# Hilcorp Alaska, LLC — Pipeline Special Permit - **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. <<>> 0 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 APR 292019 Mr. David S. Wilkins Senior Vice President Hilcorp Alaska, LLC 3800 Centerpoint Drive, Suite 1400 Anchorage, AK 99503 Docket No. PHMSA-2017-0091 Dear Mr. Wilkins: On March 24, 2017, Hilcorp Alaska, LLC (HilcOrp) wrote to the Pipeline and Hazardous Materials Safety Administration (PHMSA) requesting a special permit to waive compliance from the pipeline safety regulations in 49 Code of Federal Regulations (CFR) 195.563 and 195.573 for the proposed Liberty Pipeline. The proposed Liberty Pipeline will be approximately 7.25 miles in length, and will be located in the Foggy Island Bay of the Beaufort Sea Outer Continental Shelf and State of Alaska waters. The Liberty Pipeline will come ashore in Alaska and traverse approximately 1.5 miles above ground and tie into the existing Badami Pipeline. The regulations in 49 CFR 195.563 and 195.573 require hazardous liquid pipeline operators to maintain cathodic protection currents on steel pipelines, and to monitor the level of cathodic protection currents to prevent external corrosion or metal loss on pipelines. The Liberty Pipeline is planned to be a 12.75-inch diameter carrier pipe placed inside a 16-inch diameter casing pipe (pipe-in-pipe or PIP) for approximately 5.68 miles. Cathodic protection currents will be unable to reach and protect the 12.75-inch diameter carrier pipe from corrosion, and Hilcorp will be unable to monitor cathodic protection currents based on their planned design. The purpose of the Liberty Pipeline special permit with conditions, is to assure safety and environmental protection are maintained in lieu of compliance with these cathodic protection Federal regulations. PHMSA is granting this special permit (enclosed) which will allow Hilcorp to operate the Liberty Pipeline at a maximum operating pressure (MOP) of 1,480 pounds per square inch gauge (psig), and without monitoring cathodic protection currents, or the cathodic protection currents reaching the 12.75-inch carrier pipeline. This special permit provides relief from the Federal pipeline safety regulations for a segment of the Liberty Pipeline, but requires Hilcorp to comply with certain conditions and limitations designed to maintain pipeline safety and to protect the environment. <<>> My staff would be pleased to discuss this matter or any other regulatory matter with you. Mr. John Gale, Director, Standards and Rulemaking Division may be contacted at 202-366-0434, on regulatory matters, and Mr. Max Kieba, Acting Director, Engineering and Research Division, may be contacted at 202-493-0595, on technical matters specific to this special permit grant. Sincerely, LA4.Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure: Special Permit- PHMSA-2017-0091 PHMSA-2017-0091- Hilcorp- Liberty Pipeline- Letter of Decision Page 2 of 2 <<>> U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT Special Permit Information: Docket Number: Requested By: Operator ID#: Original Date Requested: Original Issuance Date: Effective Dates: Code Sections: PHMSA-20 17-0091 Hilcorp Alaska, LLC 32645 March 24, 2017 April 29, 2019 April 29, 2019-April 29, 2029 49 CFR 195.563 and 195.573 Grant of Special Permit: By this order, subject to the tenns and conditions set forth below, the United States Department of Transportation (DOT), Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),' grants this special permit to Hilcorp Alaska, LLC (Hilcorp),2 owner and operator ofthe proposed Liberty Sales Oil Pipeline (Liberty Pipeline). This special permit waives compliance from various sections of 49 CFR Part 195. Specifically, the Liberty Pipeline special permit waives compliance with 49 CFR 195.563 and 195.573. The Liberty Pipeline will originate on the Liberty Drilling and Production Island (LDPI), an artificial island located in federal waters. The submerged pipeline will extend southwards for approximately 5.68 miles through the Foggy Island Bay of the Beaufort Sea Outer Continental Shelf (OCS) and State of Alaska waters. The Liberty Pipeline will then come ashore, traverse approximately 1.5 miles above ground, and tie into the existing Badami pipeline. The Liberty Pipeline consists of a 12.75- 1 Throughout this special permit, the usage of"PHMSA" or "PHIMSA UPS,' means the U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration, Office ofPipeline Safety. 2 Hilcorp Alaska, LLC is a wholly-owned, operating subsidiary of Hilcorp. The Liberty Project partners include Hilcorp Alaska, LLC, BP Exploration (Alaska) Inc., and ASRC Exploration, LLC. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 1 of 44 <<>> inch diameter pipeline3 approximately 7.25 miles in length. The 7.25-mile route includes approximately 5.68 miles of submerged, buried pipe which will be located in offshore waters. The submerged portion of the Liberty Pipeline will utilize a pipe-in-pipe (PIP) design. The maximum water depth along the route is 19 feet at the LPDI. The Liberty Pipeline will transport crude oil. The 12.75-inch diameter carrier pipeline will be installed in 16-inch diameter casing pipe in the submerged offshore sections. The carrier pipeline and casing pipe will be bundled together with a 4.5 -inch diameter utility pipeline and a fiber optic communication cable during construction prior to placement in the seafloor, see Figure 1- Pipeline Bundle Cross Section, Page 36 of 44. Purpose and Need: Hilcorp's request for a special permit is for its planned Liberty Pipeline, specifically, the submerged PIP segments, and proposes waiving compliance from the following corrosion control sections of the Federal Pipeline Safety Regulations: 1) 49 CFR 195.563, Which pipelines must have cathodic protection? and 2) 49 CFR 195.573, What must I do to monitor external corrosion control? These Federal Pipeline Safety Regulations require hazardous liquid pipeline operators to have cathodic protection (CP) to prevent external corrosion and monitor the level of external corrosion control to ensure adequate protection of the pipeline. While PIP4 design is intended to prevent the creation of a corrosive environment, ifthere is a failure of either one ofthe pipes, a corrosive environment will occur and compliance with these federal corrosion regulations would not be possible. Furthermore, the PIP design and operating temperature differentials introduce atypical loads and strains to the pipeline, and presents pipeline condition assessment challenges that must be addressed to stay in full compliance. The purpose of the Liberty Pipeline special permit is to assure safety and environmental protection in lieu of compliance with these Federal Pipeline Safety Regulations. The 12.75-inch diameter pipeline may be referenced as "carrier pipe" or "carrier pipeline" throughout this document. The PIP reference means the 12.75inch diameter carrier pipe installed within the annulus ofthe 16-inch diameter casing pipe in the specialpermit segment. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 2 of 44 <<>> The special permit conditions are necessary to ensure the design, construction, and operation and maintenance (O&M) activities of the Liberty Pipeline are consistent with pipeline safety, specifically 49 CFR Part 195. The Liberty Pipeline will consist of a 12.75-inch diameter pipeline surrounded by an outer 16-inch diameter casing pipe. This PIP design creates a dry annulus that protects the carrier 12.75-inch diameter pipeline from exposure to electrolytes, such as sea water, saturated thermal insulation, or saturated soils. The special permit conditions apply to the design, construction, and O&M ofthe PIP system. Specifically, the special permit conditions address the possible introduction of an electrolyte around the carrier pipe, which could create an environment allowing corrosion to occur. Further, the special permit conditions provide a means for assessing the condition of the carrier pipe to ensure its integrity is maintained ifthe PIP system is compromised. Finally, the special permit conditions are necessary to allow Hilcorp to safely operate the specialpermit segment at a maximum operating pressure (MOP) of 1,480 pounds per square inch gauge (psig) and a maximum operating temperature of 150 degrees Fahrenheit (°F). I. Special Permit Segment: Beaufort Sea and North Slope Borouth, Alaska The Liberty Pipeline starts at the LDPI (an artificial island) and travels across Foggy Island Bay of the Beaufort Sea OCS, to the northern Alaskan coast line located west ofthe Kadleroshilik River Delta. The proposed Liberty Pipeline route and location can be reviewed on Figures 3 and 4 on pages 37 and 38 of 44. The Liberty Pipeline specialpermit segment includes the approximately 5.68 miles of 12.75-inch diameter carrier pipeline installed within a 16-inch casing pipe, the two (2) casing to carrier pipe "bulkhead" connections located on each end of the PIP segment, the 16-inch diameter casing pipe, and the connecting 12.75-inch diameter carrier pipeline from the 16-inch diameter casing pipe to the in-line inspection (ILl) tool launcher and receiver from approximate Milepost (MP) 0.02 and MP 7.25. The 16-inch diameter casing pipeline will create a sealed annular space between the casing pipe and carrier pipe using welded "bulkhead" connections located on each end of the PIP segment. The "Liberty Pipeline" refers to the entire approximately 7.25 miles of pipeline and supporting facilities that are jurisdictional to 49 CFR Part 195 PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 3 of 44 <<>> The special permit conditions require installation and operation of an ILl tool calibration spool, remote operated mainline valves located at MP 0.02 and MP 7.25, and ILl launchers and receivers. At the shore, the pipeline will transition to a single-wall, aboveground pipeline supported on vertical support members (VSMs) and continue south to tie into the existing Badami Pipeline. Product (crude oil) will be transported from the Liberty Pipeline through the Badami and Endicott Pipelines to the Trans Alaska Pipeline System (TAPS). PHMSA grants this special permit based on the findings set forth in the "Special Permit Analysis and Findings" document, which can be read in its entirety in Docket No. PHMSA- 2017-0091 in the Federal Docket Management System (FDMS) located on the internet at www.regulations.gov. The draft environmental assessment (DEA), which includes a plain-language explanation ofthe safety conditions, is included in the Docket at www.regulations.gov. II. Conditions: PHMSA grants this special permit for the specialpermit segment and the Liberty Pipeline6 subject to Hilcorp implementing the following conditions: General: 1) Applicable Regulations: The specialpermit segment and the Liberty Pipeline must be designed, constructed, operated and maintained in accordance with these special permit conditions and 49 CFR Part 195, with the exceptions of 49 CFR 195.563 and 195.573. In the event of a conflict between these special permit conditions and the applicable requirements under 49 CFR Part 195, the special permit conditions control. 2) Maximum Operating- Pressure, Temperature, Strain and Stress Limits for the Pipeline: Hilcorp must design, construct, and operate the specialpermit segment to meet the maximum operating conditions in Table 1: Liberty Pipeline- 12.75-inch Diameter Carrier Pipe Design Properties. The Liberty Pipeline specialpermit segment carrier pipeline MOP must not exceed 1,480 psig, including any surge pressures, and maximum temperatures must not exceed 150 °F in operating procedures and actual operations. 6 The special permit conditions are applicable to the O&M ofthe Liberty Pipeline that can affect the specialpermit segment. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 4 of 44 <<>> Table 1: Liberty Pipeline- 12.75-inch Diameter Carrier Pipe Design and Operating Properties Design and Operating Parameters Value Unit Flow Rate, maximum 70,000 barrels of oil per day (BOPD) ASME/ANSI Class Rating, minimum 600 n/a, rating is 1,480 psig MOP 1,480 psig Maximum/minimum Operating/Design Temperature -50 to 150 °F Normal Operating Pressure 0 to 1,000 psig Normal Operating Temperature 90 to 120 °F Maximum Allowable Combined Stress (Seq) 46,980 pounds per square inch (psi) Note: Liberty Pipeline specialpermit segment carrier pipe design must be based upon maximum operating conditions. Justification for any change in design and operating parameters in Table 1 must be provided to the PHMSA Western Region Director or Project Designee for review, and must receive a "no objection" letter prior to implementation. If Hilcorp does not receive a "no objection" letter from PHMSA within 90 days of the notification, Hilcorp may proceed. PUMSA will notify Hilcorp if additional review time is needed. 3) Integrity Management Program: Hilcorp must incorporate the specialpermit segment into its written integrity management program (IMP) as a "covered segment" in a "high consequence area (HCA)" or "could affect HCA" in accordance with 49 CFR 195.452. Design and Materials: 4) Design, Specifications and Procedures: Uilcorp must develop and implement design, construction, and O&M specifications and procedures in accordance with these special permit conditions and 49 CFR Part 195 for the specialpermit segment. These specifications and procedures must prevent stress7 and strain8 for the carrier pipe, carrier pipe girth welds, the casing pipe, and casing girth welds from exceeding the defined operational limits under the operational conditions for the specialpermit segment as outlined in Condition 2- Maximum Operating- Pressure, Temperature, Strain and Stress Limits for the Pipeline. Maximum allowable combined stresses are defmed in Table 1. 8 Strain is the longitudinal strain imposed on a pipeline by its surrounding environment (e.g., frost heave, thaw settlement, seismic, geologic fault areas, soil liquefaction areas, or soil movement areas). Strain is limited to the specific longitudinal strain value that cannot be exceeded, which for this special permit is 0.5% strain. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 5 of 44 <<>> 5) Pipe- Carrier:9 The Liberty Pipeline specialpermit segment carrier pipe must be manufactured per American Petroleum Institute Specification 5L (API 5L), Specification for Line Pipe,'° Grade X52 product specification level (PSL) 2, including supplementary requirements for offshore pipelines in API 5L Annexes J and K. The Liberty Pipeline special permit segment carrier pipe must be constructed of 12.75-inch diameter, 0.500-inch wall thickness, grade X52 or greater overall strength (wall thickness and grade combined), carbon steel pipeline. 6) Carrier Pipe Toughness: Charpy V-Notch (CVN) impact testing must be conducted on the carrier pipe in accordance with API 5L. Tests must be conducted on each carrier pipe steel heat and those test results must meet the following requirements: a) CVN impact test temperature must be negative 50 °F, and b) Minimum energy levels on full-size specimens must be 50 foot-pounds (ft-lb) average and 40 ft-lb minimum at negative 50 °F. Note: The pipe seam (weld centerline and heat affected zone) must be evaluated by C\TN impact tests if the pipe has a manufactured, longitudinal seam. 7) Carrier Pipeline Design Factor: The Liberty Pipeline specialpermit segment design must comply with 49 CFR 195.106, utilizing a design factor of 0.72 or more conservative for the carrier pipeline. The specialpermit segment bulkhead fitting and tie-in piping (2 pipe joints of each side of bulkhead for the 12.75-inch diameter carrier pipe) must be designed for a hoop stress design factor of 0.60 and a combined stress load design factor of 0.72; 8) Bends: The buried segments ofthe Liberty Pipeline specialpermit segment (carrier and casing) must not include manufactured or hot bent pipe bends. The transition segments at each end of the buried LSOP bundle (onshore transition segment and island transition segment) must gradually sweep to the surface. The directional changes of the pipeline must be designed to maintain combined stress levels within ASME B31.4-2016", section 403.3.1, Table 403.3.1-1 The Liberty Pipeline 12.75-inch diameter carrier pipe is used to transport crude oil and is subject to 49 CFR Part 195. The casing pipe is the 16-inch or larger diameter pipe that will be used as a double barrier to keep crude oil from getting into offshore waters ifthe carrier pipe leaks. 10 Hilcorp must use the edition noted for this standard that is incorporated by reference in 49 CFR 195.3. 1 Hilcorp may use the 2016 edition of ASME B3 1.4 as noted or may use the edition incorporated by reference in 49 CFR 195.3. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 6 of 44 <<>> allowable limits below 46,980 psi for API 5L X52 pipe12 (0.90 times the carrier pipeline minimum yield strength). 9) Flanges and Fittings: All flanges and fittings must comply with American Society of Mechanical Engineers (ASME)/American National Standards Institute (ANSI) B 16.5 and B l6.9,' respectively, for a ANSI Class 600 system and 1,480 psig or greater and must be designed based upon the maximum and minimum operating pressures and temperatures in Condition 2 and Table 1: Liberty Pipeline- 12.75-inch Diameter Carrier Pipe Design Properties. 10) CP- Carrier and Casing Pipe: The PIP portions of the Liberty Pipeline specialpermit segment will not have a CP system to protect the 12.75-inch diameter carrier pipe from corrosion. Corrosion protection is provided by the dual layer fusion bonded epoxy (FBE) coating and by maintaining a dry inert environment during construction and operations and the sealed 16-inch diameter casing (PIP seal) during operations. a) The 16-inch diameter casing must have a CP system that meets the requirements for a buried or submerged pipeline in 49 CFR 195.563. b) The CP system for the 16-inch diameter casing must be installed with a distributed galvanic anode system consisting of aluminum anodes spaced throughout the offshore subsea buried segment. c) The anodes must be connected to the 16-inch diameter casing and the weld area must be coated. d) The 16-inch casing must be externally coated for corrosion protection. The 16-inch diameter casing pipe must also be internally coated'4 with the exception of a short segment (less than 6-inches wide) at pipe girth welds. e) The 16-inch diameter casing must have equipment to monitor pressure and temperature of the PIP annulus at all times, except during equipment maintenance activities which must be completed within one 12-hour shift and with the knowledge of Liberty Pipeline controllers. 12 Carrier pipe must be manufactured in accordance with the incorporated by reference edition of API 5L specified in 49 CFR 195.3. 13 Hilcorp must use the editions noted for these standards that are incorporated by reference in 49 CFR 195.3. 14 The internal coating for the 16-inch diameter casing pipe must be a coating that protects against atmospheric corrosion such as Vaispar- Pipeclad Flowliner 93 OR. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 7 of 44 <<>> 11) PIP Design: The PIP design must have specifications and procedures implemented for the following: a) Casing isolators must be clamped to the 12.75-inch diameter carrier pipe to isolate it from the 16-inch diameter casing pipe. Spacing of the isolators must maintain separation between the 12.75-inch diameter carrier and 16-inch diameter casing pipe throughout the entire length of the PIP section. b) The PIP annulus'5 must be sealed at each end ofthe 16-inch diameter casing. c) The dew point'6 ofthe inert gas in the annulus must be sampled prior to commissioning of the PIP system. The dew pointofthe inert gas must be maintained at negative 10°F or lower at all times. d) The annulus must be filled with an inert gas, such as nitrogen or argon. e) The PIP annulus must be connected to a vacuum system to maintain the annular back- pressure. The annular space must be maintained below atmospheric pressure at negative 10 psig or less at all times. f) The vacuum system must be connected to the 16-inch diameter casing pipe at the LDPI. The vacuum system must include block valves, a pressure regulator, pressure relief valves, a vacuum pump, sample ports, and associated piping. The vacuum system must be operational at all times, except during maintenance activities which must be conducted during one 12-hour shift and with the knowledge of Liberty Pipeline controllers. g) The annulus must be monitored for pressure and temperature changes that would indicate changes in the gas composition in the annulus. h) Pressure transmitters to monitor pressures of fluids or gases in the annulus must be placed at each end of the PIP annulus system above ground at LDPI (MP 0.02) and above ground at the Alaska shoreline (MP 5.7) 15 "PIP annulus," "annulus," or "annular space" refers to the space between the carrier pipe and the casing pipe. 16 Typically, for corrosion to occur, it requires an electrolyte (such as water) and air to be present. The inert gas in the annulus significantly reduces the potential for external corrosion on the NPS 12 LSOP by removing the oxygen from the surface ofthe carrier pipe. The inert gas will also be unsaturated, or dry, with a dew point sufficient to keep any water from dropping out of the gas for all operating temperatures ofthe PIP system. Corrosion generally is inhibited when the relative humidity is maintained below 30%. To account for potential presence of hygroscopic dirt, a minimum relative humidity of 20% is recommended for this application. The PIP system will be installed in a subsea trench where the lowest ambient conditions are above 25 °F. The effective dew point at 20% relative humidity and 25°F is -7 °F. Therefore, a -10 °F dew point should be sufficient to prevent liquid drop out as low as 25 °F. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 8 of 44 <<>> i) Temperature transmitters to monitor temperature of the annular space must be placed at each end of the PIP annulus system, one (1) above ground at LDPI and one (1) adjacent to the onshore PIP transition. 12) PIP Bulkhead Design: Hilcorp plans to rigidly connect the 16-inch diameter casing pipe and the 12.75-inch carrier pipeline by means of a forged bulkhead, similar to what is presented in Figure 2 on page 36 of 44¯17 The bulkheads must be placed above grade where the alignment transitions from buried to aboveground installation. Installation of the bulkheads must create a sealed annulus between the 12.75 -inch diameter carrier pipeline and the 16-inch diameter casing pipe. a) The PIP bulkhead design must meet both 49 CFR 195.106, Internal Design Pressure, and ASME B3 1.4 -2016, Table A402.3.5-1, Design Factorsfor Offshore Pipeline Systems. The bulkhead design and connecting piping must be treated as piping on an offshore platform for determining hoop, circumferential, and combined stresses. b) The PIP bulkhead must be hydrostatically tested by the manufacturer in accordance with the Design Proof-Test requirements of the Manufacturers Standardization Society ofthe Valve and Fittings Industry, Inc., MSS SP-75-2014 High-Strength, Wrought, Butt-Welding Fittings or ASME B 16.9-2012 Factory-Made Wrought Butt-welding Fittings, in accordance with 49 CFR 195.118.18 The PIP bulkhead must be pressure tested with the pipeline after onsite iiistallation in accordance with 49 CFR 195.304 and 195.306. c) d) The PIP bulkhead fitting must be designed for: i) Loads: thermal force, pressure force, cap force, and friction force; ii) Design Safety Factor for all Combined Stress loads must not exceed: 0.72; iii) Design Factor for Hoop Stress must not exceed: 0.6; and iv) Minimum Factory Test Pressure: 5,700 psig for continuous 4-hours minimum. PIP bulkhead and pipeline loads must be analyzed using Finite Element Analysis (FEA) for the carrier pipeline, casing and bulkhead operating conditions, and design safety factors 17 Hilcorp may use another method of sealing the PIPdesign instead ofthe bulkhead outlined in Figure 2, but any design must meet 49 CFR Part 195 and these specialpermit conditions. Hilcorp must give PHMSA Western Region Director or Project Designee notice of any changes to the sealing method for the PIP design and must get a "no objection" letter from PHIvISA ofthe sealing method. If Hilcorp does not receive a "no objection" letter from PHIvISA within 90 days of the notification, Hilcorp may proceed. PHMSA will notify Hilcorp if additional review time is needed. 18 Hilcorp may use the editions noted for these standards (2014 and 2012) or may use the edition incorporated by reference in49CFR 195.3. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 9 0144 <<>> over the life span ofthe Liberty Pipeline specialpermit segment. The FEA must meet the design factors listed in Condition 12(c). 13) Bundle and Fiber Optic Cable: The offshore subsea buried specialpermit segment will be installed as a bundle. The bundle will consist of the PIP system, utility line, fiber optic cable, spacers and bundle straps. See Figure 1 on page 36 of 44 for a conceptual cross section of the Liberty Pipeline bundle. Note: The fiber. optic cable will be located outside ofthe PIP system. The fiber optic cable is not within the 16-inch diameter casing. a) The fiber optic cable must be installed with accurate distributed temperature sensing (DTS) capability to allow for the immediate identification of any areas experiencing changes in soil temperature. The fiber optic cable must be operational at the time the Liberty pipeline is placed into crude oil service. b) The fiber optic cable must be installed with DTS instrumentation, capable of detecting and locating temperature anomalies within five (5) feet.19 c) The DTS system must be able to sense all temperatures within the pipeline design capacity d) The temperature profile ofthe bundle must be transmitted to the supervisory control and data acquisition (SCADA) system for continuous monitoring and recording. e) The 4.5-inch utility line shown in Figure 1 is not part ofthe special permit or the special permit conditions. The 4-inch utility must comply with current Federal Pipeline Safety Regulations, and Hilcorp must notify PHMSA in accordance with 49 CFR 191.22(c) prior to placing it into 49 CFR Parts 192 or 195 service. f) The depth of cover for the bundle must be a minimum of seven (7) feet below the subsea mudline for the offshore subsea buried segment of the Liberty Pipeline specialpermit segment bundle; with the exception to the two (2) transition segments where the buried piping transitions to the surface. 14) Pipe- External Coating: Carrier and casing pipe must have an external coating system that consists of an external dual layer of Fusion Bonded Epoxy (FBE) coating. The dual layer FBE 19 Ifthe fiber optics cable should fail during the 12.75-inch diameter pipeline operational life, Hilcorp must develop and implement alternative operational procedures that maintain a similar level of safety and environmental protection. Hilcorp must submit these procedures and an implementation schedule to PHMSA Western Region Director or Project Designee and receive a response of "no objection" prior to implementation. If Hilcorp does not receive a "no Objection" letter from PHMSA within 90 days ofthe notification, Hilcorp may proceed. PHMSA will notiQj Hilcorp if additional review time is needed. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 10 of 44 <<>> consists of one (1) layer of standard FBE covered with a minimum of one (1) layer of an abrasion resistant overlay (ARO) to protect the primary FBE layer. The external pipe coating system must be applied to the Liberty Pipeline specialpermit segment in accordance with a coating. application specification that addresses: a) pipe surface cleanliness standards, b) blast cleaning, c) application temperature control, d) adhesion for coating to pipe, e) cathodic disbondment, f) moisture penneation, g) bending, h) minimum coating thickness, i) coating imperfection, and j) coating repair. 15) Monitoring System: The Liberty Pipeline specialpermit segment carrier pipe must be monitored for operating pressure, temperature, and flow rate, including the following requirements: a) Pressure transmitters must be placed at each end of the Liberty Pipeline, one (1) at LDPI and one (1) at the pipeline tie-in at the Badami Pipeline. b) Flow meters must be placed at each end ofthe Liberty Pipeline, one (1) at LDPI and one (1) at the pipeline tie-in at the Badami Pipeline. c) Temperature transmitters must be placed at each end ofthe Liberty Pipeline, one (1) at LDPI and one (1) at the pipeline tie-in at the onshore Badami Pipeline. d) Valves at LDPI and at the pipeline tie-in at the Badami Pipeline must be remote closure and have pressure monitoring on both sides of the valves. The actuation of the valves may not result in an overpressure event of the carrier pipeline, and closure rates must be substantiated by a hydraulic surge analysis. The remote closure valve status and adjacent pipeline pressures must be monitored at all times, except during scheduled equipment maintenance activities, which must be completed within a 12-hour shift and with the knowledge of Liberty pipeline controllers. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 11 of 44 <<>> 16) Casing Pipe- Design and Operating Properties: The 16-inch diameter casing design properties must be as shown in Table 2 below.20 Table 2: Liberty Pipeline- 16-inch Diameter Casing Design and Operating Properties Design and Operating Parameter Value Unit Minimum Design Pressure 1,480 psig DesignlOperating Temperature Range -50 to 150 °F Normal Operating Pressure -20 to 50 psig Normal Operating Temperature 60 to 90 °F Maximum Allowable Combined Stress (Seq) 46,980 psi Relief Valve- Annulus 25 to 50 psig a) The casing pipe must be a minimum of 16-inch diameter, 0.625-inch wall thickness, carbon steel pipeline manufactured per API Specification 5L, Specificationfor Line Pipe,2' Grade X52, PSL 2, including supplementary requirements for offshore pipelines (API 5L Annexes J and K). The casing pipe may be of a larger diameter, thicker wall thickness, or higher strength (grade) to maintain equivalent strength (a minimum design pressure of 1,480 psig). b) Charpy V-Notch (CVN) impact testing must be conducted on the casing pipe in accordance with API Specification 5L Annex G, with the following modifications: i) CVN impact test temperature must be negative 50 °F; and ii) Minimum energy levels on full-size specimens must be 50 ft-lb average and 40 ft-lb minimum. c) The 16-inch diameter casing must be coated with an external coating system. The coating system must be installed in accordance with Condition 17(b). d) The casing pipe overpressure relief valve data and/or annulus pressure data must be transmitted to the SCADA system to ensure timely pipeline shutdown should the annulus pressure exceed the established pressure thresholds in Table 2. Construction: 20 Justification for any change in the design and operating parameters in Table 2 must be provided to the Western Region Director or Project Designee for review, and must receive a "no objection" letter prior to implementation. IfHilcorp does not receive a "no objection" letter from PHMSA within 90 days ofthe notification, Hilcorp may proceed. PHMSA will notifi Hilcorp if additional review time is needed. 21 Hilcorp must use the API 5L edition incorporated by reference in 49 CFR 195.3. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 12 of 44 <<>> 17) Construction Quality Control: Hilcorp must develop and implement a right-of-way (ROW) construction monitoring program and a pipeline construction quality control program for the Liberty Pipeline specialpermit segment, as specified below: a) ROW Construction Monitoring Program: A ROW construction monitoring program must include procedures, personnel training, and be implemented for all construction phases of construction. The ROW construction monitoring program must include procedures for: i) Operator Qualification (00) Procedures: OQ Procedures must be developed and implemented for construction tasks that can affect pipeline integrity in compliance with 49 CFR 195.501. ii) Construction Quality Assurance Plan and Procedures: Hilcorp must develop a Construction Quality Assurance Plan and corresponding Procedures that establish the project quality objectives and personnel accountabilities to construct the pipeline system as designed. The Construction Quality Assurance Plan and Procedures, at a minimum, must include procedures, specifications, and personnel training for: 1) pipe inspection, 2) hauling and stringing pipe, 3) welding, 4) non-destructive examination of girth welds, 5) applying and testing field applied coating, 6) lowering the pipeline into the subsea trench, 7) backfilling, and 8) hydrostatic testing including dewatering and drying. iii) Subsea Trench Quality Plan and Procedure: Hilcorp must develop a Subsea Trench Quality Plan that provides quality objectives to ensure the pipeline system is placed in the subsea trench as designed. At a minimum, the Subsea Trench Quality Plan and Procedure must include quality assurance/control for: 1) periodic collection of samples oftrench spoils to test for chemical and electrical properties related to pipe corrosion, 2) trench depth monitoring, 3) trench bottom roughness profiling, and PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 13 of 44 <<>> 4) backfihling requirements. b) Carrier and Casing Pipe Construction Quality Control Programs: i) Coatings for Carrier and Casing Pipe: A coating application quality control specification must be developed, implemented, and personnel must be trained to ensure carrier and casing pipe surface cleanliness, application temperature control, adhesion quality, cathodic disbondment, moisture permeation, bending, and minimum coating thickness for girth weld and repair coatings. Both the carrier and casing pipe must be externally coated for corrosion protection. ii) Non-Shielding Coatings: Pipe, girth weld, and repair coatings must be non-shielding to CP. Shielding coatings such as tape or shrink sleeves must not be used. iii) Pipe Protection: Pipe end protection caps must be installed on the pipe joint weld bevels during the storage, handling, transport, and staging for all ofthe pipe included in the pipeline bundle to reduce the introduction of foreign materials including snow, ice, and water. 18) Carrier Pipeline Girth Welds: All girth welding procedures for the 12.75-inch carrier pipe must be in accordance with 49 CFR 195.2 14 that incorporates by reference, API Standard 1104.22 a) All pipeline girth welds must be non-destructively tested to meet 49 CFR 195.228, 195.230, and 195.234. b) All pipeline girth welds with any type crack must be cut-out prior to placing the carrier into service with crude oil. c) The 12.75-inch carrier pipe and coating must be protected from any weld splatter or other damage during welding of the 16-inch casing pipe. 19) Casing Pipe Girth Welds: All casing pipe girth welding procedures must be in accordance with 49 CFR 195.214 and API Standard 1104.23 a) All casing pipe girth welds must be non-destructively tested to meet 49 CFR 195.228, 195.230 and 195.234. 22 Hilcorp must use the API 1104 edition incorporated by reference in 49 CFR 195.3. 23 Hilcorp must use the API 1104 edition incorporated by reference in 49 CFR 195.3. PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 14 of 44 <<>> b) All casing pipe girth welds with any type crack must be cut-out prior to placing the 12.75- inch diameter carrier pipe into operational service with crude oil. 20) Casing Isolators: The Liberty Pipeline specialpermit segment must be supported by casing isolators at regular intervals throughout the PIP portion of the specialpermit segment. A maximum casing isolator spacing interval of 10-feet or less must be used to minimize lateral deflection between isolators, prevent contact between the casing and carrier pipes, provide structural integrity ofthe PIP design during unexpected ground movement or creation of unsupported spans caused by localized seafloor scour, and to accommodate cyclic, thermally induced movement of the carrier pipe relative to the casing. The casing isolator spacing should facilitate installation of the carrier pipe within the casing. The casing isolators must consist of two high-density polyethylene half-shells with a continuous temperature rating of 225°F or greater so that the isolators will not lose structural integrity or degrade under loading or temperature conditions for the life of the pipeline. 21)Relief Storage Tank: The PIP annulus of the Liberty Pipeline specialpermit segment must be configured so that any excessive pressure (as monitored under Condition 11) resulting from either crude oil or seawater entering the annulus can be discharged from an annulus relief valve (see Table 2 for relief set pressure ranges) to either a "breakout tank, a portable tank, drum and flare system, or other pipeline" (relief storage tank) that operates at a pressure that is not higher than the 16-inch diameter casing maximum annulus relief valve pressure setting in Table 2. The relief storage tank must facilitate the removal of liquids from the annulus in an event the annulus relief valve discharges. The relief storage tank capacity must be based upon the time to shut-down and isolate the carrier pipeline and maximum flow volumes (see Condition 16(d). O&M: 22) O&M Procedures: In addition to the O&M procedures otherwise required by 49 CFR Part 195, Hilcorp must develop and implement O&M procedures for the specialpermit segment and the Liberty Pipeline, including the following: ¯ CP monitoring system on the 16-inch diameter casing pipe, ¯ PIP annulus monitoring, ¯ SCADA System for the Liberty Pipeline and PIP System, ¯ Integrity Management Plan for the 12.75-inch diameter pipeline and 16-inch diameter casing, and PHMSA-2017-0091, Hilcorp- Liberty Pipeline- Special Permit Page 15 of 44 <<>> a) b) c) . Data Integration Plan and Procedures to monitor and remediate any corrosion or excessive strains on the 12.75-inch diameter pipeline or 16-inch diameter casing pipe. O&M procedures for the specialpermit segment and the Liberty Pipeline must technically assess all operating parameters that have an effect on the implementation of, or compliance with, all ofthese specialpermit conditions; including, but not limited to: i) maximum and minimum pressures, ii) pipe corrosion, iii) oil and environmental (soil) temperatures, and iv) maximum and minimum operating temperatures ofthe carrier pipe and casing pipe. Procedures for the carrier pipeline in the specialpermit segment must be developed and implemented to ensure the following conditions are evaluated: i) the effects of corrosion anomalies (defects), ii) the effects of mechanical damage (such as dents and gouges), iii) the effects of cracking on the stress and strain capacity of the pipe, casing, and girth welds, iv) the effect oftensile and compressive strainlstress capacity on anomalies in asse - **truncated:** true - **body characters:** 268892