{"operation":"document","citation":"PHMSA-2017-0091","title":"Hilcorp Alaska, LLC — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2019-04-29","effective_on":"2019-04-29","summary":"PHMSA-2017-0091, issued 2019-04-29 for Hilcorp Alaska, LLC's hazardous liquid system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0091.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0091.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0091","source_url":"https://www.regulations.gov/docket/PHMSA-2017-0091","body":"PHMSA pipeline special permit PHMSA-2017-0091. Operator: Hilcorp Alaska, LLC. System: Hazardous Liquid. Issue date: 2019-04-29.\n\n<<<PAGE 1>>>\n\n0\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nAPR 292019\nMr. David S. Wilkins\nSenior Vice President\nHilcorp Alaska, LLC\n3800 Centerpoint Drive, Suite 1400\nAnchorage, AK 99503\nDocket No. PHMSA-2017-0091\nDear Mr. Wilkins:\nOn March 24, 2017, Hilcorp Alaska, LLC (HilcOrp) wrote to the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) requesting a special permit to waive compliance\nfrom the pipeline safety regulations in 49 Code of Federal Regulations (CFR) 195.563 and\n195.573 for the proposed Liberty Pipeline. The proposed Liberty Pipeline will be\napproximately 7.25 miles in length, and will be located in the Foggy Island Bay of the\nBeaufort Sea Outer Continental Shelf and State of Alaska waters. The Liberty Pipeline will\ncome ashore in Alaska and traverse approximately 1.5 miles above ground and tie into the\nexisting Badami Pipeline.\nThe regulations in 49 CFR 195.563 and 195.573 require hazardous liquid pipeline operators to\nmaintain cathodic protection currents on steel pipelines, and to monitor the level of cathodic\nprotection currents to prevent external corrosion or metal loss on pipelines. The Liberty Pipeline\nis planned to be a 12.75-inch diameter carrier pipe placed inside a 16-inch diameter casing pipe\n(pipe-in-pipe or PIP) for approximately 5.68 miles. Cathodic protection currents will be unable\nto reach and protect the 12.75-inch diameter carrier pipe from corrosion, and Hilcorp will be\nunable to monitor cathodic protection currents based on their planned design. The purpose of the\nLiberty Pipeline special permit with conditions, is to assure safety and environmental protection\nare maintained in lieu of compliance with these cathodic protection Federal regulations.\nPHMSA is granting this special permit (enclosed) which will allow Hilcorp to operate the\nLiberty Pipeline at a maximum operating pressure (MOP) of 1,480 pounds per square inch\ngauge (psig), and without monitoring cathodic protection currents, or the cathodic protection\ncurrents reaching the 12.75-inch carrier pipeline. This special permit provides relief from\nthe Federal pipeline safety regulations for a segment of the Liberty Pipeline, but requires\nHilcorp to comply with certain conditions and limitations designed to maintain pipeline\nsafety and to protect the environment.\n\n<<<PAGE 2>>>\n\nMy staff would be pleased to discuss this matter or any other regulatory matter with you.\nMr. John Gale, Director, Standards and Rulemaking Division may be contacted at\n202-366-0434, on regulatory matters, and Mr. Max Kieba, Acting Director, Engineering and\nResearch Division, may be contacted at 202-493-0595, on technical matters specific to this\nspecial permit grant.\nSincerely,\nLA4.Alan K. Mayberry\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit- PHMSA-2017-0091\nPHMSA-2017-0091- Hilcorp- Liberty Pipeline- Letter of Decision Page 2 of 2\n\n<<<PAGE 3>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSPECIAL PERMIT\nSpecial Permit Information:\nDocket Number:\nRequested By:\nOperator ID#:\nOriginal Date Requested:\nOriginal Issuance Date:\nEffective Dates:\nCode Sections:\nPHMSA-20 17-0091\nHilcorp Alaska, LLC\n32645\nMarch 24, 2017\nApril 29, 2019\nApril 29, 2019-April 29, 2029\n49 CFR 195.563 and 195.573\nGrant of Special Permit:\nBy this order, subject to the tenns and conditions set forth below, the United States Department of\nTransportation (DOT), Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of\nPipeline Safety (OPS),' grants this special permit to Hilcorp Alaska, LLC (Hilcorp),2 owner and\noperator ofthe proposed Liberty Sales Oil Pipeline (Liberty Pipeline). This special permit waives\ncompliance from various sections of 49 CFR Part 195. Specifically, the Liberty Pipeline special\npermit waives compliance with 49 CFR 195.563 and 195.573.\nThe Liberty Pipeline will originate on the Liberty Drilling and Production Island (LDPI), an artificial\nisland located in federal waters. The submerged pipeline will extend southwards for approximately\n5.68 miles through the Foggy Island Bay of the Beaufort Sea Outer Continental Shelf (OCS) and\nState of Alaska waters. The Liberty Pipeline will then come ashore, traverse approximately 1.5 miles\nabove ground, and tie into the existing Badami pipeline. The Liberty Pipeline consists of a 12.75-\n1 Throughout this special permit, the usage of\"PHMSA\" or \"PHIMSA UPS,' means the U.S. Department of\nTransportation's Pipeline and Hazardous Materials Safety Administration, Office ofPipeline Safety.\n2 Hilcorp Alaska, LLC is a wholly-owned, operating subsidiary of Hilcorp. The Liberty Project partners include Hilcorp\nAlaska, LLC, BP Exploration (Alaska) Inc., and ASRC Exploration, LLC.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 1 of 44\n\n<<<PAGE 4>>>\n\ninch diameter pipeline3 approximately 7.25 miles in length. The 7.25-mile route includes\napproximately 5.68 miles of submerged, buried pipe which will be located in offshore waters. The\nsubmerged portion of the Liberty Pipeline will utilize a pipe-in-pipe (PIP) design. The maximum\nwater depth along the route is 19 feet at the LPDI.\nThe Liberty Pipeline will transport crude oil. The 12.75-inch diameter carrier pipeline will be\ninstalled in 16-inch diameter casing pipe in the submerged offshore sections. The carrier pipeline and\ncasing pipe will be bundled together with a 4.5 -inch diameter utility pipeline and a fiber optic\ncommunication cable during construction prior to placement in the seafloor, see Figure 1- Pipeline\nBundle Cross Section, Page 36 of 44.\nPurpose and Need:\nHilcorp's request for a special permit is for its planned Liberty Pipeline, specifically, the submerged\nPIP segments, and proposes waiving compliance from the following corrosion control sections of the\nFederal Pipeline Safety Regulations:\n1) 49 CFR 195.563, Which pipelines must have cathodic protection? and\n2) 49 CFR 195.573, What must I do to monitor external corrosion control?\nThese Federal Pipeline Safety Regulations require hazardous liquid pipeline operators to have\ncathodic protection (CP) to prevent external corrosion and monitor the level of external corrosion\ncontrol to ensure adequate protection of the pipeline. While PIP4 design is intended to prevent the\ncreation of a corrosive environment, ifthere is a failure of either one ofthe pipes, a corrosive\nenvironment will occur and compliance with these federal corrosion regulations would not be\npossible. Furthermore, the PIP design and operating temperature differentials introduce atypical loads\nand strains to the pipeline, and presents pipeline condition assessment challenges that must be\naddressed to stay in full compliance. The purpose of the Liberty Pipeline special permit is to assure\nsafety and environmental protection in lieu of compliance with these Federal Pipeline Safety\nRegulations.\nThe 12.75-inch diameter pipeline may be referenced as \"carrier pipe\" or \"carrier pipeline\" throughout this document.\nThe PIP reference means the 12.75inch diameter carrier pipe installed within the annulus ofthe 16-inch diameter casing\npipe in the specialpermit segment.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 2 of 44\n\n<<<PAGE 5>>>\n\nThe special permit conditions are necessary to ensure the design, construction, and operation and\nmaintenance (O&M) activities of the Liberty Pipeline are consistent with pipeline safety, specifically\n49 CFR Part 195. The Liberty Pipeline will consist of a 12.75-inch diameter pipeline surrounded by\nan outer 16-inch diameter casing pipe. This PIP design creates a dry annulus that protects the carrier\n12.75-inch diameter pipeline from exposure to electrolytes, such as sea water, saturated thermal\ninsulation, or saturated soils. The special permit conditions apply to the design, construction, and\nO&M ofthe PIP system.\nSpecifically, the special permit conditions address the possible introduction of an electrolyte around\nthe carrier pipe, which could create an environment allowing corrosion to occur. Further, the special\npermit conditions provide a means for assessing the condition of the carrier pipe to ensure its integrity\nis maintained ifthe PIP system is compromised. Finally, the special permit conditions are necessary\nto allow Hilcorp to safely operate the specialpermit segment at a maximum operating pressure\n(MOP) of 1,480 pounds per square inch gauge (psig) and a maximum operating temperature of 150\ndegrees Fahrenheit (°F).\nI. Special Permit Segment:\nBeaufort Sea and North Slope Borouth, Alaska\nThe Liberty Pipeline starts at the LDPI (an artificial island) and travels across Foggy Island Bay of\nthe Beaufort Sea OCS, to the northern Alaskan coast line located west ofthe Kadleroshilik River\nDelta. The proposed Liberty Pipeline route and location can be reviewed on Figures 3 and 4 on\npages 37 and 38 of 44.\nThe Liberty Pipeline specialpermit segment includes the approximately 5.68 miles of 12.75-inch\ndiameter carrier pipeline installed within a 16-inch casing pipe, the two (2) casing to carrier pipe\n\"bulkhead\" connections located on each end of the PIP segment, the 16-inch diameter casing pipe,\nand the connecting 12.75-inch diameter carrier pipeline from the 16-inch diameter casing pipe to the\nin-line inspection (ILl) tool launcher and receiver from approximate Milepost (MP) 0.02 and MP\n7.25. The 16-inch diameter casing pipeline will create a sealed annular space between the casing\npipe and carrier pipe using welded \"bulkhead\" connections located on each end of the PIP segment.\nThe \"Liberty Pipeline\" refers to the entire approximately 7.25 miles of pipeline and supporting facilities that are\njurisdictional to 49 CFR Part 195\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 3 of 44\n\n<<<PAGE 6>>>\n\nThe special permit conditions require installation and operation of an ILl tool calibration spool,\nremote operated mainline valves located at MP 0.02 and MP 7.25, and ILl launchers and receivers.\nAt the shore, the pipeline will transition to a single-wall, aboveground pipeline supported on vertical\nsupport members (VSMs) and continue south to tie into the existing Badami Pipeline. Product\n(crude oil) will be transported from the Liberty Pipeline through the Badami and Endicott Pipelines\nto the Trans Alaska Pipeline System (TAPS).\nPHMSA grants this special permit based on the findings set forth in the \"Special Permit Analysis and\nFindings\" document, which can be read in its entirety in Docket No. PHMSA- 2017-0091 in the\nFederal Docket Management System (FDMS) located on the internet at www.regulations.gov. The\ndraft environmental assessment (DEA), which includes a plain-language explanation ofthe safety\nconditions, is included in the Docket at www.regulations.gov.\nII. Conditions:\nPHMSA grants this special permit for the specialpermit segment and the Liberty Pipeline6 subject to\nHilcorp implementing the following conditions:\nGeneral:\n1) Applicable Regulations: The specialpermit segment and the Liberty Pipeline must be designed,\nconstructed, operated and maintained in accordance with these special permit conditions and 49\nCFR Part 195, with the exceptions of 49 CFR 195.563 and 195.573. In the event of a conflict\nbetween these special permit conditions and the applicable requirements under 49 CFR Part 195,\nthe special permit conditions control.\n2) Maximum Operating- Pressure, Temperature, Strain and Stress Limits for the\nPipeline: Hilcorp must design, construct, and operate the specialpermit segment to meet\nthe maximum operating conditions in Table 1: Liberty Pipeline- 12.75-inch Diameter\nCarrier Pipe Design Properties. The Liberty Pipeline specialpermit segment carrier\npipeline MOP must not exceed 1,480 psig, including any surge pressures, and maximum\ntemperatures must not exceed 150 °F in operating procedures and actual operations.\n6 The special permit conditions are applicable to the O&M ofthe Liberty Pipeline that can affect the specialpermit\nsegment.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 4 of 44\n\n<<<PAGE 7>>>\n\nTable 1: Liberty Pipeline- 12.75-inch Diameter Carrier Pipe Design and Operating Properties\nDesign and Operating Parameters Value Unit\nFlow Rate, maximum 70,000 barrels of oil per day (BOPD)\nASME/ANSI Class Rating, minimum 600 n/a, rating is 1,480 psig\nMOP 1,480 psig\nMaximum/minimum Operating/Design Temperature -50 to 150 °F\nNormal Operating Pressure 0 to 1,000 psig\nNormal Operating Temperature 90 to 120 °F\nMaximum Allowable Combined Stress (Seq) 46,980 pounds per square inch (psi)\nNote: Liberty Pipeline specialpermit segment carrier pipe design must be based upon\nmaximum operating conditions.\nJustification for any change in design and operating parameters in Table 1 must be provided to\nthe PHMSA Western Region Director or Project Designee for review, and must receive a \"no\nobjection\" letter prior to implementation. If Hilcorp does not receive a \"no objection\" letter\nfrom PHMSA within 90 days of the notification, Hilcorp may proceed. PUMSA will notify\nHilcorp if additional review time is needed.\n3) Integrity Management Program: Hilcorp must incorporate the specialpermit segment into its\nwritten integrity management program (IMP) as a \"covered segment\" in a \"high consequence\narea (HCA)\" or \"could affect HCA\" in accordance with 49 CFR 195.452.\nDesign and Materials:\n4) Design, Specifications and Procedures: Uilcorp must develop and implement design,\nconstruction, and O&M specifications and procedures in accordance with these special permit\nconditions and 49 CFR Part 195 for the specialpermit segment. These specifications and\nprocedures must prevent stress7 and strain8 for the carrier pipe, carrier pipe girth welds, the\ncasing pipe, and casing girth welds from exceeding the defined operational limits under the\noperational conditions for the specialpermit segment as outlined in Condition 2- Maximum\nOperating- Pressure, Temperature, Strain and Stress Limits for the Pipeline.\nMaximum allowable combined stresses are defmed in Table 1.\n8 Strain is the longitudinal strain imposed on a pipeline by its surrounding environment (e.g., frost heave, thaw settlement,\nseismic, geologic fault areas, soil liquefaction areas, or soil movement areas). Strain is limited to the specific\nlongitudinal strain value that cannot be exceeded, which for this special permit is 0.5% strain.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 5 of 44\n\n<<<PAGE 8>>>\n\n5) Pipe- Carrier:9 The Liberty Pipeline specialpermit segment carrier pipe must be\nmanufactured per American Petroleum Institute Specification 5L (API 5L), Specification for\nLine Pipe,'° Grade X52 product specification level (PSL) 2, including supplementary\nrequirements for offshore pipelines in API 5L Annexes J and K. The Liberty Pipeline special\npermit segment carrier pipe must be constructed of 12.75-inch diameter, 0.500-inch wall\nthickness, grade X52 or greater overall strength (wall thickness and grade combined), carbon\nsteel pipeline.\n6) Carrier Pipe Toughness: Charpy V-Notch (CVN) impact testing must be conducted on the\ncarrier pipe in accordance with API 5L. Tests must be conducted on each carrier pipe steel heat\nand those test results must meet the following requirements:\na) CVN impact test temperature must be negative 50 °F, and\nb) Minimum energy levels on full-size specimens must be 50 foot-pounds (ft-lb) average and\n40 ft-lb minimum at negative 50 °F.\nNote: The pipe seam (weld centerline and heat affected zone) must be evaluated by C\\TN\nimpact tests if the pipe has a manufactured, longitudinal seam.\n7) Carrier Pipeline Design Factor: The Liberty Pipeline specialpermit segment design must\ncomply with 49 CFR 195.106, utilizing a design factor of 0.72 or more conservative for the\ncarrier pipeline. The specialpermit segment bulkhead fitting and tie-in piping (2 pipe joints of\neach side of bulkhead for the 12.75-inch diameter carrier pipe) must be designed for a hoop\nstress design factor of 0.60 and a combined stress load design factor of 0.72;\n8) Bends: The buried segments ofthe Liberty Pipeline specialpermit segment (carrier and casing)\nmust not include manufactured or hot bent pipe bends. The transition segments at each end of\nthe buried LSOP bundle (onshore transition segment and island transition segment) must\ngradually sweep to the surface. The directional changes of the pipeline must be designed to\nmaintain combined stress levels within ASME B31.4-2016\", section 403.3.1, Table 403.3.1-1\nThe Liberty Pipeline 12.75-inch diameter carrier pipe is used to transport crude oil and is subject to 49 CFR Part 195.\nThe casing pipe is the 16-inch or larger diameter pipe that will be used as a double barrier to keep crude oil from getting\ninto offshore waters ifthe carrier pipe leaks.\n10 Hilcorp must use the edition noted for this standard that is incorporated by reference in 49 CFR 195.3.\n1 Hilcorp may use the 2016 edition of ASME B3 1.4 as noted or may use the edition incorporated by reference in 49 CFR\n195.3.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 6 of 44\n\n<<<PAGE 9>>>\n\nallowable limits below 46,980 psi for API 5L X52 pipe12 (0.90 times the carrier pipeline\nminimum yield strength).\n9) Flanges and Fittings: All flanges and fittings must comply with American Society of\nMechanical Engineers (ASME)/American National Standards Institute (ANSI) B 16.5 and\nB l6.9,' respectively, for a ANSI Class 600 system and 1,480 psig or greater and must be\ndesigned based upon the maximum and minimum operating pressures and temperatures in\nCondition 2 and Table 1: Liberty Pipeline- 12.75-inch Diameter Carrier Pipe Design\nProperties.\n10) CP- Carrier and Casing Pipe: The PIP portions of the Liberty Pipeline specialpermit\nsegment will not have a CP system to protect the 12.75-inch diameter carrier pipe from\ncorrosion. Corrosion protection is provided by the dual layer fusion bonded epoxy (FBE)\ncoating and by maintaining a dry inert environment during construction and operations and the\nsealed 16-inch diameter casing (PIP seal) during operations.\na) The 16-inch diameter casing must have a CP system that meets the requirements for a\nburied or submerged pipeline in 49 CFR 195.563.\nb) The CP system for the 16-inch diameter casing must be installed with a distributed galvanic\nanode system consisting of aluminum anodes spaced throughout the offshore subsea buried\nsegment.\nc) The anodes must be connected to the 16-inch diameter casing and the weld area must be\ncoated.\nd) The 16-inch casing must be externally coated for corrosion protection. The 16-inch\ndiameter casing pipe must also be internally coated'4 with the exception of a short segment\n(less than 6-inches wide) at pipe girth welds.\ne) The 16-inch diameter casing must have equipment to monitor pressure and temperature of\nthe PIP annulus at all times, except during equipment maintenance activities which must be\ncompleted within one 12-hour shift and with the knowledge of Liberty Pipeline controllers.\n12 Carrier pipe must be manufactured in accordance with the incorporated by reference edition of API 5L specified in 49\nCFR 195.3.\n13 Hilcorp must use the editions noted for these standards that are incorporated by reference in 49 CFR 195.3.\n14 The internal coating for the 16-inch diameter casing pipe must be a coating that protects against atmospheric corrosion\nsuch as Vaispar- Pipeclad Flowliner 93 OR.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 7 of 44\n\n<<<PAGE 10>>>\n\n11) PIP Design: The PIP design must have specifications and procedures implemented for the\nfollowing:\na) Casing isolators must be clamped to the 12.75-inch diameter carrier pipe to isolate it from\nthe 16-inch diameter casing pipe. Spacing of the isolators must maintain separation\nbetween the 12.75-inch diameter carrier and 16-inch diameter casing pipe throughout the\nentire length of the PIP section.\nb) The PIP annulus'5 must be sealed at each end ofthe 16-inch diameter casing.\nc) The dew point'6 ofthe inert gas in the annulus must be sampled prior to commissioning of\nthe PIP system. The dew pointofthe inert gas must be maintained at negative 10°F or\nlower at all times.\nd) The annulus must be filled with an inert gas, such as nitrogen or argon.\ne) The PIP annulus must be connected to a vacuum system to maintain the annular back-\npressure. The annular space must be maintained below atmospheric pressure at negative 10\npsig or less at all times.\nf) The vacuum system must be connected to the 16-inch diameter casing pipe at the LDPI.\nThe vacuum system must include block valves, a pressure regulator, pressure relief valves,\na vacuum pump, sample ports, and associated piping. The vacuum system must be\noperational at all times, except during maintenance activities which must be conducted\nduring one 12-hour shift and with the knowledge of Liberty Pipeline controllers.\ng) The annulus must be monitored for pressure and temperature changes that would indicate\nchanges in the gas composition in the annulus.\nh) Pressure transmitters to monitor pressures of fluids or gases in the annulus must be placed\nat each end of the PIP annulus system above ground at LDPI (MP 0.02) and above ground\nat the Alaska shoreline (MP 5.7)\n15 \"PIP annulus,\" \"annulus,\" or \"annular space\" refers to the space between the carrier pipe and the casing pipe.\n16 Typically, for corrosion to occur, it requires an electrolyte (such as water) and air to be present. The inert gas in the\nannulus significantly reduces the potential for external corrosion on the NPS 12 LSOP by removing the oxygen from the\nsurface ofthe carrier pipe. The inert gas will also be unsaturated, or dry, with a dew point sufficient to keep any water\nfrom dropping out of the gas for all operating temperatures ofthe PIP system. Corrosion generally is inhibited when the\nrelative humidity is maintained below 30%. To account for potential presence of hygroscopic dirt, a minimum relative\nhumidity of 20% is recommended for this application. The PIP system will be installed in a subsea trench where the\nlowest ambient conditions are above 25 °F. The effective dew point at 20% relative humidity and 25°F is -7 °F.\nTherefore, a -10 °F dew point should be sufficient to prevent liquid drop out as low as 25 °F.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 8 of 44\n\n<<<PAGE 11>>>\n\ni) Temperature transmitters to monitor temperature of the annular space must be placed at each\nend of the PIP annulus system, one (1) above ground at LDPI and one (1) adjacent to the\nonshore PIP transition.\n12) PIP Bulkhead Design: Hilcorp plans to rigidly connect the 16-inch diameter casing pipe and\nthe 12.75-inch carrier pipeline by means of a forged bulkhead, similar to what is presented in\nFigure 2 on page 36 of 44¯17 The bulkheads must be placed above grade where the alignment\ntransitions from buried to aboveground installation. Installation of the bulkheads must create a\nsealed annulus between the 12.75 -inch diameter carrier pipeline and the 16-inch diameter casing\npipe.\na) The PIP bulkhead design must meet both 49 CFR 195.106, Internal Design Pressure, and\nASME B3 1.4 -2016, Table A402.3.5-1, Design Factorsfor Offshore Pipeline Systems. The\nbulkhead design and connecting piping must be treated as piping on an offshore platform\nfor determining hoop, circumferential, and combined stresses.\nb) The PIP bulkhead must be hydrostatically tested by the manufacturer in accordance with\nthe Design Proof-Test requirements of the Manufacturers Standardization Society ofthe\nValve and Fittings Industry, Inc., MSS SP-75-2014 High-Strength, Wrought, Butt-Welding\nFittings or ASME B 16.9-2012 Factory-Made Wrought Butt-welding Fittings, in accordance\nwith 49 CFR 195.118.18 The PIP bulkhead must be pressure tested with the pipeline after\nonsite iiistallation in accordance with 49 CFR 195.304 and 195.306.\nc) d) The PIP bulkhead fitting must be designed for:\ni) Loads: thermal force, pressure force, cap force, and friction force;\nii) Design Safety Factor for all Combined Stress loads must not exceed: 0.72;\niii) Design Factor for Hoop Stress must not exceed: 0.6; and\niv) Minimum Factory Test Pressure: 5,700 psig for continuous 4-hours minimum.\nPIP bulkhead and pipeline loads must be analyzed using Finite Element Analysis (FEA) for\nthe carrier pipeline, casing and bulkhead operating conditions, and design safety factors\n17 Hilcorp may use another method of sealing the PIPdesign instead ofthe bulkhead outlined in Figure 2, but any design\nmust meet 49 CFR Part 195 and these specialpermit conditions. Hilcorp must give PHMSA Western Region Director\nor Project Designee notice of any changes to the sealing method for the PIP design and must get a \"no objection\" letter\nfrom PHIvISA ofthe sealing method. If Hilcorp does not receive a \"no objection\" letter from PHIvISA within 90 days of\nthe notification, Hilcorp may proceed. PHMSA will notify Hilcorp if additional review time is needed.\n18 Hilcorp may use the editions noted for these standards (2014 and 2012) or may use the edition incorporated by reference\nin49CFR 195.3.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 9 0144\n\n<<<PAGE 12>>>\n\nover the life span ofthe Liberty Pipeline specialpermit segment. The FEA must meet the\ndesign factors listed in Condition 12(c).\n13) Bundle and Fiber Optic Cable: The offshore subsea buried specialpermit segment will be\ninstalled as a bundle. The bundle will consist of the PIP system, utility line, fiber optic cable,\nspacers and bundle straps. See Figure 1 on page 36 of 44 for a conceptual cross section of the\nLiberty Pipeline bundle. Note: The fiber. optic cable will be located outside ofthe PIP system.\nThe fiber optic cable is not within the 16-inch diameter casing.\na) The fiber optic cable must be installed with accurate distributed temperature sensing (DTS)\ncapability to allow for the immediate identification of any areas experiencing changes in\nsoil temperature. The fiber optic cable must be operational at the time the Liberty pipeline\nis placed into crude oil service.\nb) The fiber optic cable must be installed with DTS instrumentation, capable of detecting and\nlocating temperature anomalies within five (5) feet.19\nc) The DTS system must be able to sense all temperatures within the pipeline design capacity\nd) The temperature profile ofthe bundle must be transmitted to the supervisory control and\ndata acquisition (SCADA) system for continuous monitoring and recording.\ne) The 4.5-inch utility line shown in Figure 1 is not part ofthe special permit or the special\npermit conditions. The 4-inch utility must comply with current Federal Pipeline Safety\nRegulations, and Hilcorp must notify PHMSA in accordance with 49 CFR 191.22(c) prior\nto placing it into 49 CFR Parts 192 or 195 service.\nf) The depth of cover for the bundle must be a minimum of seven (7) feet below the subsea\nmudline for the offshore subsea buried segment of the Liberty Pipeline specialpermit\nsegment bundle; with the exception to the two (2) transition segments where the buried\npiping transitions to the surface.\n14) Pipe- External Coating: Carrier and casing pipe must have an external coating system that\nconsists of an external dual layer of Fusion Bonded Epoxy (FBE) coating. The dual layer FBE\n19 Ifthe fiber optics cable should fail during the 12.75-inch diameter pipeline operational life, Hilcorp must develop and\nimplement alternative operational procedures that maintain a similar level of safety and environmental protection.\nHilcorp must submit these procedures and an implementation schedule to PHMSA Western Region Director or Project\nDesignee and receive a response of \"no objection\" prior to implementation. If Hilcorp does not receive a \"no Objection\"\nletter from PHMSA within 90 days ofthe notification, Hilcorp may proceed. PHMSA will notiQj Hilcorp if additional\nreview time is needed.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 10 of 44\n\n<<<PAGE 13>>>\n\nconsists of one (1) layer of standard FBE covered with a minimum of one (1) layer of an\nabrasion resistant overlay (ARO) to protect the primary FBE layer. The external pipe coating\nsystem must be applied to the Liberty Pipeline specialpermit segment in accordance with a\ncoating. application specification that addresses:\na) pipe surface cleanliness standards,\nb) blast cleaning,\nc) application temperature control,\nd) adhesion for coating to pipe,\ne) cathodic disbondment,\nf) moisture penneation,\ng) bending,\nh) minimum coating thickness,\ni) coating imperfection, and\nj) coating repair.\n15) Monitoring System: The Liberty Pipeline specialpermit segment carrier pipe must be\nmonitored for operating pressure, temperature, and flow rate, including the following\nrequirements:\na) Pressure transmitters must be placed at each end of the Liberty Pipeline, one (1) at LDPI\nand one (1) at the pipeline tie-in at the Badami Pipeline.\nb) Flow meters must be placed at each end ofthe Liberty Pipeline, one (1) at LDPI and one (1)\nat the pipeline tie-in at the Badami Pipeline.\nc) Temperature transmitters must be placed at each end ofthe Liberty Pipeline, one (1) at\nLDPI and one (1) at the pipeline tie-in at the onshore Badami Pipeline.\nd) Valves at LDPI and at the pipeline tie-in at the Badami Pipeline must be remote closure and\nhave pressure monitoring on both sides of the valves. The actuation of the valves may not\nresult in an overpressure event of the carrier pipeline, and closure rates must be\nsubstantiated by a hydraulic surge analysis. The remote closure valve status and adjacent\npipeline pressures must be monitored at all times, except during scheduled equipment\nmaintenance activities, which must be completed within a 12-hour shift and with the\nknowledge of Liberty pipeline controllers.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 11 of 44\n\n<<<PAGE 14>>>\n\n16) Casing Pipe- Design and Operating Properties: The 16-inch diameter casing design\nproperties must be as shown in Table 2 below.20\nTable 2: Liberty Pipeline- 16-inch Diameter Casing Design and Operating Properties\nDesign and Operating Parameter Value Unit\nMinimum Design Pressure 1,480 psig\nDesignlOperating Temperature Range -50 to 150 °F\nNormal Operating Pressure -20 to 50 psig\nNormal Operating Temperature 60 to 90 °F\nMaximum Allowable Combined Stress (Seq) 46,980 psi\nRelief Valve- Annulus 25 to 50 psig\na) The casing pipe must be a minimum of 16-inch diameter, 0.625-inch wall thickness, carbon\nsteel pipeline manufactured per API Specification 5L, Specificationfor Line Pipe,2' Grade\nX52, PSL 2, including supplementary requirements for offshore pipelines (API 5L Annexes J\nand K). The casing pipe may be of a larger diameter, thicker wall thickness, or higher\nstrength (grade) to maintain equivalent strength (a minimum design pressure of 1,480 psig).\nb) Charpy V-Notch (CVN) impact testing must be conducted on the casing pipe in accordance\nwith API Specification 5L Annex G, with the following modifications:\ni) CVN impact test temperature must be negative 50 °F; and\nii) Minimum energy levels on full-size specimens must be 50 ft-lb average and 40 ft-lb\nminimum.\nc) The 16-inch diameter casing must be coated with an external coating system. The coating\nsystem must be installed in accordance with Condition 17(b).\nd) The casing pipe overpressure relief valve data and/or annulus pressure data must be\ntransmitted to the SCADA system to ensure timely pipeline shutdown should the annulus\npressure exceed the established pressure thresholds in Table 2.\nConstruction:\n20 Justification for any change in the design and operating parameters in Table 2 must be provided to the Western Region\nDirector or Project Designee for review, and must receive a \"no objection\" letter prior to implementation. IfHilcorp\ndoes not receive a \"no objection\" letter from PHMSA within 90 days ofthe notification, Hilcorp may proceed.\nPHMSA will notifi Hilcorp if additional review time is needed.\n21 Hilcorp must use the API 5L edition incorporated by reference in 49 CFR 195.3.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 12 of 44\n\n<<<PAGE 15>>>\n\n17) Construction Quality Control: Hilcorp must develop and implement a right-of-way (ROW)\nconstruction monitoring program and a pipeline construction quality control program for the\nLiberty Pipeline specialpermit segment, as specified below:\na) ROW Construction Monitoring Program: A ROW construction monitoring program\nmust include procedures, personnel training, and be implemented for all construction\nphases of construction. The ROW construction monitoring program must include\nprocedures for:\ni) Operator Qualification (00) Procedures: OQ Procedures must be developed and\nimplemented for construction tasks that can affect pipeline integrity in compliance\nwith 49 CFR 195.501.\nii) Construction Quality Assurance Plan and Procedures: Hilcorp must develop a\nConstruction Quality Assurance Plan and corresponding Procedures that establish the\nproject quality objectives and personnel accountabilities to construct the pipeline\nsystem as designed. The Construction Quality Assurance Plan and Procedures, at a\nminimum, must include procedures, specifications, and personnel training for:\n1) pipe inspection,\n2) hauling and stringing pipe,\n3) welding,\n4) non-destructive examination of girth welds,\n5) applying and testing field applied coating,\n6) lowering the pipeline into the subsea trench,\n7) backfilling, and\n8) hydrostatic testing including dewatering and drying.\niii) Subsea Trench Quality Plan and Procedure: Hilcorp must develop a Subsea\nTrench Quality Plan that provides quality objectives to ensure the pipeline system is\nplaced in the subsea trench as designed. At a minimum, the Subsea Trench Quality\nPlan and Procedure must include quality assurance/control for:\n1) periodic collection of samples oftrench spoils to test for chemical and\nelectrical properties related to pipe corrosion,\n2) trench depth monitoring,\n3) trench bottom roughness profiling, and\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 13 of 44\n\n<<<PAGE 16>>>\n\n4) backfihling requirements.\nb) Carrier and Casing Pipe Construction Quality Control Programs:\ni) Coatings for Carrier and Casing Pipe: A coating application quality control\nspecification must be developed, implemented, and personnel must be trained to\nensure carrier and casing pipe surface cleanliness, application temperature control,\nadhesion quality, cathodic disbondment, moisture permeation, bending, and minimum\ncoating thickness for girth weld and repair coatings. Both the carrier and casing pipe\nmust be externally coated for corrosion protection.\nii) Non-Shielding Coatings: Pipe, girth weld, and repair coatings must be non-shielding\nto CP. Shielding coatings such as tape or shrink sleeves must not be used.\niii) Pipe Protection: Pipe end protection caps must be installed on the pipe joint weld\nbevels during the storage, handling, transport, and staging for all ofthe pipe included\nin the pipeline bundle to reduce the introduction of foreign materials including snow,\nice, and water.\n18) Carrier Pipeline Girth Welds: All girth welding procedures for the 12.75-inch carrier pipe must\nbe in accordance with 49 CFR 195.2 14 that incorporates by reference, API Standard 1104.22\na) All pipeline girth welds must be non-destructively tested to meet 49 CFR 195.228, 195.230,\nand 195.234.\nb) All pipeline girth welds with any type crack must be cut-out prior to placing the carrier into\nservice with crude oil.\nc) The 12.75-inch carrier pipe and coating must be protected from any weld splatter or other\ndamage during welding of the 16-inch casing pipe.\n19) Casing Pipe Girth Welds: All casing pipe girth welding procedures must be in accordance\nwith 49 CFR 195.214 and API Standard 1104.23\na) All casing pipe girth welds must be non-destructively tested to meet 49 CFR 195.228,\n195.230 and 195.234.\n22 Hilcorp must use the API 1104 edition incorporated by reference in 49 CFR 195.3.\n23 Hilcorp must use the API 1104 edition incorporated by reference in 49 CFR 195.3.\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 14 of 44\n\n<<<PAGE 17>>>\n\nb) All casing pipe girth welds with any type crack must be cut-out prior to placing the 12.75-\ninch diameter carrier pipe into operational service with crude oil.\n20) Casing Isolators: The Liberty Pipeline specialpermit segment must be supported by casing\nisolators at regular intervals throughout the PIP portion of the specialpermit segment. A\nmaximum casing isolator spacing interval of 10-feet or less must be used to minimize lateral\ndeflection between isolators, prevent contact between the casing and carrier pipes, provide\nstructural integrity ofthe PIP design during unexpected ground movement or creation of\nunsupported spans caused by localized seafloor scour, and to accommodate cyclic, thermally\ninduced movement of the carrier pipe relative to the casing. The casing isolator spacing should\nfacilitate installation of the carrier pipe within the casing. The casing isolators must consist of\ntwo high-density polyethylene half-shells with a continuous temperature rating of 225°F or\ngreater so that the isolators will not lose structural integrity or degrade under loading or\ntemperature conditions for the life of the pipeline.\n21)Relief Storage Tank: The PIP annulus of the Liberty Pipeline specialpermit segment must be\nconfigured so that any excessive pressure (as monitored under Condition 11) resulting from\neither crude oil or seawater entering the annulus can be discharged from an annulus relief valve\n(see Table 2 for relief set pressure ranges) to either a \"breakout tank, a portable tank, drum and\nflare system, or other pipeline\" (relief storage tank) that operates at a pressure that is not higher\nthan the 16-inch diameter casing maximum annulus relief valve pressure setting in Table 2.\nThe relief storage tank must facilitate the removal of liquids from the annulus in an event the\nannulus relief valve discharges. The relief storage tank capacity must be based upon the time to\nshut-down and isolate the carrier pipeline and maximum flow volumes (see Condition 16(d).\nO&M:\n22) O&M Procedures: In addition to the O&M procedures otherwise required by 49 CFR Part\n195, Hilcorp must develop and implement O&M procedures for the specialpermit segment and\nthe Liberty Pipeline, including the following:\n¯ CP monitoring system on the 16-inch diameter casing pipe,\n¯ PIP annulus monitoring,\n¯ SCADA System for the Liberty Pipeline and PIP System,\n¯ Integrity Management Plan for the 12.75-inch diameter pipeline and 16-inch diameter\ncasing, and\nPHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 15 of 44\n\n<<<PAGE 18>>>\n\na) b) c) . Data Integration Plan and Procedures to monitor and remediate any corrosion or\nexcessive strains on the 12.75-inch diameter pipeline or 16-inch diameter casing pipe.\nO&M procedures for the specialpermit segment and the Liberty Pipeline must technically\nassess all operating parameters that have an effect on the implementation of, or compliance\nwith, all ofthese specialpermit conditions; including, but not limited to:\ni) maximum and minimum pressures,\nii) pipe corrosion,\niii) oil and environmental (soil) temperatures, and\niv) maximum and minimum operating temperatures ofthe carrier pipe and casing pipe.\nProcedures for the carrier pipeline in the specialpermit segment must be developed and\nimplemented to ensure the following conditions are evaluated:\ni) the effects of corrosion anomalies (defects),\nii) the effects of mechanical damage (such as dents and gouges),\niii) the effects of cracking on the stress and strain capacity of the pipe, casing, and girth\nwelds,\niv) the effect oftensile and compressive strainlstress capacity on anomalies in asse","truncated":true,"body_characters":268892}