{"operation":"document","citation":"PHMSA-2018-0105","title":"Gulf Stream Pipeline — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2020-09-10","effective_on":"2020-09-10","summary":"PHMSA-2018-0105, issued 2020-09-10 for Gulf Stream Pipeline's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2018-0105.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2018-0105.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2018-0105","source_url":"https://www.regulations.gov/docket/PHMSA-2018-0105","body":"PHMSA pipeline special permit PHMSA-2018-0105. Operator: Gulf Stream Pipeline. System: Gas Transmission. Issue date: 2020-09-10.\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMay 19, 2020\nMs. Anne Moore\nVice President - Business Functions\nGulfstream Management & Operating Services, LLC\n2701 North Rocky Point Drive, Suite 1050\nTampa, Florida 33607\nDocket No. PHMSA-2018-0105\nDear Ms. Moore:\nOn October 26, 2018, pursuant to the 49 Code of Federal Regulations § 190.341, the Gulfstream\nManagement & Operating Services, LLC (Gulfstream), applied to the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) for a special permit. Gulfstream requested to waive\ncompliance with § 192.195(a) for overpressure protection and § 192.619(a) for the operation of\nthe Gulfstream ML 200 Pipeline (Gulfstream Pipeline) at Mile Post 58.7 in the Gulf of Mexico,\nViosca Knoll, Block 82. This special permit would allow utilization of a pressure gradient to\ncontrol pipeline pressure for maintaining the maximum allowable operating pressure (MAOP) on\nthe Gulfstream Pipeline. The Gulfstream Pipeline is 427.8 miles of 36-inch diameter natural gas\npipeline routed from Coden, Mobile County, Alabama across the Gulf of Mexico to Palmetto,\nManatee County, Florida.\nOn July 29, 2019, PHMSA published a Federal Register notice (84 FR 36657) 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,\nand all other pertinent documents for this special permit are available for review in Docket No.\nPHMSA-2018-0105 in the Federal Docket Management System located at www.regulations.gov.\nPHMSA grants this special permit (enclosed) based on the information provided by\nGulfstream and the findings set forth in the Special Permit Analysis and Findings, FEA, and\nFONSI. This special permit provides relief from the Federal Pipeline Safety Regulations for\nthe Gulfstream Pipeline and requires Gulfstream to comply with certain conditions and\nlimitations designed to maintain pipeline safety for the period as defined in the special permit.\nPHMSA-2018-0105 – Gulfstream Pipeline\nLetter of Decision - Special Permit for Usage of Pressure Gradient\nPage 1 of 2\n\n<<<PAGE 2>>>\n\nMy staff would be pleased to discuss this matter or any other regulatory matter with you. Sentho\nWhite, Director of PHMSA Engineering and Research Division, may be contacted at 202-366-\n2415, on technical matters; and James Urisko, Director, Office of Pipeline Safety, Southern\nRegion, may be contacted at 404-832-1150, for operational matters specific to this special\npermit.\nSincerely,\nALAN\nKRAMER\nMAYBERRY\nDigitally signed by\nALAN KRAMER\nMAYBERRY\nDate: 2020.05.19\n15:46:54 -04'00'\nAlan K. Mayberry\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit – PHMSA-2018-0105\nPHMSA-2018-0105 – Gulfstream Pipeline\nLetter of Decision - Special Permit for Usage of Pressure Gradient\nPage 2 of 2\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSPECIAL PERMIT - Usage of Pressure Gradient\nSpecial Permit Information:\nDocket Number: PHMSA-2018-0105\nRequested By: Gulfstream Management & Operating Services, LLC\nOperator ID#: 31565\nDate Requested: October 26, 2018\nIssuance Date: May 19, 2020\nEffective Dates: May 19, 2020 to May 19, 2030\nCode Section(s): 49 CFR 192.195(a) and 192.619(a)\nGrant of Special Permit:\nBy this order, subject to the terms and conditions set forth below, the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),1 grants this special\npermit to Gulfstream Management & Operating Services, LLC (Gulfstream)2. This special permit\nwaives compliance with 49 Code of Federal Regulations (CFR) 192.195(a) for overpressure\nprotection (OPP) and 49 CFR 192.619(a) to allow utilization of a pressure gradient for pressure\ncontrol on the Gulfstream ML 200 Pipeline (Gulfstream Pipeline), as described below.\nThe Federal pipeline safety regulation in 49 CFR 192.195(a) requires OPP through pressure control,\npressure relieving, or a pressure limiting device where the maximum allowable operating pressure\n(MAOP) location changes, which for the Gulfstream Pipeline occurs at Mile Post (MP) 58.7 located\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 Gulfstream Natural Gas System, LLC is an interstate natural gas transmission pipeline system jointly owned by Williams\nand Enbridge and operated by Gulfstream Management & Operating Services, LLC (Gulfstream). The Gulfstream\nPipeline is a portion of the Gulfstream Natural Gas System as defined in the Purpose and Need section of this special\npermit.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 1 of 19\n\n<<<PAGE 2>>>\n\noffshore in the Gulf of Mexico. Section 192.619(a) requires a natural gas transmission pipeline\nMAOP to be based upon the lowest or the weakest pipeline component or test pressure.\nI. Purpose and Need:\nOn the condition that Gulfstream complies with the terms and conditions set forth below, this special\npermit waives compliance from 49 CFR 192.195(a) for OPP and 49 CFR 192.619(a) to allow\nutilization of a pressure gradient for pressure control upstream of a subsea mainline valve located at\nMP 58.7 on the Gulfstream Pipeline. The Gulfstream Pipeline is a 36-inch interstate natural gas\npipeline, 427.8 miles in length, routed from near Coden, Mobile County, Alabama, across the Gulf of\nMexico, to near Palmetto, Manatee County, Florida. The Gulfstream Pipeline also includes\nCompressor Station 4103 in Coden, Alabama and Compressor Station 4204 in Palmetto, Florida and\nall mainline valves, metering, flow control, and other components along the 427.8-mile ML 200\nPipeline.\nGulfstream’s principal purpose is to increase the amount of natural gas supplied to Florida. The\nGulfstream Project flow volume uprate consists of installing a new turbine compressor unit at\nGulfstream Pipeline’s Compressor Station 410, adding pressure safety controls, and replacing 3.9\nmiles of 36-inch diameter onshore pipeline with associated controls and appurtenances in Mobile\nCounty, Alabama, as required to meet a MAOP of 2,296 pounds per square inch gauge (psig). This\nadditional piping and equipment, when operational, will increase flow by approximately 78,000\ndekatherms per day5 through the existing 36-inch diameter pipeline, an approximate 6.5% volume\nincrease through the Gulfstream Pipeline.\nThis special permit allows Gulfstream to increase the operating pressure of the Gulfstream Pipeline\nfrom the current 2,180 psig MAOP to a new MAOP of 2,296 psig from MP 0.0 to MP 58.7\n(approximately 58.7 miles). This special permit allows Gulfstream to not install overpressure\n3 Gulfstream Pipeline’s Compressor Station 410 is an existing natural gas compressor station located in Mobile County near\nCoden, Alabama.\n4 Gulfstream Pipeline’s Compressor Station 420 is an existing natural gas compressor station located in Manatee County\nnear Palmetto, Florida.\n5 78,000 dekatherms per day is equivalent to 76.4 million standard cubic feet per day with a Heating Value ~1,020 British\nThermal Units per standard cubic feet (Btu/ft3).\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 2 of 19\n\n<<<PAGE 3>>>\n\ncontrol at MP 58.7. Gulfstream Pipeline MP 3.9 is located near the shoreline in Mobile County,\nAlabama and MP 58.7 is offshore in the Gulf of Mexico, Viosca Knoll, Block 82.\nII. Special Permit Segment and Inspection Area:\nMobile County, Alabama through the Gulf of Mexico-Outer Continental Shelf to Manatee\nCounty, Florida\nThis special permit applies to the special permit segment defined as follows using the Gulfstream\nPipeline survey station (SS) references:\n• Special permit segment — Onshore SS 205+47 (MP 3.9) to Offshore SS 2892+77 (MP 58.7).\no The Gulfstream Pipeline special permit segment begins in Mobile County, Alabama\napproximately 200 feet from the shoreline at approximate MP 3.9 (Onshore SS 205+47),\nenters the Gulf of Mexico in Alabama State waters and continues into Federal waters of\nthe Gulf of Mexico to approximate MP 58.7 (Offshore SS 2892+77) immediately\nupstream of the West Subsea Tie In (WSSTI) (MP 58.7 or MP 58.7 WSSTI).6 The\ngeneral location of the special permit segment is depicted in Attachment A - Gulfstream\nPipeline – Special Permit Segment Overview Map.\n• Special permit inspection area is defined to mean the area that extends 220 yards on each side\nof the centerline along approximately 427.8 miles of the 36-inch diameter Gulfstream ML 200\nPipeline from MP 0.0 to MP 427.8. The overall special permit inspection area includes the\nfollowing:\no Special permit inspection area A is from MP 0.0 through MP 3.9 Mainline Valve\n200-1 (MLV 200-1);\no Special permit segment is from MP 3.9 to MP 58.7 WSSTI; and\no Special permit inspection area B is from the upstream side of MP 58.7 WSSTI to MP\n427.8. MP 58.7 WSSTI mainline valves include 36-inch diameter MLV-200-2A,\nMLV-200-2B, and MLV-200-2C.\nAttachment B - Gulfstream Pipeline – Overview Map shows the 36-inch diameter Gulfstream Pipeline\nfrom Mobile County, Alabama through the Gulf of Mexico and to Manatee County, Florida.\n6 Gulfstream Pipeline MP 58.7 is where the 36-inch “West Subsea Tie In” mainline valves – MLV-200-2A, MLV-200-2B,\nand MLV-200-2C are located. Note, the Gulfstream special permit application of October 26, 2018, indicated the\nsubsea mainline valves were located at MP 59, but the Gulfstream pipeline drawings show their location at MP 58.7\nlocated offshore Alabama in Viosca Knoll, Block 82.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 3 of 19\n\n<<<PAGE 4>>>\n\nPHMSA grants this special permit based on the findings set forth in the “Special Permit Analysis and\nFindings” and “Final Environmental Assessment and Finding of No Significant Impact” documents,\nwhich can be read in their entirety in Docket No. PHMSA- 2018-0105 in the Federal Docket\nManagement System located on the internet at www.Regulations.gov.\nIII. Conditions:\nPHMSA grants this special permit to Gulfstream subject to Gulfstream implementing the following\nconditions on the Gulfstream Pipeline as detailed below: 7\n1. Operating Procedures and Documentation: All procedures, records, and documentation used\nfor implementing these special permit conditions must be included in the Gulfstream Pipeline\nOperations and Maintenance (O&M) Procedures to meet 49 CFR 192.605 and 49 CFR\n192.603(a) for the life of the special permit.\n2. Maximum Allowable Operating Pressure:\na) The pipe, fittings, flanges, fabrications, and other components upstream of and including\nMainline Valve 200-1 (MLV 200-1) in the special permit inspection area A must be\ndesigned, constructed, pressure tested, and operated at a MAOP of 2,296 psig to meet 49\nCFR Part 192.\nb) The special permit segment must be operated at or below an MAOP of 2,296 psig, using a\npressure gradient to 2,180 psig or below at MP 58.7.\nc) The special permit inspection area B must be operated at or below its MAOP of 2,180 psig.\nThe subsea mainline valves at MP 58.7 are ANSI 900 rated valves (2,180 psig) and are the\npressure rating change-over location for the MAOP. 8\nNote: For Conditions 2(a), (b) and (c) above, Attachment C - Gulfstream Pipeline –\nSpecial Permit – Operating Conditions and Attachment D - Gulfstream Pipeline – Special\nPermit – Operating Scenario show the MAOPs for different pipeline segments and\noperating pressures along the Gulfstream Pipeline.\n7 All special permit conditions that are applicable to the special permit inspection area are applicable to the special permit\nsegment, special permit inspection area A, and special permit inspection area B. Special permit conditions that are\napplicable to the individual special permit segment, special permit inspection area A, and special permit inspection\narea B are not applicable to the special permit inspection area.\n8 The minimum hydrostatic test pressure for the special permit segment and special permit inspection area was 2,879 psig.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 4 of 19\n\n<<<PAGE 5>>>\n\n3. Integrity Management Program:\na) The special permit inspection area must be included in the Gulfstream Pipeline written\nintegrity management program as a “covered segment” in a high consequence area in\naccordance with 49 CFR 192.903, except for the reporting requirements contained in 49 CFR\n192.945.\nb) Gulfstream must require in its O&M Procedures the usage of inline inspection (ILI) tools\nwithin the special permit inspection area for pipeline inspection and reassessments to meet\n49 CFR 192.917 for threats and 49 CFR 192.939 for reassessment intervals. Gulfstream\nmust use high resolution ILI tools that are capable of detecting features for the identified\nthreats.\n4. Flow Model Validation:\na) Gulfstream must complete the “Active” flow model validation and both the “Active” and\n“Operational” flow models must be installed and operating prior to uprating the MAOP of the\nGulfstream Pipeline. Attachment E - Gulfstream Pipeline Hydraulic Flow Modeling and\nOperator Training describes the “Active” and “Operational” models used for the pipeline\nsystem operation.\nb) Gulfstream must revalidate the “Active” model within six (6) months of the initial validation\nand then revalidate the model on an annual basis, not to exceed 15 months, based upon real-\ntime pressure and flow readings upstream and downstream of the Gulfstream Pipeline Station\n410 (located in Alabama) and upstream of Compressor Station 420 (located in Florida). If\nthe “Active” model results are over +/- 1% of actual operating pressures, Gulfstream must\ndecrease the operating pressure to 2,180 psig or below at MP 0. Before Gulfstream increases\nthe operating pressures, the “Active” model must be retuned and revalidated to show that the\nMAOP of 2,180 psig is not exceeded at MP 58.7. Gulfstream must maintain documentation\nof the “Active” model validation for the life of the special permit.\nc) Gulfstream must report to the Director, PHMSA Southern Region, the events with a monthly\nmaximum operating pressure over the 2,180 psig MAOP (based upon the “Active” model\ncalculations) at MP 58.7 or misalignment of the pressures (model versus actual pressures at\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 5 of 19\n\n<<<PAGE 6>>>\n\nMP 0.0 and MP 427.8) at MP 0.0, MP 58.7, or MP 427.8 for varying flow rates where the\nmaximum operating pressure at MP 58.7 can be exceeded. Gulfstream may be required to\nretune and revalidate the “Active” model, if requested by the Director, PHMSA Southern\nRegion.9\n5. Operator Training: Gulfstream must complete operator training for this special permit prior to\nuprating the Gulfstream Pipeline. Operator training must include training on normal operating\nconditions and upset conditions. All training must be in accordance with 49 CFR 192.631(h).\n6. Pipeline Pressure Control:\na) Gulfstream must install an active logic algorithm system for pressure control and a station\ncontrol panel to monitor pressures at Compressor Station 410 and Compressor Station 420\nwith real time modeling to ensure the pressure remains at or below 2,180 psig at MP 58.7\nWSSTI. Compressor Station 410 must be pressure controlled and monitored to not exceed\nthe uprated 2,296 psig MAOP in special permit inspection area A and the special permit\nsegment. Attachment E - Gulfstream Pipeline Hydraulic Flow Modeling and Operator\nTraining describes the requirements that must be followed for the active logic algorithm.\nb) The “Active” model must utilize real-time Gulfstream Pipeline pressures, temperatures, flow\nrates, and gas composition to provide a detailed picture of current operations. The “Active”\nmodel must continuously compute a pressure for MP 58.7 by reading real-time flow rates and\npressures at Compressor Station 410 and Compressor Station 420.\nc) If the “Active” model is not online, the discharge pressure at Compressor Station 410 must be\nmaintained at or below 2,180 psig. Gulfstream must maintain documentation of this changed\ncondition.\nd) The Gulfstream Pipeline must have an operational supervisory control and data acquisition\n(SCADA) system, 24-hours per day and 7-days per week, for the special permit inspection\narea to be operated over a 2,180 psig MAOP. The SCADA system must be operated in\naccordance with 49 CFR 192.631 and must receive pressure data from Compressor Station\n410, Compressor Station 420, incoming gas receipt pipelines, and outgoing gas delivery\npipelines. If the Gulfstream Pipeline SCADA system becomes non-operational, Gulfstream\nmust notify the Director, PHMSA Southern Region within 48 hours of the event or the next\n9 Upon notice by the Director, PHMSA Southern Region to Gulfstream, PHMSA may have the Gulfstream Pipeline\nassigned to another PHMSA Region.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 6 of 19\n\n<<<PAGE 7>>>\n\nworking day, and must provide 24-hour per day operational coverage or communications\nwith Compressor Station 410, Compressor Station 420, gas receipt points, and gas delivery\npoints for pipeline operating pressures.\ne) The Gas Control Center for the Gulfstream Pipeline must control pressures entering and\nleaving the special permit inspection area, so that the 2,180 psig MAOP at MP 58.7 and\nthroughout the special permit inspection area B will not be exceeded.\nf) In the event that the pressure reduction requirements in Condition 6 need to be modified for\nup to a seven (7) day interval due to the model or the SCADA system is out of service,\nGulfstream must send a notice letter to the Director, PHMSA Southern Region, stating the\nproposed modification, and must receive a letter of “no objection” from the Director,\nPHMSA Southern Region prior to the pressure reduction requirements being implemented by\nGulfstream.\n7. Overpressure Protection:\na) A minimum of two (2) OPP devices must be installed at Compressor Station 410 for any\ncompressor or pipeline flowing gas into the Gulfstream Pipeline.\nb) The Station or Pipeline Control Panel set points for compressors or pipelines flowing gas into\nthe Gulfstream Pipeline must be 2,321 psig or less to activate the emergency shutdown\ndevice (ESD), and a hard-wired ESD switch must be set at 2,341 psig or less.10 These ESDs\nmust ensure the Gulfstream Pipeline overpressure events remain below the allowable over-\npressure limit of 2,267 psig at MP 58.7. 11\nc) Gulfstream must conduct annual flow model validation that ensures the OPP set point at\nCompressor Station 410 maintains an OPP limit of 2,267 psig or less at MP 58.7.\nGulfstream must maintain documentation of the validation for the life of the special permit.\nd) Within six (6) months after installation of the Gulfstream Project to expand flow volumes,\nGulfstream must conduct 30 days of pressure monitoring at MP 58.7 WSSTI to confirm the\n“Active” flow model for modeling pressure gradients on the Gulfstream Pipeline. If less than\n30 days of pressure monitoring is conducted at MP 58.7 WSSTI, Gulfstream must obtain a\n10 OPP set points at Compressor Station 410 or pipelines flowing gas into the Gulfstream Pipeline must be 2,341 psig or\nless (2,296 psig times 1.02). Gulfstream must have flow models on the Gulfstream Pipeline to show that a 2,341 psig\nOPP at Compressor Station 410 will not overpressure MP 58.7 mainline valves beyond 2,267 psig.\n11 The OPP set point at MP 58.7 must not exceed 2,180 psig times 1.04 (MAOP times 1.04), which is 2,267 psig.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 7 of 19\n\n<<<PAGE 8>>>\n\nletter of “no objection” from the Director, PHMSA Southern Region. Gulfstream must\ndocument and submit the results to the Director, PHMSA Southern Region, within 60 days of\ncompletion of the pressure monitoring.\ne) Gulfstream must record the maximum operating pressures at MP 0.0 (Compressor Station 410\ndischarge side) and MP 427.8 (Compressor Station 420 suction side) for each month during\nthe year. The “Active” model pressure must be used to calculate the maximum pressures at\nMP 58.7, and either at MP 0.0 (Compressor Station 410 discharge side) or MP 427.8\n(Compressor Station 420 suction side) based upon the actual maximum operating pressures at\nthe other Compressor Station.\nNote: A monthly maximum operating pressure above the 2,180 psig MAOP (based upon the\n“Active” model calculations) experienced at the Gulfstream Pipeline MP 58.7 is an event that\nGulfstream must report to the Director, PHMSA Southern Region and may require Gulfstream\nto retune and revalidate the “Active” model, if requested by the Director, PHMSA Southern\nRegion, see Condition 4(b).\nf) In the future, if Gulfstream expands the Gulfstream Pipeline facilities beyond what has been\ncertificated by the Federal Energy Regulatory Commission in the Gulfstream Project\n(Purpose and Need section page 3), Gulfstream must contact the Director, PHMSA Southern\nRegion, to determine if pressure monitoring at MP 58.7 WSSTI is required to revalidate the\nmodel described in Attachment E - Gulfstream Hydraulic Flow Modeling and Operator\nTraining.\n8. Pipeline Operational Controls: During any possible upset operational conditions, Gulfstream\nmust install pipeline operational controls to temporarily reduce the 2,296 psig Compressor\nStation 410 discharge pressure to 2,180 psig, by shutting down the Unit 5 Booster Compressor.\nAny possible upset operational conditions are defined as follows:\na) In-line inspection or other pigging of the Gulfstream Pipeline;\nb) Compressor Station 410, Compressor Station 420, or any portion of the Gulfstream Pipeline\nthat lies between or falls within the 3-day “cone of uncertainty” for a track projection of a\nnamed tropical storm or hurricane identified by the National Hurricane Center. The “cone of\nuncertainty” represents the range of possibilities for the storm's center and extends up to five\ndays into the future;\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 8 of 19\n\n<<<PAGE 9>>>\n\nc) Disruption of flow into or out of Compressor Station 420 with any inadvertent or intentional\nmainline valve closure12 that may cause upstream pressure increases; or\nd) Extended low flow demand of 337 million cubic feet per day or less in Florida, lasting for 72-\nhours or more, caused by seasonal or abnormal conditions.\nShould any of the pressure reduction requirements in Condition 8 need to be modified for up to a\nseven (7) day interval, Gulfstream must send a notice letter stating the proposed modification to\nthe Director, PHMSA Southern Region, and must receive a letter of “no objection” from the\nDirector, PHMSA Southern Region, prior to Gulfstream implementing the modification.\n9. Pipeline Patrols and Surveys: Gulfstream must perform aerial patrols from the Gulfstream\nPipeline MP 0 to MP 58.7 in Alabama and from MP 406 (Egmont Key - Offshore SS 21438 +16)\nto MP 427.8 in Florida on a quarterly basis, not to exceed 75 days, in accordance with 49 CFR\n192.705.\n10. Annual Offshore Leakage Survey: Gulfstream must perform an offshore leakage survey by\naircraft from Gulfstream Pipeline MP 3.9 to MP 427.8 on an annual basis, not to exceed 15\nmonths, in accordance with 49 CFR 192.706.\n11. Shallow Water Surveys: Gulfstream must develop procedures for performing shallow water\ndepth of cover surveys and remediation based upon survey findings for the Gulfstream Pipeline.\nThe procedures must require shallow water depth of cover surveys a minimum of every five (5)\nyears, not to exceed 66 months, in accordance with 49 CFR 192.612.\n12. Annual Report to PHMSA: Annually,13 after the grant of this special permit, Gulfstream must\nsubmit an annual pipeline integrity report14 to the Director, PHMSA Southern Region, with a\ncopy to the Director, PHMSA Engineering and Research, summarizing any significant integrity\nthreats or pressure modeling issues and the following:\n12 Examples of inadvertent or intentional mainline valve closures that would disrupt flow and cause mainline pressures to\nincrease would be the closure of the 36-inch mainline valves, where the Gulfstream Pipeline reaches the Florida coast\nand would include the 36-inch diameter mainline valve MLV-200-10 located near the Florida Sunshine Skyway Bridge,\nthe 36-inch diameter mainline valve MLV-200-11 located where the pipeline comes onshore in Florida, and 36-inch\ndiameter mainline valve GF-200-S1 located at the inlet of Compressor Station 420 near the incoming pig receiver.\n13 Annual reports must be received by PHMSA by the last day of the month in which the special permit is dated. For example,\nthe annual report for a Special Permit dated July 2020, must be received by PHMSA no later than July 31, each year\nbeginning in 2021.\n14 Gulfstream must submit a copy of each Gulfstream Pipeline annual report on the PHMSA docket, PHMSA-2018-0105, at\nwww.Regulations.gov.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 9 of 19\n\n<<<PAGE 10>>>\n\na) Any new integrity threats identified during the previous year in the special permit inspection\narea, and the results of any ILI or direct assessments performed (including any un-remediated\nanomalies over 30% wall loss, cracking found in the pipe body, weld seam or girth welds, and\ndents with metal loss, cracking or stress riser) during the previous year in the special permit\ninspection area. Gulfstream must include the respective survey station and MP, failure\npressure ratio, anomaly depth and length, and class location;\nb) The maximum operating pressure reached at MP 0.0 (Compressor Station 410 discharge side)\nand MP 427.8 (Compressor Station 420 suction side) for each month during the year with the\ncorresponding “Active” flow model pressure at MP 58.7 based upon these maximum\noperating pressures at MP 0.0 and MP 427.8;\nc) Any reportable incident, any leak normally indicated on the DOT Annual Report, and all\nrepairs on the pipeline that occurred during the previous year in the special permit inspection\narea;\nd) Any on-going damage prevention initiatives affecting the special permit inspection area and a\ndiscussion of the success of the initiatives including findings and any remediation actions; and\ne) Any mergers, acquisitions, transfer of assets, or other events affecting the regulatory\nresponsibility of the company operating the pipeline.\n13. Certification: A Gulfstream senior executive officer, vice president or higher, must certify in\nwriting the following:\na) The special permit inspection area meets the conditions described in this special permit.\nb) The written manual of O&M Procedures required by 49 CFR 192.605 for the Gulfstream\nPipeline has been updated to include all requirements of this special permit; and\nc) Gulfstream has implemented all conditions required by this special permit, prior to uprating the\nspecial permit inspection area, for the Gulfstream Pipeline and any future special permit\ncondition requirements are included in the Gulfstream Pipeline O&M Procedures for future\nwork.\nWithin 60 days after installation of the Gulfstream Project, Gulfstream must send the certifications\nrequired in Condition 13(a) through (c) with special permit condition status and procedure\ncompletion date, compliance documentation summary, and the required senior executive signature\nand date of the signature to the PHMSA Associate Administrator for Pipeline Safety with copies to\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 10 of 19\n\n<<<PAGE 11>>>\n\nthe Director, PHMSA Southern Region; and to the Federal Register Docket (PHMSA-2018-0105)\nat www.Regulations.gov.\nIV. Limitations:\nThis special permit is subject to the limitations set forth in 49 CFR 190.341 as well as the following\nlimitations:\n1) PHMSA has the sole authority to make all determinations on whether Gulfstream has complied\nwith the specified conditions of this special permit. Failure to comply with any condition of this\nspecial permit may result in revocation of the permit.\n2) Any work plans and associated schedules for the special permit inspection area are\nautomatically incorporated into this special permit and are enforceable in the same manner.\n3) Failure by Gulfstream to submit the certifications required by Condition 13 (Certification)\nwithin the time frames specified may result in revocation of this special permit.\n4) As provided in 49 CFR 190.341, PHMSA may issue an enforcement action for failure to\ncomply with this special permit. The terms and conditions of any corrective action order,\ncompliance order or other order applicable to a pipeline facility covered by this special\npermit will take precedence over the terms of this special permit.\n5) If Gulfstream sells, merges, transfers, or otherwise disposes all or part of the assets known as\nthe Gulfstream Pipeline special permit segment, Gulfstream must provide PHMSA with\nwritten notice of the change within 30 days of the consummation date. In the event of such\ntransfer, PHMSA reserves the right to revoke, suspend, or modify the special permit if the\ntransfer constitutes a material change in conditions or circumstances underlying the permit.\n6) PHMSA grants this special permit to limit it to a term of no more than ten (10) years from the\ndate of issuance. If Gulfstream elects to seek renewal of this special permit, Gulfstream must\nsubmit its renewal request at least 180 days prior to expiration of the ten (10) year period to\nthe PHMSA Associate Administrator for Pipeline Safety with copies to the Director, PHMSA\nSouthern Region; and to the Director, PHMSA Engineering and Research. All requests for a\nrenewal must include a summary report in accordance with the requirements in Condition 12\n(Annual Report to PHMSA) above and must demonstrate that the special permit is still\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 11 of 19\n\n<<<PAGE 12>>>\n\nconsistent with pipeline safety. PHMSA may seek additional information from Gulfstream\nprior to granting any request for special permit renewal.\nAUTHORITY: 49 U.S.C. 60118 (c)(1) and 49 CFR 1.97.\nIssued in Washington, DC on May 19, 2020\nDigitally signed by ALAN\nALAN KRAMER\nKRAMER MAYBERRY\nMAYBERRY Date: 2020.05.19\n15:50:36 -04'00'\nAlan K. Mayberry,\nAssociate Administrator for Pipeline Safety\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 12 of 19\n\n<<<PAGE 13>>>\n\nAttachment A – Gulfstream Pipeline Special Permit Segment Overview Map\nNote: MP 59 on the above map is rounded for MP 58.7. MP 58.7 is in the Gulf of Mexico, Viosca\nKnoll, Block 82.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 13 of 19\n\n<<<PAGE 14>>>\n\nAttachment B – Gulfstream Pipeline - Overview Map\nNote: MP 59 on the above map is rounded for MP 58.7. MP 58.7 is in the Gulf of Mexico, Viosca\nKnoll, Block 82. Compressor Station 420 is at MP 427.8.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 14 of 19\n\n<<<PAGE 15>>>\n\nAttachment C - Gulfstream Pipeline – Special Permit – Operating Conditions\nNote: MP 59 on the above map is rounded for MP 58.7. MP 58.7 is in the Gulf of Mexico,\nViosca Knoll, Block 82. Compressor Station 420 is at MP 427.8.\nAttachment D - Gulfstream Pipeline – Special Permit – Operating Scenario\nNote: MP 59 on the above map is rounded for MP 58.7. MP 58.7 is in the Gulf of Mexico,\nViosca Knoll, Block 82. Compressor Station 420 is at MP 427.8.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 15 of 19\n\n<<<PAGE 16>>>\n\nAttachment E - Gulfstream Hydraulic Flow Modeling and Operator Training\nE.1 Gulfstream Transient Model\nThe “Transient” model is a proven hydraulic model (model) used for planning system operating\npressures. It will be used to set-up the “Active” model to calculate the pressure at MP 58.7 where the\ndownstream specification break occurs from 2,296 psig to 2,180 psig MAOP. Based on these model\ncalculations, using the most conservative expected operating conditions, the MAOP at MP 58.7 must\nnot exceed 2,180 psig during operating flow conditions. The Gulfstream Pipeline controlling\npressure set points established at Compressor Station 410 discharge side must provide pressure\nprotection of the 2,296 psig MAOP for the special permit segment and must prevent any pressure\nexcursion above 2,180 psig at or downstream of MP 58.7 (special permit inspection area B).\nThe “Transient” model is an industry-leading software used for single phase transient modeling. It\noffers the user the ability to match real world hydraulics by utilizing pipeline characteristics along\nwith written code to mimic virtually any single-phase fluid system. Williams15 has successfully\nmodeled every liquid pipeline system that Williams owns and/or operates, including the Gulfstream\nPipeline and has tuned these systems to a high degree of accuracy. Although there are multiple\nsoftware products used for gas pipeline modeling, Williams’ experience with the “Transient” model\nis that it is capable of modeling gas systems with the same efficacy as liquid systems.\nThe “Transient” model typically contains more detail than the “Active” model. This is due to the\nneed of the “Transient” model to provide control and ESD set points for the system to prevent over\npressuring any segment. Compressor details, ESD valve set points, and control valve logic are all\ncoded to ensure the model behaves the same as reality.\nNormal and abnormal operations are simulated, and set points are provided, to estimate system\ncapacity and mitigate conservative surge scenario situations, respectively. Conservative surge\nscenarios are blockages that occur faster than one second (considered instantaneous in most cases) at\nlocations where ESD valves or control valves exist. For special areas of interest, these blockages can\nbe placed a mile or so downstream of MP 58.7 to simulate a stuck pig that blocks 100% of the flow\nrate. Conservative scenarios also consider inadvertent compressor station shutdowns.\nE.2 Gulfstream Active Model16\nThe “Active” model software utilizes the PipelineManager™ program as developed by Energy-\nSolutions, Inc. under Emerson Automation Solutions. PipelineManager™ is the industry-leading\nsolution for real-time pipeline monitoring for liquids and gas pipelines. It offers multiple leak\ndetection technologies to find anything from leaks to ruptures. The “Active” model utilizes real-time\npressure, temperature, flow rates and fluid composition to provide a detailed picture of current\noperations.\n15 Williams’ gas control center conducts flow and pressure control functions on the Gulfstream Pipeline.\n16 If a modification to the “Active” model is required, Gulfstream must notify the Director, PHMSA Southern Region within\nfive (5) working days of the modification.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 16 of 19\n\n<<<PAGE 17>>>\n\nAn algorithm based on the “Active” model will be running in the Williams Pipeline Control for\nGulfstream (Pipeline Control) and communicating with the SCADA system. The algorithm will\ncontinuously calculate the pressure at MP 58.7. The SCADA system will send the calculated value\nof this pressure to the Station Programmable Logic Controller, which can be viewed as a\ncontinuously updated reference value. This value will also be used for alarm purposes back to\nPipeline Control. Pipeline Control will monitor the pressure calculated by the model algorithm and\nthe SCADA system will trigger an alarm if the calculated pressure at MP 58.7 approaches 2,180 psig,\nallowing the operator to take appropriate actions to reduce the current set point of the booster\ncompressor accordingly to avoid an overpressure scenario.\nThe “Active” model has been tuned using two (2) weeks of archived SCADA data for all available\nmetering and field transmitters. The software will run and verify model-calculated pressures with\nactual pipeline pressures via SCADA and pressure recorder values. The model must be fine-tuned by\nconducting a statistical analysis of the difference between model calculated pressures and actual\npressures.\nCombining the use of “Transient” and “Active” models will provide more protection over and above\nthe existing regulatory requirements.\nE.3 Operational Model\nThe System Planning Operations group was tasked with tuning of the “Operational” model for\nGulfstream. For this purpose, the model was curtailed to the Gulfstream Pipeline offshore portion\nbetween Compressor Station 410 and Compressor Station 420.\nFirst the offshore pipeline “Operational” model was aligned with geographic information system\n(GIS) data for pipe lengths, pipe diameter, pipe wall thickness, elevations and valve locations and\nverified for accuracy. Then the Gulfstream Pipeline offshore pipe ambient temperature profiles were\nset up using the following third-party technical reports and papers:\n• Analyses of near bottom temperatures near the Gulfstream Pipeline by Robert H. Weisberg,\nProfessor of Physical Oceanography, University of South Florida and Lianyuan Zheng, Ph.D.,\nSenior Associate in Research.\n• PSIG 1212 - Tuning of Subsea Pipeline Models to Optimize Simulation Accuracy.\nNext, the hourly average data was gathered from SCADA using the process history database and\nfrom measurement using the Flow Cal database for the 2017 calendar year. From SCADA, pressure\nand temperature data was pulled at the discharge side of Compressor Station 410, and suction side of\nCompressor Station 420 and at the Bartow Meter Station. Line pack data was gathered for all Pipes\nin Florida downstream of Compressor Station 420. From measurement, the inlet and outlet gas flows\nwere gathered at all meter stations in Florida downstream of Compressor Station 420 and at the\nBartow Meter Station.\nThe “Operational” model was developed using the Compressor Station 410 delivery pressure and\ntemperature, the delivery flow at Bartow and the netted flow through Compressor Station 420. The\nmodel was run for the entire year, but the focus was kept on the summer months when Gulfstream\nexperiences higher flow rates.\nPHMSA-2018-0105 - Gulfstream Management & Operating Services, LLC Special Permit – Usage of Pressure Gradient\nPage 17 of 19\n\n<<<PAGE 18>>>\n\nAfter each run the model calculated pressure and temperature at Compressor Station 420 and Bartow\nmeter station were compared with the respective SCADA data using standard deviations. The\npipeline roughness and thermal conductivity was adjusted, and the model was run again. This\niterative process was repeated until the pipe roughness and heat transfer were adjusted to align the\nmodel calculated pressure and temperature with SCADA pressure and temperature accordingly.\nThe Gulfstream Pipeline roughness was adjusted from 350 to 175 micro inches while the heat\ntransfer coefficient was adjusted from 0.50 to 1.25 Btu/hr-ft2\n-degree Fahrenheit. By completing this\nprocess, the “Operational” model was fine-tuned to improve accuracy.\nE.4 Operator Training System:\nThe Operator Training System (OTS) ","truncated":true,"body_characters":42681}