special permit. TETLP's policy is to take\nspot gas samples for small volume receipt points up to 5 mmcfd and utilize continuous\ngas samplers for receipt points between 5 mmcfd and 15 mmcfd. TETLP typically\ninstalls gas chromatographs only for those points with a volume greater than 15 mmcfd.\nTETLP proposes to continue spot sampling for receipt points up to 5 mmcfd and\ncontinuous gas samplers for receipt points between 5 mmcfd and 15 mmcfd, and requests\nthe special permit allow this philosophy. TETLP believes that small volume receipts,\neven if the gas does not meet tariff gas quality specifications, will adequately blend to\neliminate the risk of internal corrosion from this gas.\nTETLP requests that this section be addressed in the proposed special permit. TETLP\nwill document the effect of blending based on proposed flows and compositions prior to\noperation at the increased pressure and then reevaluate the effect of blending on an\nannual basis.\n49 CFR 192.620(d)(7)(i)\nWithin six months after placing the cathodic protection of a new pipeline segment in\noperation, or within six months after certifying a segment under § J92.620(c)(J) of an\nexisting pipeline segment under this section. assess the adequacy of the cathodic\nprotection through an indirect method such as close-interval survey, and the integrity of\nthe coating using direct current voltage gradient (DCVG) or alternating current voltage\ngradient (ACVG).\nDuring the construction of most of the pipelines covered by the proposed special permit,\nTETLP performed post backfill coating integrity testing, and remediated coating holidays\nthat didn't meet TETLP's requirements. Since the coating integrity assessments to\nidentify and remediate coating damage caused during construction have already been\nperformed, TETLP requests an interpretation from PHMSA that clarifies the coating\nintegrity surveys do not need to be duplicated for TETLP Lines 1 and 2.\n\n<<<PAGE 12>>>\n\nDocket No. PHMSA-2008-02S7\nTETLP Request for Special Permit\nDecember 22, 2008\nPage 9 of II\n49 CFR 192.620(d)(7)(ii)\nRemediate any construction damaged coating with a voltage drop classified as moderate\nor severe (IR drop greater than 35%for DCVG or 50 dBuv for ACVG) under section 4 of\nNACE RP-0502-2002 (incorporated by reference, see §192. 7).\nGiven that this provision states \"construction damaged coating\", TETLP presumes that\nthis applies to new pipelines and construction on existing pipelines after the effective date\nof the rule, and not existing pipelines constructed prior to the effective date. TETLP\nperformed post backfill coating integrity testing for most of the pipelines covered by the\nspecial permit, and remediated coating holidays that didn't meet TETLP's requirements.\nAdditionally, TETLP will be performing a close interval survey on these pipelines to\nassure adequate cathodic protection. TETLP has also performed approximately 218\nmiles of in-line inspections with MFL tools, with very few indications of corrosion. This\nvalidates that the coating and cathodic protection systems are performing adequately to\nprotect the pipeline. TETLP requests an interpretation from PHMSA clarifying that the\nrequirement for remediation of construction damaged coating is applicable only to\npipelines installed after the effective date of the Final Rule.\n49 CFR 192.620(d)(10)(iii)\nUse direct assessment (per §192.925, §192.927 and/or §192.929) or pressure testing (per\nsubpart J of this part) for periodic assessment of a portion of a segment to the extent\npermittedfor a baseline assessment under paragraph (d)(8)(iii) of this section.\nTETLP requests an interpretation from PHMSA to clarify that direct examination\ntechniques are acceptable alternatives to external corrosion direct assessment (\"ECDA\")\nor internal corrosion direct assessment (\"ICDA\") for non-piggable segments operating at\nthe alternate design factors. TETLP believes that direct examination techniques can be\nmore effective and provide a better assessment than ECDA and ICDA for short segments\nof non-piggable lines.\n49 CFR 192.620(d)(11)(ii)(A)\nThe defect is a dent discovered during the baseline assessment for integrity under\nparagraph (d)(9)' of this section and the defect meets the criteriafor immediate repair in\n§192.309(b).\nIn the preamble of the Final Rule, PHMSA states \"With respect to dents, the repair\ncriteria of §192.309(b) apply only for dents found during construction baseline\nassessments (i.e., for new pipelines). PHMSA notes that this section already requires\nrepair of two percent dents for pipelines over 12Y4 inches in diameter. The criteria for\nrepairing dents on existing pipelines and subsequent assessments on new pipelines and\nexisting pipelines are in §192.933(d).\" (73 FR 62165) TETLP agrees with PHMSA's\nI The fmal rule language references section (d)(8), however TETLP believes this is a typographical error.\nTETLP believes (d)(9) is the correct section reference for the baseline assessment.\n\n<<<PAGE 13>>>\n\nDocket No. PHMSA-2008-0257\nTETLP Request for Special Pennit\nDecember 22, 2008\nPage 10 ofll\nstated intent, however points out that the language in the Final Rule does not reflect this\nintent. TETLP interprets the Final Rule language to require dents in existing lines to be\nremediated in accordance with § I 92.309(b) and § I 92.933( d). TETLP requests an\ninterpretation from PHMSA to clarify that § 192 .309(b) is applicable only to new\npipelines, and that dents identified by baseline assessments for existing pipelines are to be\nremediated in accordance with §192.933(d).\nPROPOSED INTEGRITY MANAGEMENT ACTIVITIES TO SUPPORT THE\nPROPOSED SPECIAL PERMIT\nTo ensure that this proposed special permit will achieve an increase in pipeline safety and\nintegrity, TETLP will apply its Pipeline Integrity Management Plan (IMP) to all\nsegments of Lines 1 & 2 covered under this proposed special permit. If the special\npennit request is granted and TETLP obtains approval from the Federal Energy\nRegulatory Commission (FERC) to reflect this uprated MAOP in its FERC-certificated\ndesign, TETLP's IMP will be applied to all segments of Lines 1 & 2 that have been\nuprated, not just those in HCAs. Specifically, TETLP proposes to perform the following\nintegrity activities:\n• Perform in-line inspection on the special permit segments with high resolution\nmagnetic flux leakage (MFL) and multi-channel geometry tools within 2 years prior\nto the MAOP uprate.\n• Perform a close-interval survey (CIS), or similar performance assessment, of the\ncathodic protection (CP) system on the special pennit segments within 2 years prior\nto the MAOP uprate.\n• Remediate all actionable anomalies based on an operating pressure of 1,112 psig and\nusing the criteria in the TETLP IMP and the Final Rule prior to increasing the\npressure.\n• Integrate CIS data with the in-line inspection results to address any cathodic\nprotection enhancements needed to improve long-term integrity of the pipeline.\nThese documented enhancements will be implemented within one-year of the\npressure increase.\n• Replace pressure rated components as needed to meet a minimum of 1,112 psig prior\nto increasing pressure.\n• Perform a leak survey in accordance with TETLP's Standard Operating Procedures\nafter the pressure increase.\n• Perform inspections and preventive and mitigative measures in accordance with the\nTETLP IMP on the segments of Line 1 & 2 pipeline system that are operating at the\nalternate design factors.\n• Perform reassessment using in-line inspection in accordance with Part 192 Subpart 0\nrequirements or more frequently based on a technical review of reassessment\nintervals for these pipelines operating at a MAOP of 1,112 psig.\n\n<<<PAGE 14>>>\n\nDocket No. PHMSA-2008-0257\nTETLP Request for Special Permit\nDecember 22, 2008\nPage II of II\n• Hydrostatic retesting of several segments of Line 1 that were not tested to 125% of\nMAOP during original construction.\n• Evaluate ILl logs to identify indications of external corrosion in close proximity to\ngirth welds and excavate those locations that are likely to have failed shrink sleeves.\n• Develop a plan for excavation of a limited number of known shrink sleeve locations,\nremoval of the shrink sleeve at these locations and evaluation of the pipe for see and\nexternal corrosion.\n• Perform long term coating integrity surveys for pipelines operating over 1200 F.\nSUMMARY\nTETLP has reviewed the Final Rule, and has determined that segments ofTETLP's Lines\n1 and 2 substantially meet most of the requirements of the Final Rule. However, TETLP\nLines 1 and 2 do not retroactively meet a limited number of the specified requirements in\nthe Final Rule, such as the those requirements regarding pipe and coating manufacturing\ntesting and inspection, construction inspection, and operator qualification requirements\nfor previous construction. In some cases, the specified requirements were not yet\nrecognized as \"best practice\", in other cases, the specified requirements were\nsubstantially met but supporting documentation does not exist. As a result, TETLP is\nrequesting its special permit petition dated September 11, 2008 be modified as detailed in\nthis letter. Additionally, TETLP requests interpretations regarding certain sections of the\nFinal Rule as to how these sections apply to existing pipelines.\nTETLP's believes the pipelines covered by the proposed special permit are well suited to\noperation at the higher design factors specified by the Final Rule. Through the proposed\nspecial permit, TETLP commits to apply rigorous integrity management activities to the\nentire pipeline covered by the special permit.\nWe look forward to continued discussions and progress on this special permit petition.\nPlease contact Rick Kivela at 713-627-6388 if you have any questions or request any\nadditional information.\nL-\nAttachments\n\n<<<PAGE 15>>>\n\ncc w/Attachments:\nWilliam Gute - PHMSA\nAlan Mayberry - PHMSA\nByron Coy - PHMSA\nClyde Myers - PHMSA\n\n<<<PAGE 16>>>\n\nTETLP LINES 1 & 2\nPROPOSED MAOP UPRATE\nYURK\nNEW\nSYL.VANIA\nVIRGINIA\nNOKTH CARCINA\n..t-\nCARININA\nAppendix\nAICHICN\n.LNOS\n_Pogend\n6 ats knos\nVINADIRI\nStation Site (No Horsepower)\nSpectra)\nEnergy-\nTexas Eastern Tranamission Corporation\n3400 farbeimur Ca. Housem. TX T7056-9310 7131827-9490\nCompressor Station\nNoturai Ges Storage Flaid\nTexas Eastern Transmisaion, LP\ndinahinpi-l (PISIST:- wits.en./cc0.sg\nOKLUIOMA\nKANSAS\nTrX ^9\n\n<<<PAGE 17>>>\n\nAPPENDIX B\nTETLP LINES 1 & 2\nSCOPE OF MAOP UPRATE\nMainline regulator al\nMP 1428.88\n36-inch Line 2\n20-inch Line 2\n36·inch Line 1\nUniontown) Bedford\n....\nChambersburg Heidlersburg Marietta\n36·inch Line 1\n20-inch Line 2 -)\nLambertville (26)\nMP 1435.90\nI 20·inch Line 1\nUprate Phase 1 (2010) J 1 Uprate Phase 2 (Date T8D) ,-1\nPhiladelphia system Skippack system\nJ\nNOTES :\nRed denotes the pipeline segments under consideration for a MAOP uprate (from 1000 psig to 1112 psig).\nTETLP is proposing a phased implementation of the uprate, with Phase 1 being uprated in Nov. 2010 and Phase 2\nbeing uprated for a future undefined expansion project.\nThe uprate will also include compressor station yard and unit piping at Uniontown, Bedford. Chambersburg and\nHeidlersburg in Phase 1 and Marietta in Phase 2. The compressor stations will be designed for a 1200 psig MAOP.\nand thus will not be included in the special permit.\nEagle Compressor Station does not compress on the mainline. It compresses gas from the mainline into the Philadelphia\nlateral (20\" Line 1-H). Therefore this unit piping is not subject to the proposed uprate.\n\n<<<PAGE 18>>>\n\nAPPENDIX C\nTEMAX and TIME III Facilities MaD\n•\n","truncated":true,"body_characters":40228}