{"operation":"document","citation":"PHMSA-2017-0161","title":"Tennessee Gas Pipeline Company, LLC — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2022-08-11","effective_on":"2022-08-11","summary":"PHMSA-2017-0161, issued 2022-08-11 for Tennessee Gas Pipeline Company, LLC's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0161.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0161.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2017-0161","source_url":"https://www.regulations.gov/docket/PHMSA-2017-0161","body":"PHMSA pipeline special permit PHMSA-2017-0161. Operator: Tennessee Gas Pipeline Company, LLC. System: Gas Transmission. Issue date: 2022-08-11.\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSpecial Permit Analysis and Findings\nClass 1 to 3 Location\nSpecial Permit Information:\nDocket Number: PHMSA-2017-0161\nRequested By: Tennessee Gas Pipeline Company, LLC\nOperator ID#: 19160\nOriginal Date Requested: December 7, 2017\nOriginal Issuance Date: August 11, 2022\nCode Section(s): 49 CFR 192.611(a) and (d) and 192.619(a)\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS),\n1 provides this information to describe the facts of the subject special permit application\nsubmitted by Tennessee Gas Pipeline Company, LLC (TGP)2 to discuss any relevant public comments\nreceived with respect to the application, to present the engineering and safety analysis of the special\npermit application, and to make findings regarding whether the requested special permit should be\ngranted and, if so, under what conditions. TGP requested that PHMSA waive compliance from the 49\nCode of Federal Regulations (CFR) 192.611(a) and (d) and 192.619(a) for a natural gas transmission\npipeline segment, where the class location has changed from Class 1 to a Class 3 location.\nPipeline System Affected:\nThis special permit application by TGP requests a waiver from the class location change requirements in\n49 CFR 192.611(a) and (d) and 192.619(a) for approximately 1.050 miles of the 20-inch diameter gas\n1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of Transportation’s\nPipeline and Hazardous Materials Safety Administration Office of Pipeline Safety.\n2 TGP is a wholly owned subsidiary of Kinder Morgan, Inc.\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 1 of 10\n\n<<<PAGE 2>>>\n\ntransmission pipeline located in Kanawha County, West Virginia.\nPipe specifications including outside diameter, year installed, seam type, coating type, pipe grade, wall\nthickness, maximum allowable operating pressure (MAOP), minimum pressure test pressure, and\npressure test factor based on the minimum test pressure are detailed in Table 1 – Pipe Specifications by\nLine Name.\nTable 1 – Pipe Specifications by Line Name\nOutside\nWall\nMin. Test\nPressure\nYear\nLine Name\nDiameter\nInstalled\nSeam\nType MAOP\nCoating Type Grade\nThickness\nPressure\nTest\n(psig)\n(inches)\n(inches)\n(psig)\nFactor\n100-1 20 1984 DSAW Fusion bonded epoxy X52 0.25 936 1,198 1.28\nNote: DSAW is double submerged arc welded pipe weld seam type.\nPsig means pounds per square inch gauge.\nWithout this special permit, 49 CFR 192.611(a) would require TGP to replace the special permit\nsegments with stronger pipe or reduce the pipeline MAOP for a Class 1 to Class 3 location change.\nSpecial Permit Request:\nOn December 29, 2020, TGP applied to PHMSA for a special permit seeking relief from 49 CFR\n192.611(a) and (d) and 192.619(a) for the below-listed special permit segments, where a class location\nchange occurred from the original Class 1 to a Class 3 on the 20-inch diameter Line 100-1 Pipeline\n(Pipeline) located in Kanawha County, West Virginia.\nTGP’s special permit applies to the special permit segments and special permit inspection area\ndescribed and defined as follows, using the TGP survey station references:\nSpecial Permit Segments:\nThis special permit applies to the special permit segments identified using the TGP valve and station\nreferences as detailed in Table 2 – Special Permit Segments.\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 2 of 10\n\n<<<PAGE 3>>>\n\nTable 2 – Special Permit Segments\nSpecial\nPermit\nOutside\nLine\nDiameter\nName\nLength\n(feet)\nSegment\nNumber3\n(inches)\nStart Survey Station\n(Valve/MP–\nStation)\nEnd Survey\nStation\nCounty/Parish,\nState\nNo.\nYear\nInstalled Seam Type MAOP\n(psig)\n451 20 100-1 4,249.18 120-1 – 14819 (Valve/MP –\nStation)\n120-1 – 15995 Dwellings\nKanawha,\nWV 13 1984 DSAW 936\n452 20 100-1 1,816.56 120-1 – 19928 120-1 – 21744 Kanawha,\nWV 2 1984 DSAW 936\n453 20 100-1 845.38 120-1 - 23426 120-1 – 24271 Kanawha,\nWV 1 1984 DSAW 936\nSpecial Permit Inspection Area:\nThe special permit inspection area is defined as the area that extend 220 yards on each side of the\ncenterline as shown in Table 3 – Special Permit Inspection Area.\nTable 3 – Special Permit Inspection Area\nSpecial Permit\nInspection Area\nNumber\nSpecial\nPermit\nOutside\nLine\nDiameter\nSegment\nName\nStart Survey Station\n(Valve/MP – Station)\nEnd Survey Station\n(Valve/MP – Station)\nLength4\n(miles/feet)\n(inches)\nNumber\n1 451.452,\n453 20 100-1 118-1 – 18.79 121-1 – 27219.53 46.02/\n242,989.49\nPublic Notice:\nOn April 5, 2022, PHMSA posted a notice of this special permit request in the Federal Register (87 FR\n19735) with a closing date of May 5, 2022. PHMSA did not receive any comments concerning this\nspecial permit request.\nThe TGP special permit application letter, Federal Register notice, Final Environmental Assessment,\nFinding of No Significant Impact, and all other pertinent documents are available for review in Docket\nNo. PHMSA-2017-0161 in the Federal Docket Management System (FDMS) located at\nwww.Regulations.gov.\nAnalysis:\nBackground: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the criteria it\nuses for the consideration of applications for class location change waivers, now being granted or denied\n3 On February 3, 2022, TGP rescinded requested special permit segments 454, 455, 456, 457, 458, 459, 462, and 463.\n4 If the special permit inspection area footage does not extent from launcher to receiver then the special permit inspection\narea would need to be extended.\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 3 of 10\n\n<<<PAGE 4>>>\n\nthrough a special permit. First, certain threshold requirements should be met on a pipeline special\npermit segments for a class location change special permit to be granted. Second, the age and\nmanufacturing process of the pipe; system design, and construction; environmental, operating and\nmaintenance histories; and integrity management (IM) program elements are evaluated as significant\ncriteria. These significant criteria are presented in matrix form and can be reviewed in the FDMS,\nDocket No. PHMSA–RSPA-2004-17401. Third, special permits will only be granted when pipe\nconditions and active IM provide a level of safety greater than or equal to a pipe replacement or pressure\nreduction. The operator’s Federal pipeline safety regulation compliance history is also evaluated as part\nof the criteria matrix for acceptability prior to issuance of a special permit.\nThreshold Requirements: Each of the threshold requirements published by PHMSA in the June 29,\n2004, Federal Register notice is discussed below regarding the TGP special permit request.\n• No pipeline segment in a class location changing to Class 4 location will be considered.\n• This special permit request is for three (3) special permit segments where a change has\noccurred from a Class 1 location to a Class 3 location.\n• TGP meets this requirement.\n• No bare pipe will be considered.\n• The special permit segments are externally coated with fusion bonded epoxy.\n• TGP meets this requirement.\n• No pipe containing wrinkle bends will be considered.\n• There are no reported wrinkle bends in the special permit segments.\n• TGP meets this requirement.\n• No pipe segment operating above 72% of the specified minimum yield strength (SMYS) will be\nconsidered for a Class 3 special permit.\n• The special permit segments operate at or below 72% SMYS.\n• TGP meets this requirement.\n• Records must be produced that show a hydrostatic test to at least 1.25 times the MAOP. The records\nshould include test pressure, year of the test, test duration, and pressure test percent of MAOP for the\npipeline:\n• TGP has provided records to PHMSA that the special permit segments have been tested to at\nleast 1.25 times the MAOP.\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 4 of 10\n\n<<<PAGE 5>>>\n\n• TGP meets this requirement\n• Inline Inspection (ILI) must have been performed with no significant anomalies identified that\nindicate systemic problems such as stress corrosion cracking (SCC).\n• TGP ran an ILI for corrosion and deformation and an ILI for denting in all special permit\nsegments.\n• Criteria for consideration of a class location change waiver, being considered through the special\npermit, published by PHMSA in the Federal Register (69 FR 38948), define a waiver inspection\narea (special permit inspection area) as up to 25 miles of pipe on either side of the waiver segment\n(special permit segment).\n• TGP has identified a longer segment surrounding the special permit segments as the special\npermit inspection area. The special permit inspection area is the entire segment length\nbetween the upstream launcher and downstream receiver on the ILI segment that contains the\nspecial permit segments.\n• A special permit would be contingent upon TGP’s incorporation of the special permit\nsegments into its written IM program as a covered segment in a high consequence area in\naccordance with 49 CFR 192.903.\nCriteria Matrix: The data submitted by TGP for the special permit segment has been compared to the\nclass location change special permit criteria matrix.\n• The special permit segments fall in the probable acceptance column of the criteria matrix for:\n• Pipe material and toughness, coating type, design stress, depth of cover, test pressure, test\nfailures, local geology, type of service, pressure fluctuations, safety related conditions, ILI type,\nILI timeframe, and damage prevention program.\n• The special permit segments fall in the requires substantial justification column of the criteria\nmatrix for:\n• Kinder Morgan, Inc. overall enforcement findings fall in the requires substantial justification\ncategory. TGP’s 11-year enforcement findings do not fall within this category.\n• This special permit requires TGP to implement the special permit conditions that include safety\nrequirements on the operations, maintenance, and IM of the special permit segments (1.050\nmiles) and the special permit inspection area (46.02 miles). Therefore, the safety benefits are\nobtained well beyond the portion of the pipeline that experienced a class location change.\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 5 of 10\n\n<<<PAGE 6>>>\n\n• TGP will be required to submit an annual report for this special permit on integrity threats to the\npipeline in the special permit segments and the special permit inspection area.\nOperational Integrity Compliance:\nTo inform PHMSA’s decision about whether a special permit could provide a level of safety greater than\nor equal to a pipe replacement or pressure reduction and is consistent with pipeline safety, PHMSA\nreviewed this special permit request to understand the known type of integrity threats that are in the\nspecial permit segments and special permit inspection area. This integrity information was used to\nconsider special permit conditions to provide a systematic program to review and remediate the pipeline\nfor safety concerns. Additional operational integrity review and remediation requirements are required\nby this special permit to ensure that the operator has an ongoing program to locate and remediate safety\nthreats. These threats to integrity and safety include any issues with the pipe coating quality, cathodic\nprotection effectiveness, operations damage prevention program, pipe depth of soil cover, weld seam\nand girth weld integrity, anomalies in the pipe steel and welds, and material and structures either along\nor near the pipeline that could cause the cathodic protection system to be ineffective. PHMSA would\nhave to carefully design a comprehensive set of conditions that TGP must implement to comply with\nthis special permit.\nPast Enforcement History – January 1, 2011 through January 31, 2022:\nDuring January 1, 2011, through January 31, 2022, TGP was cited in 27 enforcement actions with a total of\n$257,600 in assessed civil penalties. PHMSA issued four (4) Corrective Action Orders, six (6) Notices of\nAmendment, ten (10) Notices of Probable Violation, one (1) Safety Order, and six (6) Warning Letters to\nTGP. Tables 4 and 5 below show PHMSA’s enforcement actions and civil penalties for TGP:\nTable 4: TGP Enforcement Matters from\nJanuary 1, 2011 through January 31, 2022\nNotice of\nStatus Corrective\nAction Order\nNotice of\nSafety\nProbable\nAmendment\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 3 5 9 1 6 24\nOPEN 1 1 1 0 0 3\nTotal 4 6 10 1 6 27\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 6 of 10\n\n<<<PAGE 7>>>\n\nTable 5: TGP Enforcement Civil Penalty Status\nJanuary 1, 2011 through January 31, 2022\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$384,200 $0 $257,600 $126,000 $257,000\nSummary of Enforcement Findings for TGP includes: Reporting, welding, compliance with\nspecifications or procedures, corrosion control, operations and maintenance procedures, continuing\nsurveillance, public awareness, MAOP, control room management, relief devices, maintenance of\nvalves, qualification of operating personnel, and IM:\n• 49 CFR 191.22, 191.27, 192.225, 192.229, 192.303, 192.469, 192.479, 192.481, 192.603,\n192.605, 192.613, 192.615, 192.616, 192.619, 192.631, 192.705, 192.706, 192.709, 192.713,\n192.735, 192.736, 192.739, 192.743, 192.745, 192,805, 192.905, 192.921, and 192.937.\nTable 6 below shows PHMSA’s enforcement actions and civil penalties for TGP and the specific 49 CFR Part\n191 and 192 violations:\nTable 6: Summary of Enforcement Findings from TGP\nJanuary 1, 2011 through January 31, 2022\nNotice of Amendment\nConstruction 1 Control Room\nManagement 3 OME Procedural\nManual 2\nOperation and/or\nMaintenance 2 Reporting 2 Welding of Steel in\nPipelines 1\nNotice of Amendment Total: 11\nNotice of Probable Violation\nControl Room\nManagement 1 OME Procedural\nManual 7 Public Awareness 1\nCorrosion Control 3 Operation and/or\nMaintenance 8 Reporting 1\nIntegrity Management 3 Operator\nQualification 3 Welding of Steel in\nPipelines 1\nNotice of Probable Violation Total: 28\nWarning Letter\nOME Procedural\nManual 2 Operation and/or\nMaintenance 4 Reporting 1\nNotice of Amendment Total: 7\nGrand Total: 46\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 7 of 10\n\n<<<PAGE 8>>>\n\nSummary of Enforcement Findings for the Kinder Morgan Gas Pipelines Companies - CIG, EPNG,\nNGPL, SNG, TEJAS, and TGP:\nFrom January 1, 2011, through January 31, 2022, Kinder Morgan, the operator of TGP, was cited in 69\nenforcement actions with a total of $1,077,800 in assessed civil penalties on its Colorado Interstate Gas\nCompany (CIG), El Paso Natural Gas Company (EPNG), Natural Gas Pipeline of America (NGPL), Southern\nNatural Gas Company (SNG), Tejas Pipeline (TEJAS), and Tennessee Gas Pipeline Company (TGP) pipeline\nsystems. PHMSA issued seventeen (17) Notice of Amendments, twenty-two (22) Notices of Probable\nViolation, twenty (21) Warning Letters, one (1) Safety Order, and eight (8) Corrective Action Orders to\nKinder Morgan.\nTables 7 and 8 below show PHMSA’s enforcement actions and civil penalties for Kinder Morgan on\nthese pipeline systems – CIG, EPNG, NGPL, SNG, TEJAS, and TGP with operator identification\nnumbers (OPID#) 2564, 4280, 13120, 18516, 4900, and 19160.\nTable 7: Kinder Morgan Enforcement Matters from\nJanuary 1, 2011 through January 31, 2022\nNotice of\nStatus Corrective\nAction Order\nNotice of\nSafety\nProbable\nAmendment\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 5 16 21 1 21 64\nOPEN 3 1 1 0 0 5\nTotal 8 17 22 1 21 69\nTable 8: Kinder Morgan Enforcement Civil Penalty Status\nJanuary 1, 2011 through January 31, 2022\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$1,461,500 $0 $1,077,800 $383,700 $1,077,800\nThe type of 49 CFR Part 192 enforcement violations against Kinder Morgan on these six (6) pipeline\nsystems from January 1, 2011 through January 31, 2022, were as follows:\nSummary of Enforcement Findings for CIG, EPNG, NGPL, SNG, TEJAS, and TGP includes:\nThe type of 49 CFR Part 192 enforcement violations against Kinder Morgan on these six (6) pipeline\nsystems from January 1, 2011, through January 31, 2022, included reporting, design, welding,\ncompliance with specifications or procedures, corrosion control, operations and maintenance\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 8 of 10\n\n<<<PAGE 9>>>\n\nprocedures, continuing surveillance, public awareness, emergency plans, MAOP, control room\nmanagement, relief devices, maintenance of valves, qualification of operating personnel, and IM:\n• 49 CFR 191.5, 191.14, 191.15, 191.22, 191.25, 191.27, 192.12, 192.14, 192.161, 192.199, 192.225,\n192.227, 192.229, 192.303, 192.459, 192.463, 192.465, 192.469, 192.475, 192.479, 192.481,\n192.603, 192.605, 192.613, 192.615, 192.616, 192.619, 192.625, 192.631, 192.705, 192.706,\n192.707, 192.709, 192.713, 192.735, 192.736, 192.739, 192.743, 192.745, 192,805, 192.807,\n192.905, 192.911, 192.917, 192.921, 192.933, 192.935, and 192.937.\nTable 9 below gives a complete summary of the findings and the specific 49 CFR Part 191 and 192 violation:\nTable 9: Summary of Enforcement Findings for\nCIG, EPNG, NGPL, SNG, TEJAS, and TGP\nJanuary 1, 2011, through January 31, 2022\nNotice of Amendment\nOME Procedural\nManual 11 Operation and/or\nMaintenance 2 Operator Qualification 3\nPublic Awareness 8 Reporting 3 Transportation of Gas 5\nIntegrity Management 10 Control Room\nManagement 4 Construction 1\nWelding of Steel in\nPipelines 3\nNotice of Amendment Total: 50\nNotice of Probable Violation\nCorrosion Control 13 OME Procedural\nManual 14 Operation and/or\nMaintenance 26\nOperator Qualification 7 Public Awareness 2 Reporting 5\nIntegrity Management 10 Control Room\nManagement 1 Welding of Steel in\nPipelines 1\nDesign 2\nNotice of Probable Violation Total: 81\nWarning Letter\nCorrosion Control 10 OME Procedural\nManual 9 Operation and/or\nMaintenance 31\nOperator Qualification 2 Public Awareness 4 Reporting 1\nTransportation of Gas 1 Integrity\nManagement 1 Design 1\nNotice of Amendment Total: 60\nGrand Total: 191\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 9 of 10\n\n<<<PAGE 10>>>\n\nFindings:\nBased on the information submitted by TGP and PHMSA’s analysis of the technical, operational, and\nsafety issues, PHMSA finds that granting this special permit with conditions for TGP to operate the\nspecial permit segments defined in Table 1 at its current MAOP for a Class 1 to 3 location change\nwould not be inconsistent with pipeline safety.\nPHMSA has designed the special permit conditions to effectively assess and remediate threats to the\nspecial permit segments and special permit inspection area, including pressure testing, obtaining pipe\nmaterial records, and conducting assessments to evaluate pipe girth welds that have not been non-\ndestructively tested, any pipe with missing material records, and SCC. To ensure TGP properly\nimplements the special permit conditions, TGP will be required to give PHMSA an annual review of\ntheir compliance with the special permit.\nPHMSA finds the issuance and full implementation of this special permit that waives the requirements\nof 49 CFR 192.611 for a class location change to a Class 3 location is not inconsistent with pipeline\nsafety. This special permit requires TGP to implement the special permit conditions that include safety\nrequirements on the operations, maintenance, and IM of the special permit segments and the special\npermit inspection area. TGP will be required to implement the special permit conditions in the special\npermit segments and special permit inspection area, which include areas along the pipeline where\nperiodic assessment is not required by 49 CFR Part 192.\nCompleted in Washington DC on: August 11, 2022\nPrepared by: PHMSA - Engineering and Research Division\nFinal Page of the Special Permit Analysis and Findings\nPHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Special Permit Analysis and Findings – WV\nPage 10 of 10\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nAugust 11, 2022\nMr. Kenneth W. Grubb\nChief Operating Officer\nKinder Morgan Natural Gas Division\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nRe: Docket No. PHMSA-2017-0161\nSpecial Permit from August 11, 2022 to August 11, 2032\nDear Mr. Grubb:\nOn December 7, 2017, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Tennessee\nGas Pipeline Company, LLC (TGP)1 applied to the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) for a special permit. TGP requested a special permit to waive\ncompliance with 49 CFR §§ 192.611(a) and (d), and 192.619(a) for Class 1 to Class 3 location\nchanges on three (3) pipeline segments for approximately 1.050 miles of 20-inch diameter gas\ntransmission pipelines (Pipelines) located in Kanawha County, West Virginia. A gas\ntransmission pipeline operator is required by 49 CFR § 192.611 to confirm or revise the\nmaximum allowable operating pressure of a pipeline segment where the class location has\nchanged as defined in 49 CFR § 192.5.\nOn April 5, 2022, PHMSA published a Federal Register notice (87 FR 19735) announcing the\nSpecial Permit Request. The Special Permit Request letter, Final Environmental Assessment\n(FEA) and Finding of No Significant Impact (FONSI), Special Permit Analysis and Findings\n(SPAF), and all other pertinent documents for this special permit are available in Docket No.\nPHMSA-2017-0161 in the Federal Docket Management System located at\nwww.regulations.gov.2\nSubject to the stated terms and conditions, PHMSA grants this special permit (enclosed) based\non the information provided by TGP and the findings set forth in the SPAF, FEA, and FONSI.\nThis special permit provides relief from certain provisions of the Federal pipeline safety\n1 Tennessee Gas Pipeline Company, LLC is owned by Kinder Morgan, Inc.\n2 https://www.regulations.gov/docket?D=PHMSA-2017-0161.\n\n<<<PAGE 2>>>\n\nregulations for the Pipelines and requires TGP to comply with conditions and limitations\ndesigned to maintain pipeline safety as defined in the special permit. Note that in accordance\nwith 49 CFR § 190.341(j), PHMSA reserves the right to revoke, suspend, or modify this special\npermit if circumstances occur in which its continuance would be inconsistent with safety. If\nTGP elects not to implement the special permit conditions, TGP must notify PHMSA within 60\ndays and comply with 49 CFR § 192.611 within 18 months of the date of this letter.\nMy staff would be pleased to discuss this special permit or any other regulatory matter with you.\nSentho White, Director of PHMSA Engineering and Research Division, may be contacted at\n202-366-2415, on technical matters; and James Urisko, Director, Office of Pipeline Safety,\nSouthern Region, may be contacted at 404-832-1150, for operational matters specific to this\nspecial permit.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit – PHMSA-2017-0161\nSpecial Permit: PHMSA-2017-0161 – Tennessee Gas Pipeline Company, LLC Letter of Decision – Class 1 to 3 Location – West Virginia\nPage 2 of 2","truncated":false,"body_characters":23616}