PHMSA-2008-0067
PHMSA-2008-0067
Notice to PHMSA from Oprator (Increase of Operating Pressure as per Existing Special Permit Conditions)(Fayetteville Lateral), page 1Official PDFBOARDWALK SEP 2 8 2010 OOO PIPELINE PARTNERS™ September, 27, 2010 Mr. Jeffrey Wiese JS Department of Transportation Issociate Administrator for Pipeline Safety Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE E22 Washington, DC 20590 Re: Notice to Increase Operating Pressures up to Special Permit Levels on the Fayetteville Lateral Only, under the Special Permit issued July 31, 2008 ("Special Permit") and the Modification Agreement, dated April 30, 2009, as Amended Documents"); and Supplemented (collectively, "Special Permit Fayetteville/Greenville Lateral Pipelines, Docket No. PHMSA-2008-0067 Dear Mr. Wiese: Boardwalk Pipeline Partners, LP, by and through its subsidiary Texas Gas Transmission, LLC (hereinafter "Boardwalk"), in cooperation with the Pipeline and Hazardous Materials Safety Administration (hereinafter "PHMSA"), has been actively engaged in satisfying the terms and conditions set forth in the Special Permit Documents. As part of those terms and conditions, Boardwalk is required to provide PHMSA with thirty (30) days prior notice of its intent to operate the applicable pipeline at Special Permit operating pressures. This letter shall serve as Boardwalk's thirty (30) day prior notice for the Fayetteville Lateral only. Boardwalk will, at a later date, submit a similar thirty (30) day notice to PHMSA to operate the Greenville Lateral at Special Permit operating pressures. With respect to the Fayetteville Lateral, Boardwalk has satisfied all of the terms and conditions of the Special Permit Documents, except for those two conditions discussed below. Specifically, Boardwalk has successfully implemented Conditions 1 (Steel Properties), 2 (Manufacturing Standards), 3 (Fracture Control), 4 (Steel Plate Quality Control), 5 (Pipe Seam Quality Control), 6 (Mill Hydrostatic Test), 7 (Pipe Coating), 8 (Field Coating), 9 (Coatings for Trenchless Installation), 10 (Bends Quality), 11 (Fittings), 12 (Design Factor - Pipelines), 13 (Temperature Control), 14 (Overpressure Protection Control), 15 (Welding Procedures), 16 (Depth of Cover), @GUL CROSSING , GULF SOUTH' OH, LLO 9 Greenway Plaza, Sulte 2800, Houston, Texas 77046 713.479.8000#
Notice to PHMSA from Oprator (Increase of Operating Pressure as per Existing Special Permit Conditions)(Fayetteville Lateral), page 2BOARDWALK PIPELINE PARTNERS™ 17 (Construction Quality), 18 (Interference Currents Control), 19 (Test Level), 20 (Assessment of Test Failures), 21 (SCADA System Capabilities), 22 (SCADA Procedures), 23 (Mainline Valve Control), 24 (Pipeline Inspection), 25 (Gas Quality Monitoring), 28 (Gas Quality Control), 29 (Gas Quality Monitoring Equipment), 33 (Verification of Cathodic Protection), 36 (Pipeline Markers), 44 (Potential Impact Radius Calculation Updates), and 46 (Reporipel- 30 day) during the design, pipe manufacturing, construction and operating phases In addition, the following conditions of the Special Permit have been incorporated into the Boardwalk Operations & Maintenance Manual: Condition 3 (Fracture Control), 7 (Pipe Coating), 8 (Field Coating), 9 (Coatings for Trenchless Installation), 10 (Bends Quality), 11 (Fittings), 12 (Design Factor - Pipelines), 13 (Temperature Control), 14 (Overpressure Protection Control), 16 (Depth of Cover), 18 (Interference Currents Control), 21 (SCADA System Capabilities), 22 (SCADA Procedures), 23 (Mainline Valve Control), 24 (Pipeline Inspection), 25 (Gas Quality Monitoring), 26 (Pigging Plan), 27 (H2S Sampling), 28 (Gas Quality Control), 29 (Gas Quality Monitoring Equipment), 30 (Cathodic Protection), 31 (Interference Current Surveys), 32 (Corrosion Surveys), 33 (Verification of Cathodic Protection), 34 (Initial CIS), 35 (Initial Coating Assessment), 36 (Pipeline Markers), 37 (Pipeline Patrolling), 38 (Monitoring of Ground Movement), 39 (Initial ILL), 40 (Future ILI), 41 (Direct Assessment Plan), 42 (Damage Prevention Program), 43 (Anomaly Evaluation and Repair), 44 (Potential Impact Radius Calculation Updates), 45 (Reporting - Immediate), 46 (Reporting - 30 Day), and 47 (Annual Reporting). For Condition 31 (Interference Current Surveys), Boardwalk completed the interference surveys within six (6) months of placing the Fayetteville Lateral pipeline in service. Since that time, Boardwalk discovered interference issues at two foreign pipeline crossing locations at Station 3383+77 and Station 3365+29. Site-specific interference tests were completed at each of these two pipeline crossings, and the sites were both excavated and remediated to address the interference issues. To ensure the remediation was effective, in September of 2010, Boardwalk performed a close interval survey (CIS) of the entire Fayetteville Lateral, including these two locations, and the CIS data confirms there are no interference issues on the entire pipeline and the stray currents at these two specific locations have been remedied. (For more detailed information, please see the attached Special Permit Book in CD format, hereinafter "Special Permit CD." These interference issues and mitigative measures will also be reported in the next & GULF CROSSING GULFSOUTH TEXAS OAS 9 Greenway Plaza, Suite 2800, Houston, Texas 77046 713.479.8000#
Notice to PHMSA from Oprator (Increase of Operating Pressure as per Existing Special Permit Conditions)(Fayetteville Lateral), page 3BOARDWALK OOO PIPELINE PARTNERS™ For Condition 35 (Initial Coating Assessment), the required DCVG testing was completed on the Fayetteville Lateral with the exception of some in-accessible waterways and flooded areas that were not feasible to access with DCVG or ACVG surveys. These skipped (PCM). When both CIS and PCM data are integrated, a determination of the coating condition under the body of water can be made. The PCM and CIS field work has been completed for these skip areas. Integration of the CIS and PCM data is currently being analyzed. The threshold levels for monitored, scheduled, and immediate anomaly response will be established utilizing the criteria set forth in the Boardwalk External Corrosion Direct Assessment Plan. In any event, Boardwalk will submit a separate letter to PHMSA to confirm the completion of this Condition 35 prior to operating the Fayetteville Lateral at Special Permit pressures. Please consider this letter as Boardwalk's thirty (30) day notice of intent to increase its operating pressures to those set forth in the Special Permit for the Fayetteville Lateral. Specifically, Boardwalk intends to operate the Fayetteville Lateral with design factors of 0.80 in Class 1 and 0.67 in Class 2 locations. As noted above, the Greenville Lateral will not be operated under the Special Permit until such time as Boardwalk sends a similar notice to PHMSA certifying completion of all the conditions of the Special Permit Documents for the Greenville Lateral. For your convenience, please find attached to this letter the Special Permit CD. The Special Permit CD contains documentation of Boardwalk's compliance with the conditions of the Special Permit Documents. Boardwalk requests that PHMSA treat the information contained on the Special Permit CD as "confidential business information" and that Boardwalk is deemed a "submitter" within the meaning of the Freedom of Information Act, 5 U.S.C. § 552. & GULF CROSSING GULF SOUTH * TAXAS AR 9 Greenway Plaza, Suite 2800, Houston, Texas 77046 713.479,8000#
Notice to PHMSA from Oprator (Increase of Operating Pressure as per Existing Special Permit Conditions)(Fayetteville Lateral), page 4... .. BOARDWALK : O00 PIPELINE PARTNERS™ Boardwalk appreciates PHMSA's continuing efforts to address these important issues. If you have any questions or require any additional information, please contact Frank Maraia at (985) 898-1004 or Frank.Maraia@bwpmlp.com. Sincerely, and bood. David Goodwin Vice President cc: Mr. Rod Seeley Ms. Linda Daugherty Mr. Alan Mayberry Mr. Wayne Lemoi Mr. Chris Taylor Mr. Anthony Rallis & GULF CROSSING GULF SOUTH" TEXAS A 9 Greenway Plaza, Sulte 2800, Houston, Texas 77046 713.479.8000#
This is an issued PHMSA special permit. The issued index does not establish current validity or applicability beyond the facilities and conditions stated in the official decision.