GULF SOUTH PIPELINE COMPANY, LLC — Integrity Assurance Notification

ALTERNATIVE PIPE SAMPLINGIn accordance with §192.18, Gulf South Pipeline Company, LP (Gulf South) is hereby notifying PHMSA of its intent to use an alternative statistical sampling approach as outlined in §192.607(e)(5). Gulf South intends to use Rosen’s RoMAT PGS in-line inspection pipeline grading tool on Gulf South’s Index 915-6 in Escambia County, Florida on or around August 26, 2021. As clarified in FAQ-21 [1], the data collected from Rosen’s RoMAT tool will be used to determine pipeline population groups under §192.607(e). Also as stated in FAQ 22 [1], ILI can be used to determine pipeline material properties and attributes. The RoMAT tool is capable of collecting material properties and attributes on every pipe joint and every bend. This approach far exceeds the sampling frequency required by §192.607(e)(2) (one per mile in each population) and meets the requirements of §192.607(e)(5) ensuring that the material properties and attributes are valid. Rosen’s analysis of the ILI data will be based on a statistical analysis to achieve at least a 95% confidence level that the material properties are valid. Furthermore, Rosen’s analysis will be supplemented with in-ditch non-destructive and/or destructive testing once population groups are established. The frequency of the in-ditch testing will be defined after the ILI data analysis is completed.#