{"operation":"document","citation":"PI-19-0006","title":"Enstar Natural Gas Company — Pipeline Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-10-22","effective_on":null,"summary":"PI-19-0006 response to Enstar Natural Gas Company concerning 192.467.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-19-0006.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-19-0006.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-pi-19-0006","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/pipeline/interpretations/72776/enstar-pi-19-0006-10-22-2019-part192467.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nofTransportation\nPipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Avenue SE\nWashington DC 20590\nOCT 2 2 2019\nMr. Steve Cooper\nDirector of Operations\nEnstar Natural Gas Company\n3000 Spenard Road\nP.O. Box 190288\nAnchorage, AK 99519-0288\nDear Mr. Cooper:\nIn a June 18, 2019, letter to the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), you asked for reconsideration of PHMSA's March 11, 2019, response to your request\nfor interpretation on external corrosion control under§ 192.467.\nYou based your request for reconsideration on the remoteness of the casing/pipeline location,\nlow operating pressure (MAOP of 60 psig), leak survey frequency, and class location of the 8-\ninch pipeline diameter, 0.277-inch wall thickness distribution pipeline located in a Class 1\nlocation.\nPHMSA provides written clarifications based on current Federal pipeline safety regulations. As\nto the referenced interpretation (PI-86-004), please refer to PHMSA's March 11, 2019, response\nletter. After examining your latest information, PHMSA does not believe remoteness of a\npipeline location and the quarterly leak survey frequency are justification for not complying with\nthe pipeline safety regulations. PHMSA still believes the March 11, 2019, interpretation\nresponse letter correctly reflects the current pipeline safety regulations. Therefore, Enstar must\nperform inspections, tests, and remediation with procedures that are in accordance with\n§ 192.467.\nlfwe can be of further assistance, please contact Tewabe Asebe at 202-366-5523.\nale\nDirector, Office of Standards\nand Rulemaking\nThe Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety provides written clarifications 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 2>>>\n\nJ UN 2 7 2 0\\9\n3000 Spenard Road\nP.O. Box 190288\nAnchorage, AK 99519-0288\nwww.enstarnaturalgas.com\nJune 18, 2019 '•,.•:\n> I • I\nU.S.DOT\nPHMSA Office of Hazardous Materials Standards\nAttn: John A. Gale\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\nRE: Interpretation Decision Letter\nPipelinl ; safety Officer~ . '\nThe following _is.in response to your March 11, 2019 l~tter t? ENST AR Natural Ga&· Co~pany ,\n(ENSTAR) regarding the interpretation request for shorted pipeline casings.\nBased on langq.age in the PHMSA response, and afl:er discussions withPHMSA staff, it was appa,rent that\ninformation impm1:ant to thj,s request was not being considered; or may not have been properly understood\nwhen. PHMSA made th~ir decisjon on this matter. ENSTAR wishes to clarify some points and\nrespectfully-requests that PHMSA reconsider this intetpretation request dated November 14~ 2016. Jn. the\ninitial request ENST AR asked to be granted an interpretation similar to an existing one (PI-86-004)\nregarding shorted casings.\nIn two of the locations where this request would apply, the remoteness of the casing/pipeline location, the\nmaximum. operating pressure of the pipeline, leak survey frequency, and pipeline class location are all\nimportant factors that should be considered. In these cases the pipeline is an 8-inch diameter distribution\npressure main (MAOP 60psi) with a wall thickness of0.277 inches and in a Class I location. The main is\na one-way feed to a remote community (Whittier, Alaska) that provides natural gas to 47 customers. As\ndescribeq it:i the. following, unique challenges to remediation of the shorts at these locations have driven\nthis request:\n• The first shorted casing is located between a steep mountainside and Portage Creek, buried\napproximately 10 feet deep and, due to its location on the opposite side of the river from the\ndriven road, only accessible by rail. Work to correct this short would almost certain require\ninstalling a new Cfossing of the river and completing a complicated tie-in between the. railroad\ntracks and the river bank.\n• The second shorted location is a few miles downstream of the first location and near where the ,\npipeline transitions out of a 2-mile· long utility twmel that pa:sses t~ough a mountain on.- its way\nAnchorage: 907-277-5551 • Kenai, Peninsul~ Office: 907-262-9334 • Mat-Su Office: ~07 376-7979\nAl/Our\n\n<<<PAGE 3>>>\n\ninto Whittier. Repairing this short would require removing a portion of the tunnel entrance and\nreplacing pipe back inside the tunnel. Replacing pipe inside the tunnel simply presents many\nchallenges related to hot work in a confined space that while not impossible, are cu,mbersome and\nexpensive.\nThese challenges while maintaining continuity of service to the end-of-the-road community during\nremediation work have made resolving isolation issues difficult. ENST AR closely monitors the cathodic\nprotection potentials of the casing and carrier pipe for deteriorating potentials, to date the potentials have\nnot shifted. As an alternative solution to date ENST AR has performed leak surveys every quarter year to\nensure the integrity of the system. This process has been completed in accordance with a previous\nPHMSA interpretation, PI-86-004 3(A) iii, which was given to the Public Service Commission of\nKentucky in 1986. ENST AR requests that PHMSA grant the same guidance to ENST AR as described in\nthe interpretation PI-86-004, specifically part 3. Reasonable time allowance and methods for operator\ncorrection of shorted casings.\nShould you have any questions regarding this request for interpretation, please feel free to call me\nat 907-334-7730 between 8:00 AM and 5:00 PM AST.\nSincerely\nENSTAR Natural Gas Company\nSteve Cooper, P.E.\nDirector of Operations\nSteve.Cooper@enstarnaturalgas.co:rn\nAnchorage: 907-277-5551 • Kenai Peninsula Office: 907-262-9334 • Mat-5~ Offi' ce ; 90/316· ~79'7~ ·\nAl/Our","truncated":false,"body_characters":6066}