# National Fuel and Gas Supply Corporation — Pipeline Special Permit - **operation:** document - **citation:** PHMSA-2017-0090 - **title:** National Fuel and Gas Supply Corporation — Pipeline Special Permit - **source type:** permit - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** current - **official:** true - **published on:** 2019-08-27 - **effective on:** 2019-08-27 - **summary:** PHMSA-2017-0090, issued 2019-08-27 for National Fuel and Gas Supply Corporation's transmission system. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0090.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0090.md - **app url:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0090 - **source url:** https://www.regulations.gov/docket/PHMSA-2017-0090 **body:** PHMSA pipeline special permit PHMSA-2017-0090. Operator: National Fuel and Gas Supply Corporation. System: Transmission. Issue date: 2019-08-27. <<>> U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT Special Permit Information: Docket Number: PHMSA-2017-0090 Requested By: National Fuel Gas Supply Corporation Operator ID#: 13063 Original Date Requested: July 28, 2017 Original Issuance Date: August 27, 2019 Effective Dates: August 27, 2019 to August 26, 2029 Code Section(s): 49 CFR 192.53, 192.55, 192.105, 192.107, 192.109, 192.111, 192.113, 192.144, 192.149, 192.150, 192.327, 192.463, and 192.619 Grant of Special Permit: By this order, subject to the terms and conditions set forth below, the Pipeline and Hazardous Materials Safety Administration (PHMSA) Office of Pipeline Safety (OPS)' grants this special permit to National Fuel Gas Supply Corporation (NFG) waiving compliance from 49 Code of Federal Regulations (CFR)) 192.53, 192.55, 192.105, 192.107, 192.109, 192.111, 192.113, 192.144, 192.149, 192.150, 192.327, 192.463, and 192.619 for one (1) pipeline segment totaling 5.8 miles of 6-inch diameter FlexSteel pipe and components located in gas transmission class 1 and 2 locations on the FM120 Pipeline located in McKean and Elk Counties, Pennsylvania, as described below. This special permit is for usage of FlexSteel pipe and components in Class 1 and 2 locations inserted within a 12.75-inch diameter casing pipe. FlexSteel is a type of flexible steel pipeline, which is not currently in use in PHMSA-regulated interstate gas transmission pipelines. Purpose and Need: This special permit grant is part of a modernization project which will allow NFG to use FlexSteel 1 Throughout this special permit the usage of "PHMSA" or "PHMSA OPS" means the U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety. Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 1 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> pipe to replace a 12.75-inch diameter, 1950's vintage bare steel pipeline, known as the FM120 Pipeline. The new 6-inch diameter FlexSteel will be inserted through the existing 12.75-inch diameter pipeline, which will require significant maintenance and repair to continue to operate in pressurized natural gas service. Use of FlexSteel will significantly reduce excavation, earth disturbance, and other activities associated with removal of the existing 12.75-inch diameter steel pipeline and installation of a new steel pipeline into the right of way. This special permit with conditions implemented by NFG will allow the use of FlexSteel pipe for this modernization project. This special permit will allow NFG to replace approximately 5.84 miles of FM120 Pipeline (1950s vintage 12.75-inch diameter bare steel natural gas pipeline) through insertion of 6-inch FlexSteel pipe into the existing FM120 bare steel pipeline. NFG states that replacement will enhance the reliability and safety of NFG's FM120 Pipeline for the public, its shipper's distribution markets, storage and local production, and users of the state forest where the pipeline runs. Upon completion, NFG will continue to provide connectivity for storage and transportation services. The insertion process will greatly reduce the earth disturbance and amount of time required to complete the project as compared to the standard direct bury, or open trench type of construction. IL. Regulatory Background This special permit application request seeks a special permit (waiver) to use flexible steel pipe in a gas transmission pipeline that operates at a maximum allowable operating pressure (MAOP) of 720 pounds per square inch gauge (psig). NFG has requested a special permit (waiver) of the following 49 CFR 192 sections: Section Section Title Discussion / Rationale 192.53 General Sub-paragraph (c) does not recognize flexible steel pipe in meeting the requirements of the Subpart. 192.55 Steel Pipe (a)(1) There is no listed specification for flexible steel pipe. (a)(2) Qualification requirements are specific to rigid steel pipe and do not apply to flexible steel. 192.105 Design formula for steel This section does not provide a design formula for flexible steel pipe. pipe 192.107 Yield strength (S) for steel This section does not provide a design formula for flexible steel pipe pipe and fittings. 192.109 Nominal wall thickness (t) This section does not address the steel strip reinforcement used in for steel pipe flexible steel pipe. Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 2 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> 192.111 | Design factor (F) for steel This section does not provide design factors for flexible steel pipe. pipe 192.113 Longitudinal joint factor This section does not apply to flexible steel pipe. (E) for steel pipe 192.144 Qualifying metallic components There is no listed specification for the swaged steel connectors to use with the FlexSteel pipe system. 192.149 Standard fittings There is no listed specification for the Flexsteel connectors. 192.150 Passage of internal There is no need or value in running an ILI tool since the internal inspection devices wall of the FlexSteel pipe is thermoplastic instead of steel. 192.327 Cover The existing 12.75-inch diameter steel pipeline is proposed to be used as a casing for the new 6-inch FlexSteel pipeline. Given that the existing line was installed in the mid-1950's, there are some areas with less than 30-inches to 36-inches of cover. However, the existing steel pipe, will serve as a casing for the FlexSteel line, thereby affording it an additional level of protection from excavation damage and from anticipated wheel loads. 192.463 External corrosion control: This section envisions steel coated or bare pipe and does not Cathodic Protection contemplate externally high-density polyethylene (HDPE) lined steel materials. NFG will insert FlexSteel pipe into the existing 12.75- inch diameter pipeline, which will be cleaned prior to insertion (See Section VIII, Condition 5.a.v for pipeline cleaning procedure). NFG will direct bury and install a cathodic protection test station and anode in soil at every FlexSteel fitting outside the 12.75-inch diameter casing. 192.619 Maximum allowable This section does not provide a design formula for flexible steel pipe. operating pressure: Steel or plastic pipelines III. Special Permit Segment and Inspection Area: McKean and Elk Counties, Pennsylvania Special Permit Segment: This special permit applies to the special permit segment defined as follows using the NFG FM120 Pipeline survey station references: • Special permit segment - FM120 Pipeline — (30,624 feet or 5.84 miles) Mile Post 0.0 to 5.84; The special permit segment is defined as 5.84 miles of the FM120 Pipeline which is being replaced with a 6-inch diameter FlexSteel pipe inserted into an existing 12.75-inch diameter pipeline. The special permit segment is in McKean and Elk Counties, Pennsylvania. Attachment 1 - FM120 Pipeline Overview Map shows the location of the special permit segment. Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 3 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> The special permit segment MAOP will be 720 psig. PHMSA grants this special permit based on the findings set forth in the "Special Permit Analysis and Findings" and "Final Environmental Assessment and Finding of No Significant Impact" documents, which can be read in their entirety in Docket No. PHMSA- 2017-0090 in the Federal Docket Management System (FDMS) located on the internet at www.regulations.gov. IV. Conditions: PHMSA grants this special permit subject to the following conditions: 1) NFG must design, operate, and maintain the pipeline in accordance with the following: a) For purposes of the special permit, the "special permit segment," i.e., the "Project," is defined as the FlexSteel pipe, fittings, monitoring devices, and related facilities to be installed within the 5.84-mile section of FM120 Pipeline. Other "new construction" will consist of those installations outside of the 5.84 miles of the special permit segment and is not included in this special permit. b) The pipeline must operate at or below a MAOP of 720 psig. This MAOP has been established based on the pipeline facilities that the special permit segment is connected to Line K, an interstate pipeline that spans between northern Pennsylvania and the Buffalo, New York areas and Line KL, a pipeline that spans between Line K and the FM120 Pipeline. The pipeline must operate at or below a design factor of 0.24 of the stated product burst rating of 3,000 psig, which is 48% of the product's 1,500 psig manufacturer pressure rating, for all class locations, and road crossings within the special permit segment. i) All road crossings must be cased with steel pipe. Any future road crossings using FlexSteel pipe must have a minimum of 36-inches cover and must be cased or 49 CFR Part 192 compliant steel pipe must be installed. ii) Due to the composite design of FlexSteel pipe, Barlow's formula in 49 CFR 192.105 cannot be used to determine the pressure rating of this material. Per API 15S, Second Edition, Section 5.2.5, the maximum pressure rating for a product is equal to the product's calculated minimum burst pressure multiplied by a maximum design factor of 0.5. In this case, the 6-inch diameter FlexSteel pipe has Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 4 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> a minimum burst pressure of 3,000 psig, which results in a maximum pressure rating of 1,500 psig.? d) NFG must conduct quarterly patrols and instrumented leakage surveys at a maximum of 4- ½ months, but at least four times each calendar year in accordance with the requirements in 49 CFR 192.705, 192.706, and 192.935(d)(3) on the special permit segment. e) Should a class location increase or expand in length in the special permit segment, NFG must notify PHMSA of the class location changes or of a new high consequence area (HCA). i) This special permit is not applicable for Class 3 and 4 locations and HCAs or for a class 2 to 3 class location bump as described in 49 CFR 192.611. ii) The special permit conditions must be reviewed for class location modifications (49 CFR 192.609) to ensure Code compliance and safety are maintained. If a new building intended for human occupancy is identified within 197 feet (1.5 times PIR) of the special permit segment and that building causes the Class 1 location to become a Class 2 location or causes the present Class 2 location to extend in length along the special permit segment, NFG will be required to remove and replace that portion of FlexSteel pipe with 49 CFR Part 192-compliant steel line pipe. f) NFG must treat the special permit segment as if the entire segment is a covered segment in an HCA and must develop and follow an integrity management program in accordance with the requirements of 49 CFR Part 192, Subpart O (except as waived or modified herein) applicable to plastic transmission pipelines including the following sections: 49 CFR 192.901, 192.917(b) through (e), 192.921(a)(2) or (a)(4), 192.935, 192.937 (c)(2) or (c)(4), and 192.939(b). This includes, but not limited to, risk assessments, regular patrolling, participation in the national one call system, installation of remote controlled valves, and a pressure test re-assessment every seven (7) years, not to exceed 90 months, at a minimum pressure of 1.5 times MAOP for 24 continuous hours. g) NFG must ensure that both its Integrity Management (IM) Procedures and its Operations & Maintenance (O&M) Procedures are modified to incorporate the conditions required by 2 The proposed 6-inch diameter FlexSteel pipe will be 5.60-inch inside diameter and 7.05-inch outside diameter with a rating (°F), and maximum installation tension of 30,000 pounds. of 1,500 psig, empty weight of 12.9 pounds per foot, maximum pipe operating temperature of 150 degrees Fahrenheit Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 5 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> this special permit for the special permit segment. NFG must make these portions of its IM Procedures and O&M Procedures available to PHMSA upon request. 2) General and Design Requirements a) Branches: NFG must not tap, branch, or split the special permit segment FlexSteel pipe without the use of the appropriate FlexSteel manufactured fittings for the specified application. 3) Material and Testing Requirements a) Pipe Layers: NFG must install line pipe in the special permit segment that is comprised of high density polyethylene (HDPE) PE4710 inner and outer layers made from natural gas pipe grade material, which meet the material requirements of API 15S, Second Edition. All FlexSteel components must be manufactured and tested in accordance with API 15S, Second Edition. b) Regrind and Rework of Polymeric Materials: Materials used in the manufacture of the pipe installed within the special permit segment, during construction or in future repairs or replacement, may not contain any regrind or rework material. c) Outdoor Pipe Storage: NFG must comply with API 15S, Second Edition requirements for outdoor storage and ultraviolet radiation exposure of polyethylene (PE) pipe for all FlexSteel pipe materials used in the special permit segment. NFG must document compliance with API 15S, Second Edition in its Material Specifications and O&M Procedures. NFG must obtain mechanical and chemical properties test reports that certify the steel by heat used in manufacturing the FlexSteel pipe. d) Factory Pressure Testing: All pipe used in the special permit segment must be factory pressure tested to a minimum of 1.3 times MAOP for a minimum of one (1) hour. NFG must make available pressure test records demonstrating that all special permit segment pipe was factory pressure tested. Such records must be traceable to all line pipe repair pipe or replacement pipe used within the special permit segment and must include: pressure test reports, pressure testing parameters (pressure, time, procedure and/or standard number, date, etc. and test acceptance parameters), and pressure testing recorders with current calibration records for pressure test recoding equipment. NFG must provide a certification from the pipe manufacturer that the tests were completed and that all pipe was visually checked during the pressure tests for leaks. NFG must make available all pressure test Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 6 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> records to the Director, PHMSA Eastern Region prior to operation of the special permit segment upon request. e) Long-Term Integrity: In designing the pipeline, NFG must consider and plan for all pipeline risk factors, including, but not limited to: pressure and temperature cycling; performance of multilayer composite pipe in subzero temperatures, and repairs under a range of ambient conditions; long term performance of composite material and mechanical fittings; cathodic protection of metallic appurtenances; coating performance; long term performance of pipe; risk migration through damage inner pipe wall; and methods for assessment of buried or excavated pipe. i) NFG must schedule and perform five (5) inspections during which non-destructive and destructive testing must be performed on the pipe material after installation. Nondestructive testing must focus on the composition and degradation of the pipe material and destructive testing must include a hydrotest to burst pressure. NFG must perform these inspections and tests at a maximum of 1, 2.5, 5, 7.5 and 10 year intervals (not to exceed this timing by 90-days) after installation. ii) A section of pipe no less than 200 feet must be installed in such a way that simulates the condition of the special permit segment (i.e. cased) in the immediate vicinity of the operating pipeline at Milepost 0 on or near NFG's property, see Attachment 1- FM120 Pipeline Overview Map. This FlexSteel pipe segment must have 20 feet removed during the intervals defined in (i) to be evaluated, including destructive testing. The results must be made available to the Director, PHMSA Eastern Region. 1. Each removed segment must be disassembled, visually, and non- destructively inspected, as appropriate, for any indications of corrosion; 2. FlexSteel's internal and external HDPE layers must be destructively tested per ASTM D638-03 (Standard Test Method for Tensile Properties of Plastics) 2003 edition for yield strength, ultimate strength, and elongation. These properties must be evaluated based on the requirements of ASTM D2513-12ael (Standard Specification for Polyethylene (PE) Gas Pressure Pipe, Tubing, and Fittings) April 1, 2012 edition, Section 5.12.2.1 (Elongation) Table 1, and ASTM D3550-12el (Standard Specification for Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 7 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> Polyethylene Plastics Pipe and Fittings Materials) April 1, 2012 edition, Table 1 (Yield Strength). 3. Flex Steel's inner core must be destructively tested per ASTM A370-18 December 1, 2018 edition for yield strength, ultimate strength and elongation and per ASTM A751-14a October 1, 2014 edition for chemical composition. These results must be evaluated based on the requirements of ASTM A109-16 (Standard Specification for Steel, Strip, Carbon (0.25 Maximum Percent), Cold Rolled) 2016 Edition Table 2 (Chemical Properties). The results of the mechanical properties testing shall be per the manufacturer's requirement for as-received steel strip materials. These mechanical property values exceed the values listed in ASTM A109-16. Acceptance criteria is available for review upon request, but for trade secret reasons, it is requested that the criteria not be listed in the docket folder. 4. A section of FlexSteel pipe must be burst tested per the requirements of API 15S, Second Edition, Section 5.2.3.5. iii) Perform removal, replacement, and installation of pipe and fittings, and other actions related to the removal of test segments, in accordance with the requirements of this special permit. iv) NFG must report the results of the inspections and tests to the Director, PHMSA Eastern Region within 60 days of completion of testing. 4) Construction Operator Qualifications a) If the performance of a construction task associated with construction or repair of the special permit segment could affect the integrity of the segment, NFG must treat that task as a "covered task" notwithstanding the definition in 49 CFR 192.801(b), and must implement the requirements of 49 CFR Part 192, subpart N. NFG's construction operator qualification (COQ) procedures, training program, and qualification tests must include detailed information on all construction-related tasks as a covered task. b) NFG must develop and implement a COQ plan that specifically relates to construction activities for the special permit segment. The purpose of the plan must be to ensure construction personnel and operations personnel are trained. The COQ plan must be followed throughout the construction phase with respect to the following: pipe inspection, Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 8 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> hauling and stringing, appurtenance inspection, field jointing methods, installation of appurtenances, pull through of the pipeline, padding and backfilling as required, hydrostatic testing, pipe repairs made from hydrostatic testing, dewatering and purging, and inspection of work (i.e. trenching, excavating, etc.). These tasks can affect the integrity of the special permit segment and must be treated as "covered tasks." The individuals driving the pipe trucks to the pipeline right-of-way will not need to be COQ qualified, unless they are responsible for the pipe unloading. c) NFG must also treat in the following special permit segment tasks as covered COQ "covered tasks", such tasks include: right-of-way soil stability determination, surveying, locating foreign lines, one call notifications, ditching or excavation, cathodic protection (CP) system surveys, mitigation, and installation, anomaly evaluations and repairs, right of way clean up (including installation of line markers), SCADA control point installation and verification, gas quality monitoring, and quality assurance monitoring. d) NFG must have FlexSteel personnel on-site when initial pipeline installation is conducted. i) NFG must have FlexSteel certified joining personnel onsite installing all FlexSteel couplings. e) NFG must make available its COQ plan to the Director, PHMSA Eastern Region 30-days prior to beginning construction. 5) Excavation, Pipe Cover, and Damage Prevention a) Pipe - Inspection for Damage: i) NFG must make available its inspection training and qualification plan to the Director, PHMSA Eastern Region 30 days prior to the start of construction. This plan must define the requirements and training necessary to inspect and evaluate damage to FlexSteel pipe and fittings. In addition, NFG must have FlexSteel employees on site during any insertion activities not only to advise on any construction related activities but to assist in inspection, evaluation, and repair of any damage indications, should they be encountered. ii) NFG must inspect the pipeline during offloading at the storage yard, offloading on location, during uncoiling, placement into the ditch, backfill, right-of-way grading, and clean up. iii) NFG must certify and document all inspections with date, time, pipeline station, and pipe spool number. Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 9 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> iv) NFG must inspect the leading 25 feet of pull-through pipe for damage, and replace any damaged pipe. All indications of pipe damage must be evaluated and replaced or repaired as follows: (1) Option 1 - Minimal Damage to the Pipe Shield: Gouges or scrapes that exceed 0.1181 inches or 3 millimeters (mm) in depth must be repaired in accordance with Option 2 or 3 below or replaced with new pipe. (2) Option 2 - Moderate Damage to the Pipe Shield with No Steel Strip Exposed: gouges more than the depth specifications listed above must be repaired with either a pipe clamp or a pipe repair system consisting of polyethylene/butyl rubber pipeline tape, heat-activated wrap, or replaced with new pipe. Prior to applying the clamp or wrap, gouges must be smoothed and blended with an appropriate grit sand paper or equivalent material. For this repair option to be used the pipe must contain: no visible evidence of exposed steel layers, outer sheath damage must be less than six (6) square inches, and the outer sheath damage cannot be more than halfway around the pipe. (3) Option 3 - Extensive Damage to the Pipe Shield: When the steel layer has become exposed or the degree of outer sheath damage exceeds the parameters specified in Option 2 above, the damaged section of the pipe must be cut out and a midline connection installed. v) During the pre-installation, NFG must develop procedures for internally cleaning the existing 12.75-inch diameter pipe (future casing pipe) to remove liquids and debris and to inspect the casing pipe for any hazards that could damage the FlexSteel pipe during the casing pull through. vi) Prior to insertion, each insertion section of the special permit segment must be pigged with a cleaning pig to verify the cleanness of the section. If any liquids are found as a result of this run, additional cleaning pig runs must be performed until no visible liquids are found. vii) During the insertion process, the tensile force on the FlexSteel pipe shall be monitored by use of a calibrated dynamometer, calibrated within six (6) months of use. This tensile force shall be limited to 24,000 pounds which is 80% of FlexSteel's rating of 30,000 pounds. Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 10 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> b) NFG must develop and implement O&M Procedures and/or Construction Specifications to remove and replace any FlexSteel pipe with the following conditions: 1) Cuts, scrapes, abrasions, or gouges that at any place exceeds the criteria for wall damage defined in Condition 5(a). ii) Discolorations of the outer HDPE layer that may indicate material degradation or lack of homogeneity; ili) All FlexSteel pipe must be newly produced after the grant of this special permit and not obtained from inventory. The outside HDPE layer is PE 4710 wịth 2% carbon black content, which has a 50-year UV resistance per ASTM D3350.3 iv) Any section of FlexSteel pipe that appears to contain cracking or crazing (may require laboratory testing to determine any widespread materials issue with the pipe); and in the event, that crazing is identified, crazing less than 0.07874-inches (2 mm) in depth will have no adverse effects on the pipe. Any damage exceeding 0.07874-inches (2 mm) in depth will require a more detailed assessment to determine the appropriate mitigative measures, up to and including replacement.4 v) NFG must not install any FlexSteel pipe above grade (ground). c) Other possible signs of material damage or unsoundness must be reviewed by qualified personnel, and if the integrity of the FlexSteel pipe is negatively affected, NFG must remove and replace such pipe. i) NFG must document its repair and replacement procedures and standards within the comprehensive written specifications or standards required under 49 CFR 192.303 and the O&M Procedures required in 49 CFR 192.605. ii) NFG must develop O&M Procedures based upon safe operating conditions, but must hand dig for initial location of the special permit segment pipeline and associated monitoring devices' communication lines. NFG must hand dig whenever excavation operations are within two (2) feet of the pipeline and associated monitoring devices' communication lines. 3 NFG and FlexSteel do not believe discolorations will be an issue for this application. 4 NFG and FlexSteel believe crazing and cracking will be unlikely for this project. Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 11 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> iii) NFG must prepare and follow a damage prevention program in accordance with 49 CFR 192.614. NFG must make this program part of its O&M Procedures prior to placing the special permit segment in natural gas service. d) NFG must ensure that the special permit segment will comply with the requirements in 49 CFR Part 192, except as waived or modified herein as listed in Section II - Regulatory Background. 6) Corrosion Control a) NFG must apply cathodic protection (CP) on all buried FlexSteel pipe components, and joints within the special permit segment in accordance with 49 CFR Part 192 (except as waived or modified herein). Electrical conductivity of swaged joints to inner pipe layer must be tested. i) Each FlexSteel fitting must be installed with an anode and CP test station. These fittings are electrically conductive with the FlexSteel pipe inner steel core. b) Test stations: NFG must install CP test stations at each metallic connector. c) NFG must perform external corrosion control monitoring on each buried metallic fitting in accordance with 49 CFR 192.465. NFG must perform CP monitoring at least once each calendar year, not exceeding 15 months. Corrosion control monitoring of the buried metallic fittings by a sampling basis is not permitted. i Each stainless steel and carbon steel FlexSteel fitting must be installed with a test station and anode, coated and direct buried. d) NFG must determine the native structure-to-electrolyte potential for each buried metallic fitting prior to energizing the CP system. e) NFG must seal the 12.75-inch casing ends to prevent water and other debris from entering the casing annulus. f) NFG must ensure that no 12.75-inch casing end, where natural gas can leak or migrate to the soil surface, is within the 6-inch FlexSteel pipe PIR (minimum of 131 feet) of a dwelling for human occupancy for the life of the special permit. g) NFG must develop and implement Construction and O&M Procedures to identify non- isolation areas and maintain electrical isolation of the FlexSteel pipe inner steel core from contact with the steel casing pipe and from water entering the inner steel core. Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 12 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> 7) Pressure and Temperature Control and Monitoring a) NFG must install an annulus monitoring system (Condition 7(d) below) that will provide continuous integrity monitoring of the external HDPE layer. If a holiday is present on the . external layer, this system will detect this defect. b) Over-pressure Protection: NFG must install over-pressure protection equipment necessary to keep the pipeline pressure from exceeding 720 psig plus allowable build-up at any time. Allowable build ups are those conditions which occur due to anomalous conditions outside of the special permit segment. Occurrences resulting in pressures exceeding 720 psig plus allowable build-up of MAOP plus 4%, must be reported to the Director of PHMSA Eastern Region within 24 hours or the next business day of the occurrence for their review. c) Pressure Monitoring: NFG must monitor operating pressures by the installation of pressure transmitters and switches in the piping system that report to the facility's SCADA system. NFG must monitor the special permit segment with continuous and redundant pressure transmitters and switches. NFG must provide a means to inform operator personnel performing work on the pipeline of the pressure on the line. d) Annulus Monitoring: NFG must install an annulus monitoring system that will provide continuous integrity monitoring of the external HDPE layer. If a holiday is present on the external layer, this system will detect this defect. NFG must continuously monitor through SCADA the pressure of the annulus space between the FlexSteel pipe HDPE layers along the "entire special permit segment." These pressure monitoring transmitters and pressure vents must be located at valve settings at Mile Post 0 and Mile Post 1.2, see Attachment 1 - FM120 Pipeline Overview Map. ii) The annulus between inside liner and outer jacket HDPE materials is used to monitor pipe integrity. This annulus is a pressure containing capable structure that is designed to contain pressure up to 30 psig. 1/8-inch female (national pipe thread) NPT outlets on the end fittings will be outfitted with the necessary tubing to attach pressure transmitters that must be incorporated into SCADA monitoring. With permeated gasses permitted to build to a predetermined level (15 to 20 psig), transmitters will be configured to alarm on indications of high or low pressure outside of the established acceptable range. Continuous pressure readings within acceptable ranges provide real time indication that several key integrity features are Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 13 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> functioning as designed. Positive pressure indicates the outer jacket material is intact (holiday free), demonstrating a "perfect coating", thus external corrosion cannot occur. It indicates that the HDPE liner material is intact and containing bore gas pressure as intended. Any breach of the liner will expose the outer jacket to bore pressure, resulting in a loss in pressure indicated by the "real time" annulus monitoring. This monitoring will alert NFG that third party damage or liner failure may have occurred, allowing prompt response for further investigation. NFG will use this monitoring capability and monitor this annular pressure with a SCADA system on a continuous 24-hour basis. iii) The FlexSteel fittings must be designed to allow the annulus of each segment of pipe to be common with each other, so that monitoring of the annular space can be conducted at one end of the system. iv) A pressure relief valve with a 20 psig set point must be installed with annulus monitoring equipment to maintain the 15 to 20 psig pressure range. This relief and the associated annulus monitoring equipment must be located within fenced in locations at Mile Posts 0 and 1.2. e) Gas Temperature: NFG must continuously monitor natural gas temperature at the discharge of NFG's Wellendorf Compressor Station, see Attachment 1 - FM120 Pipeline Overview Map, in order that the pipeline is not exposed to temperatures exceeding 150 degrees Fahrenheit (°F). If the FlexSteel pipe is exposed to temperatures exceeding 150 °F, the special permit segment pipeline must be shut down, pressure reduced to a maximum of 20% below the current operating pressure, and the Director, PHMSA Eastern Region must be contacted within two (2) working days of the detection for their review. f) SCADA and Shut-In: i) NFG must continuously monitor the special permit segment with a SCADA system. Remote controlled valves must be installed within the vicinity of Milepost 0 and Milepost 1.2. ii) If communication is lost for over three (3) hours, NFG must have personnel onsite to continue operations and monitoring of the special permit segment. iii) NFG must document SCADA operating procedures and Control Room Management Procedures (49 CFR 192.631), within the O&M Procedures for the special permit segment. Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 14 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> 8) Construction and Operations a) Tools and Equipment: NFG must have tools and fittings available either by stocking such or from a local vendor such that it can respond within a reasonable time to operational maintenance and emergency repairs (the number and types must be detailed in the O&M Procedures): An inventory of tools and materials must be indicated in the O&M Procedures for maintenance and emergency repairs. ii) NFG must have available either by stocking such or from a local vendor appropriate tools and fittings to repair and replace appurtenances and piping within the special permit segment. iii) NFG must maintain a supply of FlexSteel pipe at NFG's project and/or operational maintenance yards for the special permit segment. iv) Construction Specifications: NFG must develop construction specifications for all construction phases of the special permit segment. These construction specifications must be made available to the Director, PHMSA Eastern Region, 30- days prior to beginning construction of the special permit segment pipeline. b) Inspection criteria: NFG must develop inspection criteria for construction procedures and document them within the O&M Procedures. The inspection criteria must meet the requirements of these special permit conditions and 49 CFR Part 192 (except as waived or modified herein). These inspection criteria must be made available to the Director, PHMSA Eastern Region, 30-days prior to beginning construction of the special permit segment pipeline. c) Repair criteria: NFG must develop pipe repair criteria and document them within the O&M Procedures. Repair criteria must be submitted to the Director, PHMSA Eastern Region, 30-days prior to beginning construction of the special permit segment pipeline. d) Hydrostatic test: Prior to NFG putting the pipe in service, the pipe, connections, and appurtenances must be field hydrostatically tested at a pressure of 1.5 times the MAOP of 720 psig (minimum test pressure of 1080 psig) for a minimum of 24 hours with recording charts (pressure chart, temperature chart, dead weights and log, and calibration records of equipment, calibrated within 30 days of test), the results of which must be made available to the Director, PHMSA Eastern Region for review, including determination parameters of Special Permit: PHMSA-2017-0090 - National Fuel Gas Supply Corporation Page 15 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> an acceptable test. NFG must compensate for temperature and elevation variations and such compensation must be documented on test records. e) Leakage detection surveys: NFG must conduct leakage detection surveys of the entire special permit segment four (4) times per calendar year at a minimum, not to exceed 4-½ months between surveys, utilizing instrumented leak detection equipment capable of parts per million (ppm) detection. NFG must repair all leaks as they are found, and notify the Director, PHMSA Eastern Region of any leaks found within two (2) business days. Leak testing procedures, equipment, and scheduling must be documented within the O&M Procedures. The first survey must be performed within 48 hours of commencement of pipeline operations with natural gas. f) As defined in Condition 1, any new construction outside the special permit segment must conform to 49 CFR 192.327 - Cover. • NFG must conform to the depth of cover requirements in 49 CFR 192.327 for any new construction outside of the special permit segment. ii) Based upon available depth of cover information, the pipe located at the northern end (the Class 2 section of line) of the special permit segment has depths of cover meeting 49 CFR 192.327, while the data available in the Class 1 section indicates varying depths, all of which may not meet 49 CFR 192.327 requirements depending on soil conditions (i.e. Class 1 locations in consolidated rock may be installed at a depth of cover of 18 inches per 49 CFR 192.327 as opposed to an installation depth of cover of 30 inches in normal soil). In addition, two known exposures of the existing line (one at a stream crossing at Milepost 4.45 and one upland exposure at the southern terminus of the project) exist. The pipe at these locations must be removed and the FlexSteel replacement pipe will be direct buried in these locations to a depth of cover meeting 49 CFR 192.327 requirements. All pipe locations with cover less than 24-inches must have additional preventive and " A primary objective of NFG's special permit request was to capitalize on the opportunity to perform the construction via installation was before Part 192 was developed, and there are locations that do not meet depth of cover requirements. Special Permit: PHMSA-2017-0090 — National Fuel Gas Supply Corporation Page 16 of 26 Special Permit Conditions for FM120 pipeline to use FlexSteel Pipe <<>> mitigative measures such as additional pipeline markers, lowering the pipe, adding cover, or installing subsurface concrete safety barriers.® iii) Due to the insertion method, periodic bell holes will be dug and sections of the existing pipeline will be removed to facilitate the installation process. In these areas, the FlexSteel coupler fittings will be direct buried, along with the adjacent FlexSteel pipe. To minimize environmental impacts, the bell holes will be kept to a minimum length that will allow for the safe installation of the FlexSteel pipe. The expected length of the bell holes is anticipated to be approximately 30 f - **truncated:** true - **body characters:** 60060