{"operation":"document","citation":"PHMSA-2019-0202","title":"Columbia Gas TC — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2023-06-30","effective_on":"2023-06-30","summary":"PHMSA-2019-0202, issued 2023-06-30 for Columbia Gas TC's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2019-0202.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2019-0202.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2019-0202","source_url":"https://www.regulations.gov/docket/PHMSA-2019-0202","body":"PHMSA pipeline special permit PHMSA-2019-0202. Operator: Columbia Gas TC. System: Gas Transmission. Issue date: 2023-06-30.\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-2019-02021,2\nRequested By: Columbia Gas Transmission, LLC\nOperator ID#: 2616\nOriginal Date Requested: October 15, 2019\nOriginal Issuance Date: March 31, 2022\nAmended Date: June 30, 2023\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),\n3 provides this information to describe the facts of the subject special permit amendment\napplication submitted by Columbia Gas Transmission, LLC (TCO),\n4 to discuss any relevant public\ncomments received with respect to the application, to present the engineering and safety analysis\nof the special permit application, and to make findings regarding whether the requested special\npermit should be granted and, if so, under what conditions. TCO requested that PHMSA waive\n1 On June 22, 2022, TCO requested the addition of two (2) special permit segments 5 and 6 to its existing special\npermit. On November 30, 2022, TCO requested the addition of one (1) special permit segment 7. These segments\nare shown in Table 1 – Special Permit Segments\n2 PHMSA published the special permit request in the Federal Register (87 FR 50691) for a 30-day public comment\nperiod from August 17, 2022, through September 16, 2022, for special permit segments 5 and 6. On January 5,\n2023, PHMSA posted a notice of this special permit request for special permit segment 7, in the Federal Register\n(88 FR 908) to Docket No. PHMSA-2022-0166 with a closing date of February 6, 2023. Special permit segments\n5, 6, and 7 have been included into special permit docket 2019-0202.\n3 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of\nTransportation’s Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety.\n4 TCO is a wholly owned, subsidiary of TC Energy.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 1 of 12\n\n<<<PAGE 2>>>\n\ncompliance from the 49 Code of Federal Regulations (CFR) 192.611(a) and (d) and 192.619(a) for\nnatural gas transmission pipeline segments, where the class location has changed from a Class 1 to\na Class 3 location.\nPipeline System Affected:\nThis amendment of the special permit applies to the TCO request for a waiver from the class\nlocation change requirements in 49 CFR 192.611(a) and (d) and 192.619(a) for 3,101 feet\n(approximately 0.587 miles) of the 30-inch diameter gas transmission Line MC - Line VC Pipeline\nlocated in Montgomery County, Maryland; and Loudoun County, Virginia. Without this special\npermit, 49 CFR 192.611(a) would require TCO to replace the three (3) special permit segments\nwith stronger pipe or reduce the pipeline maximum allowable operating pressure (MAOP) for a\nClass 1 to Class 3 location change.\nPipe specifications including outside diameter, year installed, seam type, coating type, pipe grade,\nwall thickness, MAOP, minimum pressure test pressure, and pressure test factor based on the\nminimum test pressure are detailed in Table 1 – Pipe Specifications by Line Name.\nTable 1 – Pipe Specifications by Line Name\nOutside\nMin. Test\nLine\nDiameter\nYear Installed Name\nSeam\nType Coating Type Grade Wall Thickness\n(inches)\nMAOP\nPressure\nPressure\n(psig)\nTest Factor\n(inches)\n(psig)\nMC/VC 30 1962 DSAW Asphalt X60 0.312 898 1,146 1.28\nNote: DSAW is double submerged arc welded seam pipe.\nSpecial Permit Request:\nOn June 22, 2022, and November 30, 2022, TCO applied to PHMSA for an amendment to its\nspecial permit seeking relief from 49 CFR 192.611(a) and (d) and 192.619(a) for the below listed\nspecial permit segments, where a class location change occurred from the original Class 1 to a\nClass 3 on the 30-inch diameter Line MC - Line VC Pipeline located in Montgomery County,\nMaryland; and Loudoun County, Virginia.\nSpecial Permit Segments:\nThis special permit applies to the special permit segments in Table 2 – Special Permit\nSegments.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 2 of 12\n\n<<<PAGE 3>>>\n\nTable 2 – Special Permit Segments\nSpecial\nOutside\nPermit\nLine\nDiameter\nName\nLength\n(feet)\nStart Survey\nStation (SS)\nEnd Survey\nStation (SS)\nCounty or Parish,\nState\nNo.\nYear\nSeam\nMAOP\nSegment\nNumber\nDwellings\nInstalled\nType\n(psig)\n(inches)\n5 30 Line VC 481 361+50 366+31 Loudoun, VA 3 1962 DSAW 898\n6 30 Line MC 1,169 858+09 869+78 Montgomery, MD 2 1962 DSAW 898\n7 30 Line MC 1,450 244+00 258+50 Montgomery, MD 3 1962 DSAW 898\nNote: DSAW is double submerged arc welded seam pipe.\nSpecial Permit Inspection Area:\nThe special permit inspection area is defined as the area that extends 220 yards on each side of the\ncenterline as listed in Table 3 – Special Permit Inspection Area.\nTable 3 – Special Permit Inspection Area\nSpecial\nSpecial Permit\nOutside\nStart Survey\nPermit\nEnd Survey Station\nLength5\nInspection\nDiameter\nLine Name\nStation\nSegment(s)\n(SS)\n(miles)\nArea Number\n(inches)\n(SS)\nIncluded\n1 1, 2, 3, 4, 5,\n6, and 7 30 Line VC - Line MC 0+00 (Line VC) 1603+78 (Line MC) 40.5\nPublic Notice:\nOn August 17, 2022, PHMSA posted a notice of this special permit request in the Federal Register\n(87 FR 50691) for special permit segments 5 and 6, with a closing date of September 16, 2022.\nPHMSA received no public comments concerning this special permit amendment. On January 5,\n2023, PHMSA posted a notice of this special permit request for special permit segment 7, in the\nFederal Register (88 FR 908) to Docket No. PHMSA-2022-0166 with a closing date of February 6,\n2023. PHMSA received public comment on the November 30, 2022, request and is addressing the\ncomment received concerning this special permit amendment in the Final Environmental\nAssessment (FEA) and Finding of No Significant Impact (FONSI).\nThe TCO special permit amendment application letter, Federal Register notice, Special Permit,\nFEA and FONSI, and all other pertinent documents are available for review in Docket No.\n5 If the special permit inspection area footage does not extent from launcher to receiver then the special permit\ninspection area would need to be extended.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 3 of 12\n\n<<<PAGE 4>>>\n\nPHMSA-2019-0202 in the Federal Docket Management System (FDMS) located on the internet at\nwww.Regulations.gov.\nAnalysis:\nBackground: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the\ncriteria it uses for the consideration of applications for class location change waivers, now being\ngranted or denied through a special permit. First, certain threshold requirements should be met on\na pipeline special permit segment for a class location change special permit to be granted. Second,\nthe age and manufacturing process of the pipe; system design, and construction; environmental,\noperating, and maintenance histories; and integrity management program elements are evaluated as\nsignificant criteria. These significant criteria are presented in matrix form and can be reviewed in\nthe FDMS, Docket No. PHMSA–RSPA-2004-17401. Third, special permits will only be granted\nwhen pipe conditions and active integrity management provides a level of safety greater than or\nequal to a pipe replacement or pressure reduction. The operator’s federal pipeline safety regulation\ncompliance history is also evaluated as part of the criteria matrix for acceptability prior to issuance\nof a special permit.\nThreshold Requirements: Each of the threshold requirements published by PHMSA in the June\n29, 2004, Federal Register notice is discussed below for the TCO special permit request.\n1) No pipeline segments in a class location changing to Class 4 location will be considered.\n• This special permit request is for special permit segments on the TCO 30-inch diameter\nLine MC – Line VC Pipeline, where a change has occurred from a Class 1 location to a\nClass 3 location.\n• TCO meets this requirement.\n2) No bare pipe will be considered.\n• The TCO special permit segments are externally coated with asphalt enamel.\n• TCO has not reported any coating issues such as disbonded coating.\n• TCO meets this requirement.\n3) No pipe containing wrinkle bends will be considered.\n• There are no wrinkle bends in the special permit segments.\n• TCO meets this requirement.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 4 of 12\n\n<<<PAGE 5>>>\n\n4) No pipe segments operating above 72% of the specified minimum yield strength (SMYS) will\nbe considered for a Class 3 special permit.\n• The special permit segments operate at or below 72% SMYS.\n• TCO meets this requirement.\n5) Records must be produced that show a hydrostatic test to at least 1.25 x MAOP and 90% of\nSMYS.\n• The special permit segments on the Line MC – Line VC Pipeline was tested to at least\n1.28 times the MAOP.\n• TCO meets this requirement.\n6) Inline inspection (ILI) must have been performed with no significant anomalies identified that\nindicate systemic problems such as stress corrosion cracking (SCC).\n• TCO ran ILI tools on the Line MC – Line VC Pipeline in 2019 in the special permit\ninspection area.\n• TCO has not found any SCC indications in or within 20 miles of the special permit\nsegment.\n• TCO meets this requirement.\n7) Criteria for consideration of a class location change waiver, being considered through the\nspecial permit, published by PHMSA in the Federal Register (69 FR 38948), define a waiver\ninspection area (special permit inspection area) as up to 25 miles of pipe on either side of the\nwaiver segment (special permit segment).\n• A special permit would be contingent upon TCO’s incorporation of the special permit\nsegments in its written integrity management program as covered segments in a high\nconsequence area (HCA) in accordance with 49 CFR 192.903 and to assess and\nremediate threats to the special permit inspection area.\n• TCO’s defined special permit inspection area is 40.5 miles in length.\nCriteria Matrix: The data submitted by TCO for the special permit segments has been compared\nto the class location change special permit criteria matrix. The data fall within the probable\nacceptance or the possible acceptance column of the criteria matrix, except for PHMSA\nenforcement findings which fall under the requires substantial justification.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 5 of 12\n\n<<<PAGE 6>>>\n\n• The special permit segments fall in the probable acceptance column of the criteria\nmatrix for:\no Design stress, pipe material, depth of pipe cover, test pressure, test failures, type\nservice, pressure fluctuations, safety related conditions, leaks and failures, direct\nassessment, ILI type, ILI program, and damage prevention program.\n• The special permit segments fall in the possible acceptance column of the criteria matrix\nfor:\no Class 1 to 3 location, pipe manufacturer, pipe coating type (may shield cathodic\nprotection (CP)), local geology, CP, and HCA program.\n• The special permit segments fall in the requires substantial justification column of the\ncriteria matrix for:\no TCO has identified issues in girth welds within the special permit segments and\npipe girth weld records are not available. TCO will complete Special Permit\nCondition 6 – Girth Welds;\no The coating type may shield CP when disbonded, causing SCC.\n6 TCO will\ncomplete Special Permit Condition 7 – Stress Corrosion Cracking Threat; and\no Inspection findings (Enforcement History) – PHMSA enforcements are in the “Past\nEnforcement History – January 1, 2011 through September 30, 2022” section\nbelow.\nOperational Integrity Compliance:\nTo inform PHMSA’s decision about whether a special permit could provide a level of safety\ngreater than or equal to a pipe replacement or pressure reduction and is consistent with pipeline\nsafety, PHMSA reviewed this special permit request to understand the known type of integrity\nthreats that are in the special permit segments and special permit inspection area. This integrity\ninformation was used to design special permit conditions to provide a systematic program to\nreview and remediate the pipeline for safety concerns. Additional operational integrity review and\nremediation requirements are required by this special permit to ensure that the operator has an\nongoing program to locate and remediate safety threats. These threats to integrity and safety\n6 Two (2) types of SCC are found on pipelines: High pH (9 to 11) SCC and near-neutral pH (6 to 8) SCC. Coal tar\nand asphalt coatings that are disbonded are more prone to having SCC.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 6 of 12\n\n<<<PAGE 7>>>\n\ninclude any issues with the pipe coating quality, CP effectiveness, operations damage prevention\nprogram, pipe depth of soil cover, weld seam and girth weld integrity, anomalies in the pipe steel\nand welds, and material and structures either along or near the pipeline that could cause the CP\nsystem to be ineffective. PHMSA has carefully designed a comprehensive set of conditions that\nTCO must implement to comply with this special permit.\nPast Enforcement History – January 1, 2012 through January 22, 2023:\nFrom January 1, 2012, through January 22, 2023, TCO was cited in forty-four (44) enforcement\nactions with a total of $2,167,004 in assessed civil penalties. PHMSA initiated one (1) Corrective\nAction Order, eleven (11) Notices of Amendment, fifteen (15) Notices of Probable Violation, two\n(2) Safety Orders, and fifteen (15) Warnings Letter against TCO. TC Energy acquired TCO in\n2016. Since TC Energy became owner of TCO, PHMSA has issued five (5) Notice of\nAmendments, three (3) Notice of Probable Violations, one (1) Safety Order, and twelve (12)\nWarning Letters with a total of $1,529,904 in collected penalties to TC Energy on the TCO\npipeline system.\nTables 4 and 5 below show PHMSA enforcement actions and civil penalties for TCO:\nTable 4: TCO Enforcement Matters from January 1, 2012 through January 22, 2023\nNotice of\nStatus Corrective\nAction Order\nNotice of\nSafety\nProbable\nAmendment\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 1 11 13 2 15 42\nOPEN 0 0 2 0 0 2\nTotal 1 11 15 2 15 44\nTable 5: TCO Enforcement Civil Penalty Status\nJanuary 1, 2012 through January 22, 2023\nProposed Awaiting\nOrder Assessed Withdrawn/Reduced Collected\n$2,293,804 $0 $2,167,004 $100,400 $2,167,004\nSummary of Enforcement Findings for TCO includes:\n• Construction: Compliance with specifications or standards, Repair of Steel Pipe, General\nInspection, and Installation of Pipe in a Ditch; Control Room Management: Alarm\nManagement, Compliance and Deviations, Fatigue Mitigation, SCADA System Limitations,\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 7 of 12\n\n<<<PAGE 8>>>\n\nProvide Adequate Information, and Training Procedures; Atmospheric Corrosion Control:\nGeneral and Monitoring; Corrosion Control: Corrosion Control Records; External\nCorrosion Control: Buried Pipe Post 1971, Interference Currents, and Monitoring; Design:\nCompressor Stations Additional safety equipment and Supports and Anchors; Enforcement\nProcedures: Inspections and Investigations; Integrity Management (IM): Elements and\nImplementation, Preventative and Mitigative Measures, and HCA Identification; OME\nProcedural Manual: Abnormal Operations, General, and Maintenance and normal operations;\nMaintenance: General, Line Markers, Pressure Limiting and Regulating Stations, Prevention\nof Accidental Ignition, Patrolling, Record keeping, and Leak Surveys; Operations: Alternative\nMAOP, Emergency Plans, General, MAOP-Steel or Plastic, and Procedures; Operator\nQualification: Qualification Program; Reporting: Filing Safety Related Condition Report\n(SRCR) and GTGG Annual Reports; Test Requirements: General and SMYS > 30% (at or\nabove the test pressure for at least 8 hours); Gas Transportation: Class Locations, Gathering\nLine Requirements, and Underground natural gas storage facilities; Welding: Inspection and\nTest of Welds.\n• 49 CFR 190.203, 191.17, 191.22, 191.25, 192.5, 192.9, 192.12, 192.161, 192.171, 192.241,\n192.303, 192.305, 192.309, 192.319, 192.455, 192.465, 192.473, 192.479, 192.481, 192.491,\n192.503, 192.505, 192.603, 192.605, 192.615, 192.619, 192.620, 192.631, 192.703, 192.705,\n192.706, 192.707, 192.709, 192.743, 192.805, 192.905, 192.907, and 192.935.\nTable 6 below shows PHMSA’s enforcement actions and civil penalties for TCO and the specific 49\nCFR Parts 191 and 192 violations:\nTable 6: Summary of Enforcement Findings from TCO\nJanuary 1, 2012 to January 22, 2023\nNotice of Amendment\nConstruction 1 Control Room Management 13 Integrity Management 1\nOME Procedural Manual 4 Operation and/or Maintenance 7 Operator Qualification 2\nTransportation of Gas 10\nNotice of Amendment Total: 38\nNotice of Probable Violation\nConstruction 2 Corrosion Control 9 Design 1\nFire Protection 1 Integrity Management 1 OME Procedural Manual 4\nOperation and/or\nMaintenance 5 Reporting 2 Test Requirements 1\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 8 of 12\n\n<<<PAGE 9>>>\n\nTransportation of Gas 1 Welding of Steel in Pipelines 1\nNotice of Probable Violation Total: 28\nWarning Letter\nCorrosion Control 2 Design 1 Enforcement and\nRegulatory Procedures 1\nOME Procedural Manual 6 Operation and/or Maintenance 13 Reporting 3\nTransportation of Gas 3\nWarning Letter Total: 27\nGrand Total: 93\nSummary of Enforcement Findings for TC Energy – ANR, CGT, GLGTC, PNGTS, and\nTCO:\nFrom January 1, 2012 through January 22, 2023, TC Energy, the operator of PNGTS, was cited in\n73 enforcement actions with a total of $2,978,004 in assessed civil penalties on its ANR Pipeline\nCompany (ANR) (OPID 405), Columbia Gulf Transmission (CGT) (OPID 2620), Columbia Gas\nTransmission (TCO) (OPID 2616), Great Lakes Gas Transmission Company (GLGTC) (OPID\n6660), and Portland Natural Gas System (PNGTS) (OPID 31145) pipeline systems. PHMSA\nissued three (3) Corrective Action Orders, 18 Notices of Amendment, 24 Notices of Probable\nViolation, two (2) Safety Orders and 26 Warning Letters to TC Energy.\nTables 7 and 8 below show PHMSA’s enforcement actions and civil penalties for TC Energy on\nthese pipeline systems – ANR, CGT, TCO, GLGTC, and PNGTS pipeline systems.\nTable 7: TC Energy Enforcement Matters from\nJanuary 1, 2012 through January 22, 2023\nNotice of\nStatus Corrective\nAction Order\nNotice of\nSafety\nProbable\nAmendment\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 3 18 22 2 26 71\nOPEN - - 2 - - 2\nTotal 3 18 24 2 26 73\nTable 8: TC Energy Enforcement Civil Penalty Status\nJanuary 1, 2012 through January 22, 2023\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$3,161,004 $0 $2,978,004 $156,600 $2,978,004\nThe type of 49 CFR Part 192 enforcement violations against TC Energy on these five (5) pipeline\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 9 of 12\n\n<<<PAGE 10>>>\n\nsystems from January 1, 2012 through January 22, 2023 were as follows:\nSummary of Enforcement Endings for ANR, CGT, TCO, GLGTC, and PNGTS includes:\nConstruction: Compliance with specifications or standards, General Inspection, Installation of\nPipe in a Ditch; Control Room Management: Alarm Management, Compliance and Deviations,\nFatigue Mitigation, Provide Adequate Information (Point to Point Checks), Roles &\nResponsibilities, SCADA System Limitations, Training, and Training Procedures; Atmospheric\nCorrosion Control: General and Monitoring; Corrosion Control: Corrosion Control Records;\nExternal Corrosion Control: Buried Pipe Post 1971, Interference Currents, Monitoring, and Test\nLeads; Design: Compressor Station Design & Construction, Compressor Stations Additional\nSafety Equipment, Compressor Stations Emergency Shutdown, and Supports and Anchors; Drug\nand Alcohol: Alcohol Tests Required and Drug Testing Required; Enforcement Procedures:\nInspections and Investigations, IM: Addressing Integrity Issues, Elements and Implementation,\nChange to IM Plan, HCA Identification, Preventative and Mitigative Measures, Program Elements,\nand Requirements for SCCDA; OME Procedural Manual: General, Maintenance and normal\noperations, Abnormal operations, Alternative MAOP, and SRCR; Maintenance: Abandonment or\nDeactivation of Facilities, Compressor Stations-Gas Detection, Compressor stations-inspection and\ntesting of relief devices, Compressor stations-Storage of Combustible Materials, General, Line\nMarkers, Pressure Limiting and Regulating Stations-Inspection and Testing, Pressure Limiting and\nRegulating Stations-Relief Devices, Prevention of Accidental Ignition, Procedures, Remedial\nMeasures, Patrolling, Record keeping, Repair Procedures, and Valve Maintenance Transmission\nLines; Operations: Change in Class Location (Required Study), Emergency Plans, General,\nMAOP-Steel or Plastic, Odorization of Gas, Procedures, Transfer Procedures, and Underwater\nInspection to Identify Gulf of Mexico Pipeline Hazards; Operator Qualification: Qualification\nProgram; Public Awareness: Activities for advising affected municipalities, Comprehensive\nMedia, Develop and Implement Public Awareness, Justification for not following API RP 1162,\nSpecifics addressing the Public; Reporting: Filing SRCR, Annual Reports, Immediate Reporting\nIncident, and National Registry of Pipeline and LNG Operators; Test Requirements: General;\nGas Transportation: Class Locations, Gathering Line Requirements, Underground Natural Gas\nStorage Facilities; Welding: Inspection and Test of Welds, Procedures, and Qualification of\nWelders,\n• 49 CFR 190.203, 191.3, 191.5, 191.15, 191.17, 191.22, 191.25, 192.5, 192.9, 192.12,\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 10 of 12\n\n<<<PAGE 11>>>\n\n192.161, 192.163, 192.167, 192.171, 192.201, 192.225, 192.241, 192.303, 192.305, 192.309,\n192.319, 192.455, 192.465, 192.471, 192.473, 192.479, 192.481, 192.491, 192.603, 192.605,\n192.609, 192.612, 192.615, 192.616, 192.619, 192.625, 192.631, 192.703, 192.705, 192.707,\n192.709, 192.727, 192.731, 192.735, 192.736, 192.739, 192.743, 192.745, 192.751, 192.805,\n192.905, 192.907, 192.909, 192.911, 192.933, and 192.935.\nTable 9 below gives a complete summary of the findings and the specific 49 CFR Part 191 and\n192 violation:\nTable 9: Summary of Enforcement Findings for\nANR, TCO, CGT, GLGT, and PNGTS\nJanuary 1, 2012 through January 22, 2023\nNotice of Amendment\nConstruction 1 Control Room Management 16 Integrity Management 5\nOME Procedural Manual 9 Operation and/or Maintenance 7 Operator Qualification 2\nPublic Awareness 6 Transportation of Gas 10 Welding of Steel in Pipelines 1\nNotice of Amendment Total: 57\nNotice of Probable Violation\nConstruction 2 Corrosion Control 11 Design 3\nDrug and Alcohol 2 Integrity Management 6 OME Procedural Manual 6\nOperation and/or Maintenance 16 Public Awareness 1 Reporting 8\nTest Requirements 1 Transportation of Gas 1 Welding of Steel in Pipelines 1\nNotice of Probable Violation Total: 58\nWarning Letter\nControl Room Management 5 Corrosion Control 4 Design 2\nEnforcement and Regulatory\nProcedures 1 Integrity Management 2 OME Procedural Manual 11\nOperation and/or Maintenance 19 Operator Qualification 1 Reporting 8\nTransportation of Gas 5 Welding of Steel in Pipelines 1\nWarning Letter Total: 59\nGrand Total: 174\nFindings:\nBased on the information submitted by TCO and PHMSA’s analysis of the technical, operational,\nand safety issues, PHMSA finds that granting this special permit to TCO to operate special permit\nsegments on the 30-inch diameter Line MC – Line VC Pipeline located in Montgomery County,\nMaryland, and Loudoun County, Virginia is consistent with pipeline safety.\nPHMSA has designed special permit conditions to effectively assess and remediate threats to the\nspecial permit segments and special permit inspection area, including assessments to evaluate\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 11 of 12\n\n<<<PAGE 12>>>\n\npipe girth welds that have not been non-destructively tested and for SCC. To ensure TCO properly\nimplements the special permit conditions, TCO will be required to give PHMSA an annual review\nof their compliance with the special permit.\nPHMSA finds that no significant negative impact to human safety and the environment will result\nfrom the issuance and full implementation of this amendment of a special permit that waives the\nrequirements of 49 CFR 192.611 for class location changes from Class 1 to a Class 3 location.\nThis permit amendment requires TCO to implement the special permit conditions that include\nsafety requirements on the operations, maintenance, and integrity management of the special\npermit segments and the special permit inspection area.\nCompleted in Washington DC on: June 30, 2023\nPrepared by: PHMSA - Engineering and Research Division\nFinal Page of the Special Permit Analysis and Findings\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland and Virginia\nPage 12 of 12\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nJune 30, 2023\nStanley Chapman\nExecutive VP and President of U.S. Natural Gas Pipelines\nTC Energy\n700 Louisiana Street, Suite 300\nHouston, Texas 77002\nRe: Docket No. PHMSA-2019-0202\nSpecial Permit from March 31, 2022, to March 31, 2032\nDear Mr. Chapman:\nOn June 22, 2022, and November 30, 2022, pursuant to 49 Code of Federal Regulations (CFR)\n§ 190.341, Columbia Gas Transmission, LLC (TCO)1 applied to the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) for a special permit. TCO requested to amend the\npreviously granted special permit at Docket No. PHMSA 2019-0202 to waive compliance with\n49 CFR §§ 192.611(a) and (d) and 192.619(a) for Class 1 to Class 3 location changes for an\nadditional 0.587 miles of the 30-inch diameter Line MC – Line VC pipeline (Pipeline). The\nPipeline is located in Montgomery County, Maryland, and Loudoun County, 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 August 17, 2022, PHMSA published a Federal Register notice (87 FR 50691) announcing the\nSpecial Permit Request for Docket No. PHMSA-2019-0202. On January 5, 2023, PHMSA\npublished an additional Federal Register notice (88 FR 908) for the second request under\nseparate Docket No. PHMSA-2022-0166. The Special Permit Request letter, Final\nEnvironmental Assessment (FEA) and Finding of No Significant Impact (FONSI), Special\nPermit Analysis and Findings (SPAF), and all other pertinent documents for this special permit\nhave been combined and are available in Docket No. PHMSA-2019-0202 in the Federal Docket\n1 Columbia Gas Transmission, LLC is a subsidiary of TC Energy.\n\n<<<PAGE 2>>>\n\nManagement System located at www.regulations.gov.\n2 PHMSA received public comment on\nthese special permit requests and has addressed such in the Final Environmental Assessment.\nSubject to the stated terms and conditions, PHMSA grants the amendment to the special permit\n(enclosed) issued on March 31, 2022, based on the information provided by TCO and the\nfindings set forth in the SPAF, FEA, and FONSI. This special permit provides relief from\ncertain provisions of the Federal pipeline safety regulations for the Pipeline and requires TCO to\ncomply with conditions and limitations designed to maintain pipeline safety as defined in the\nspecial permit. In accordance with 49 CFR § 190.341(j), PHMSA reserves the right to revoke,\nsuspend, or modify this special permit if circumstances occur in which its continuance would be\ninconsistent with pipeline safety. If TCO elects not to implement the special permit conditions\nfor the segments identified in the amended special permit, TCO must notify PHMSA within 60\ndays and comply with 49 CFR § 192.611(a) within 18 months of the date of this letter granting\nthe special permit amendment.\nMy staff would be pleased to discuss this special permit or any other regulatory matter with you.\nMary McDaniel, Acting Director of PHMSA Engineering and Research Division, may be\ncontacted at (713) 272-2847, on technical matters; and Robert Burrough, Director, Office of\nPipeline Safety, Eastern Region may be contacted at (609) 771-7809, for operational matters\nspecific to this special permit.\nSincerely,\nAlan K. Mayberry\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit – PHMSA-2019-0202\n2 https://www.regulations.gov/docket?D=PHMSA-2019-0202. PHMSA will also post all documents relevant to the\nNovember 30, 2022, request in Docket No. PHMSA-2022-0166, the docket number for which that request was\ninitially assigned.Special Permit Amendment: PHMSA-2019-0202 – Columbia Gas Transmission, LLC\nLetter of Decision – Class 1 to 3 Locations – Maryland and Virginia Page 2 of 2\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-2019-0202\nRequested By: Columbia Gas Transmission, LLC\nOperator ID#: 2616\nOriginal Date Requested: October 15, 2019\nOriginal Issuance Date: March 31, 2022\nEffective Dates: March 31, 2022 to March 31, 2032\nCode Section(s): 49 CFR 192.611\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS),\n1 provides this information to describe the facts of the subject special permit\napplication submitted by Columbia Gas Transmission, LLC (TCO),\n2 to discuss any relevant\npublic comments received with respect to the application, to present the engineering and safety\nanalysis of the special permit application, and to make findings regarding whether the requested\nspecial permit should be granted and, if so, under what conditions. TCO requested that PHMSA\nwaive compliance from the 49 Code of Federal Regulations (CFR) 192.611 for natural gas\ntransmission pipeline segments, where the class location has changed from a Class 1 to a Class 3\nlocation.\n1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of\nTransportation’s Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety.\n2 TCO is a wholly-owned, subsidiary of TC Energy.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland\nPage 1 of 12\n\n<<<PAGE 2>>>\n\nPipeline System Affected:\nThis special permit application applies to the TCO request for a waiver from the class location\nchange requirements in 49 CFR 192.611 for 10,801 feet (approximately 2.046 miles) of the 30-\ninch diameter gas transmission Line MC Pipeline located in Montgomery County, Maryland.\nWithout this special permit, 49 CFR 192.611(a) would require TCO to replace the four (4)\nspecial permit segments with stronger pipe or reduce the pipeline maximum allowable operating\npressure (MAOP) for a Class 1 to Class 3 location change.\nPipe specifications including outside diameter, year installed, seam type, coating type, pipe\ngrade, wall thickness, MAOP, minimum pressure test pressure, and pressure test factor based on\nthe minimum test pressure are detailed in Table 1 – Pipe Specifications by Line Name.\nTable 1 – Pipe Specifications by Line Name\nOutside\nMin. Test\nLine\nDiameter\nYear Installed Name\nSeam\nType Coating Type Grade Wall Thickness\n(inches)\nMAOP\nPressure\nPressure\n(psig)\nTest Factor\n(inches)\nMC 30 1962 SAW Asphalt X60 0.312 / 0.375 898 (psig)\n1,275 1.42\nNote: SAW is single submerged arc welded seam pipe.\nSpecial Permit Request:\nOn October 15, 2019, TCO applied to PHMSA for a special permit seeking relief from 49 CFR\n192.611 for the below listed special permit segments, where a class location change occurred\nfrom the original Class 1 to a Class 3 on the 30-inch diameter Line MC Pipeline located in\nMontgomery County, Maryland.\nSpecial Permit Segments:\nThis proposed special permit applies to the special permit segments in Table 2 – Special\nPermit Segments.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland\nPage 2 of 12\n\n<<<PAGE 3>>>\n\nTable 2 – Special Permit Segments\nMaterial\nSpecial\nPermit\nOutside\nRecords –\nLine\nLength\nStart Survey\nEnd Survey\nCounty or Parish,\nNo.\nYear\nSeam\nMAOP\nDiameter\nCondition\nSegment\nNumber\nName\n(feet)\nStation (SS)\nStation (SS)\nState\nDwellings\nInstalled\nType\n(psig)\n(inches)\n13(d)\n1 30 Line MC 3,453 553+57 588+10 Montgomery, MD 20 1962 SAW 898 required\nYes\n2 30 Line MC 2,685 596+56 623+41 Montgomery, MD 35 1962 SAW 898 Yes\n3 30 Line MC 3,415 281+49 315+64 Montgomery, MD 74 1962 SAW 898 Yes3\n4 30 Line MC 1,248 337+91 350+39 Montgomery, MD 2 1962 SAW 898 Yes\nNote: SAW is single submerged arc welded seam pipe.\nSpecial Permit Inspection Area:\nThe special permit inspection area is defined as the area that extends 220 yards on each side of\nthe centerline as listed in Table 3 – Special Permit Inspection Area.\nTable 3 – Special Permit Inspection Area\nSpecial\nSpecial Permit\nOutside\nPermit\nInspection\nDiameter\nLine Name\nStart Survey\nStation\nEnd Survey Station\n(SS)\nLength4\n(miles)\nArea Number\nSegment(s)\nIncluded\n(inches)\n(SS)\n1 1, 2, 3, and 4 30 Line VC - Line MC 0+00 (Line VC) 1603+78 (Line MC) 40.5\nThe special permit inspection area is located in Loudoun County, Virginia, and Montgomery\nand Howard Counties, Maryland.5 Figures 1 through 3 are maps showing the 30-inch diameter\nLine VC – Line MC Pipeline special permit segments, special permit inspection area, and class\nlocations.\nPublic Notice:\nOn September 8, 2020, PHMSA posted a notice of this special permit request in the Federal\nRegister (85 FR 55574) with a closing date of October 8, 2020. PHMSA received an anonymous\ncomment recommending that PHMSA not issue any special permits and take other actions\nrelated to energy legislation. PHMSA’s statute and regulations provide pipeline operators the\nopportunity to apply for special permits and PHMSA uses the conditions placed on permit grants\n3 TVC material records for 3,377 feet of the original 1962 pipe from 281+53 to 314+32 and 314+66 to 315+64\nwere not provided.\n4 If the special permit inspection area footage does not extent from launcher to receiver then the special permit\ninspection area would need to be extended.\n5 The special permit inspection area includes the special permit segments.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland\nPage 3 of 12\n\n<<<PAGE 4>>>\n\nto protect public safety and the environment. PHMSA is an executive agency that does not take\nlegislative actions.\nPHMSA has reviewed this special permit application to ensure the special permit conditions\naddress pipeline safety and integrity threats to the pipeline in the special permit segments and\nspecial permit inspection area. The special permit will require TCO’s Operations and\nMaintenance (O&M) Manual and Procedures to provide a systematic program to review and\nremediate the pipeline for safety concerns. Additional operational integrity reviews and\nremediation requirements will be required by this special permit for these special permit\nsegments for Class 1 to 3 location changes.\nThe TCO special permit application letter, Federal Register notice, Special Permit, Final\nEnvironmental Assessment (FEA) and Finding of No Significant Impact (FONSI), and all other\npertinent documents are available for review in Docket No. PHMSA-2019-0202 in the Federal\nDocket Management System (FDMS) located on the internet at www.Regulations.gov.\nAnalysis:\nBackground: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the\ncriteria it uses for the consideration of applications for class location change waivers, now being\ngranted or denied through a special permit. First, certain threshold requirements should be met\non a pipeline special permit segment for a class location change special permit to be granted.\nSecond, the age and manufacturing process of the pipe; system design, and construction;\nenvironmental, operating, and maintenance histories; and integrity management program\nelements are evaluated as significant criteria. These significant criteria are presented in matrix\nform and can be reviewed in the FDMS, Docket No. PHMSA–RSPA-2004-17401. Third,\nspecial permits will only be granted when pipe conditions and active integrity management\nprovides a level of safety greater than or equal to a pipe replacement or pressure reduction. The\noperator’s federal pipeline safety regulation compliance history is also evaluated as part of the\ncriteria matrix for acceptability prior to issuance of a special permit.\nThreshold Requirements: Each of the threshold requirements published by PHMSA in the June\n29, 2004, Federal Register notice is discussed below for the TCO special permit request.\n1) No pipeline segments in a class location changing to Class 4 location will be considered.\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland\nPage 4 of 12\n\n<<<PAGE 5>>>\n\n• This special permit request is for special permit segments on the TCO 30-inch diameter\nLine MC Pipeline, where a change has occurred from a Class 1 location to a Class 3\nlocation.\n• TCO meets this requirement.\n2) No bare pipe will be considered.\n• The TCO special permit segments are externally coated with asphalt.\n• TCO has not reported any coating issues such as disbonded coating.\n• TCO meets this requirement.\n3) No pipe containing wrinkle bends will be considered.\n• There are no wrinkle bends in the special permit segments.\n• TCO meets this requirement.\n4) No pipe segments operating above 72% of the specified minimum yield strength (SMYS)\nwill be considered for a Class 3 special permit.\n• The special permit segments operate at or below 72% SMYS.\n• TCO meets this requirement.\n5) Records must be produced that show a hydrostatic test to at least 1.25 x MAOP and 90% of\nSMYS.\n• The special permit segments on the Line MC Pipeline was tested to at least 1.42 times\nthe MAOP.\n• TCO meets this requirement.\n6) Inline inspection (ILI) must have been performed with no significant anomalies identified\nthat indicate systemic problems such as stress corrosion cracking (SCC).\n• TCO ran ILI tools on the Line MC Pipeline in 2019 in the special permit inspection\narea.\n• TCO has not found any SCC indications in or within 20 miles of the special permit\nsegment.\n• TCO meets this requirement.\n7) Criteria for consideration of a class location change waiver, being considered through the\nspecial permit, published by PHMSA in the Federal Register (69 FR 38948), define a waiver\ninspection area (special permit inspection area) as up to 25 miles of pipe on either side of\nthe waiver segment (special permit segment).\nPHMSA-2019-0202 – Columbia Gas Transmission, LLC Special Permit Analysis and Findings – Maryland\nPage 5 of 12\n\n<<<PAGE 6>>>\n\n• A special permit would be contingent upon TCO’s incorporation of the special permit\nsegments in its written integrity management program as covered segments in a high\nconsequence area (HCA) in accordance with 49 CFR 192.903 and to assess and\nremediate threats to the special permit inspection area.\n• TCO’s defined special permit inspection area is 40.5 miles in length.\nCriteria Matrix:","truncated":true,"body_characters":48651}