# Gulf South Pipeline Company, LP — Pipeline Special Permit

- **operation:** document
- **citation:** PHMSA-2019-0207
- **title:** Gulf South Pipeline Company, LP — Pipeline Special Permit
- **source type:** permit
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2020-07-20
- **effective on:** 2020-07-20
- **summary:** PHMSA-2019-0207, issued 2020-07-20 for Gulf South Pipeline Company, LP's gas transmission system.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2019-0207.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2019-0207.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2019-0207
- **source url:** https://www.regulations.gov/docket/PHMSA-2019-0207
**body:**

PHMSA pipeline special permit PHMSA-2019-0207. Operator: Gulf South Pipeline Company, LP. System: Gas Transmission. Issue date: 2020-07-20.

<<<PAGE 1>>>

U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, DC 20590
July 20, 2020
Docket No. PHMSA-2019-0207
Mr. Tony Rizk
Vice President, Technical Services
Gulf South Pipeline Company, LP
9 Greenway Plaza, Suite 2800
Houston, TX 77046
Dear Mr. Rizk:
On October 4, 2019, pursuant to the 49 Code of Federal Regulations § 190.341, Gulf South
Pipeline Company, LP (GSPC) applied to the Pipeline and Hazardous Materials Safety
Administration (PHMSA) for a special permit. GSPC requested to waive compliance with
§ 192.611(a) for a Class 1 to Class 3 location change of 214 feet of the 42-inch diameter Index
817 Pipeline (Pipeline) located in Madison Parish, Louisiana. A gas transmission pipeline is
required by § 192.611(a) to have the maximum allowable operating pressure of a pipeline
segment to be confirmed or revised where the class location has changed as defined in § 192.5.
On February 7, 2020, PHMSA published a Federal Register notice (85 FR 7388), announcing the
special permit request. The Special Permit Request letter, Final Environmental Assessment
(FEA) and Finding of No Significant Impact (FONSI), Special Permit Analysis and Findings,
and all other pertinent documents for this special permit are available in Docket No. PHMSA-
2019-0207 in the Federal Docket Management System located at www.regulations.gov.
PHMSA grants this special permit (enclosed) based on the information provided by GSPC
and the findings set forth in the Special Permit Analysis and Findings, FEA, and FONSI. This
special permit provides relief from the Federal Pipeline Safety Regulations for 214 feet of
the Pipeline and requires GSPC to comply with certain conditions and limitations designed
to maintain pipeline safety for the period as defined in the special permit.

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My staff would be pleased to discuss this special permit or any other regulatory matter with you.
Sentho White, Director of PHMSA Engineering and Research Division, may be contacted at
202-366-2415, on technical matters; and Allan Beshore, Director, Office of Pipeline Safety,
Central Region, may be contacted at 816-329-3811, for operational matters specific to this
special permit.
Sincerely,
Digitally signed by ALAN
ALAN KRAMER
KRAMER MAYBERRY
MAYBERRY Date: 2020.07.20
16:02:51 -04'00'
Alan K. Mayberry
Associate Administrator for Pipeline Safety
Enclosure: Special Permit – PHMSA-2019-0207
PHMSA-2019-0207 Gulf South Pipeline Company, LP - Letter of Decision - Page 2 of 2

<<<PAGE 1>>>

U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
SPECIAL PERMIT – Class 1 to 3 Location Change
Special Permit Information:
Docket Number: PHMSA-2019-0207
Requested By: Gulf South Pipeline Company, LP
Operator ID#: 31728
Date Requested: October 4, 2019
Original Issuance Date: July 20, 2020
Effective Dates: July 20, 2020 to July 20, 2030
Code Section(s): 49 CFR 192.611(a)
Grant of Special Permit:
By this order, subject to the terms and conditions set forth below, the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),1 grants this special
permit to Gulf South Pipeline Company, LP (GSPC).2 This special permit waives compliance
with the 49 Code of Federal Regulations (CFR) 192.611(a) for a Class 1 to Class 3 location
change of GSPC’s Index 817 Pipeline, which is a 42-inch diameter natural gas transmission
pipeline, in Madison Parish, Louisiana. This special permit requires that GSPC implement
additional conditions on the operations, maintenance, and integrity management of the Index 817
Pipeline.
I. Purpose and Need:
The special permit is needed for a Class 1 to Class 3 location change that has occurred on the 42-
inch diameter Index 817 Pipeline located in Madison Parish, Louisiana. On the condition that
GSPC complies with the terms and conditions set forth below, this special permit waives
compliance from 49 CFR 192.611(a) for 214 feet of natural gas transmission pipeline on the 42-
1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of
Transportation’s Pipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety.
2 GSPC is a wholly-owned subsidiary of the Boardwalk Pipeline Partners, LP.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
Page 1 of 20

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inch diameter Index 817 Pipeline. This special permit allows GSPC to continue to operate the
special permit segment as defined below at its current maximum allowable operating pressure
(MAOP) of 1,456 pounds per square inch gauge (psig) for the Index 817 Pipeline.3
The Federal pipeline safety regulations in 49 CFR 192.611(a) require natural gas transmission
operators to either pressure test, replace the pipe with stronger pipe, or lower the MAOP when
there is a Class 1 to Class 3 location change as defined in 49 CFR 192.5. The 214 feet of 42-inch
diameter pipe in the GSPC special permit request operates at a stress level of 65.2% of specified
minimum yield strength (SMYS) based upon a 1,456 psig MAOP. Without this special permit,
in accordance with 49 CFR 192.611(a), GSPC would be required to replace the pipe segment or
reduce the pipeline MAOP. The 214 feet of the 42-inch diameter Index 817 Pipeline was
hydrostatically tested to a minimum pressure of 1,875 psig for 8 hours in late 2007, whereas 49
CFR 192.611(a) requires a minimum test pressure of 2,184 psig for a Class 3 location and the
pipe design factor is greater than 60% of SMYS.
II. Special Permit Segments and Inspection Areas:
Madison Parish, Louisiana
This special permit applies to the special permit segment defined using the GSPC survey station
(SS) references as follows:
• Special permit segment – Index 817 Pipeline – 4,638 feet, SS 9409+44 to SS
9455+82.
Note: GSPC’s special permit request was for 214 feet from SS 9431+56 to SS
9433+70. All procedures, surveys, assessments, remediation, and assessment
intervals required in these special permit conditions for the special permit segment
are applicable on either side of the special permit segment end points for a distance
of two (2) times the potential impact radius (PIR), as defined in 49 CFR 192.903.
The PIR for a 42-inch diameter, 1,456 psig MAOP pipeline is 1,106 feet. Two (2)
3 This special permit is for a 214-foot segment of 42-inch diameter Index 817 Pipeline as requested by GSPC. The
special permit segment includes additional pipeline footage beyond the 214 feet that extends the special permit
segment which the special permit conditions are applicable. Condition 14 will allow extensions beyond the 214
feet of pipeline should the Class 3 location extend further. PHMSA has granted this special permit due to the 214
feet of 42-inch diameter pipe operating at a stress level of 65.2% of specified minimum yield strength (SMYS)
based upon a 1,456 psig MAOP. Pipelines with a MAOP of over 72% SMYS are not allowed to operate in a
Class 3 location. This special permit is not for pipe operating above 72% SMYS.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
Page 2 of 20

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times the PIR would be 2,212 feet. The special permit segment total footage is 4,638
feet. PHMSA extended this special permit request from a 214-foot special permit
segment to a 4,638-foot special permit segment since this pipeline has an existing
Alternative MAOP special permit4 to operate up to 80% SMYS in Class 1 locations.
This special permit applies to the special permit inspection area defined using the GSPC SS
references as follows:
• Special permit inspection area – Index 817 Pipeline – SS 8898+40 to 10752+83,
approximately 35.1 miles.
The special permit inspection area is in Madison Parish, Louisiana, and Warren and Hinds
Counties, Mississippi. The special permit inspection area starts at the Tallulah, Louisiana
Compressor station and ends at a pointed located in Hinds County, Mississippi for a length of
approximately 35.1 miles and includes the special permit segment. Attachments A and B
include Index 817 Pipeline route maps showing the special permit segment and special permit
inspection area.
PHMSA grants this special permit based on the findings set forth in the “Special Permit Analysis
and Findings” and “Final Environmental Assessment and Finding of No Significant Impact”
documents, which can be read in its entirety in Docket No. PHMSA-2019-0207 in the Federal
Docket Management System located on the internet at www.regulations.gov.
III. Conditions:
PHMSA grants this special permit to GSPC subject to GSPC implementing the following
conditions on the Index 817 Pipeline as detailed below:
1) Maximum Allowable Operating Pressure for the Special Permit:
a) MAOP: GSPC must continue to operate the special permit segment and special permit
inspection area at or below the existing MAOP of 1,456 psig.
b) Alternative MAOP: GSPC must continue to implement the conditions in the Alternative
MAOP special permit (PHMSA-2006-26533) for both the special permit segment and
4 PHMSA-2006-26533.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
Page 3 of 20

<<<PAGE 4>>>

the special permit inspection area. The special permit inspection area is defined in this
special permit (PHMSA-2019-0207).
2) Integrity Management Program: GSPC must incorporate the requirements of this special
permit into its written integrity management program and standard operating procedures
(SOPs).
a) GSPC must treat the special permit segment as a “covered segment” in a “high
consequence area (HCA)” in accordance with 49 CFR Part 192, Subpart O.
Reassessments of the special permit segment and special permit inspection area using
high resolution magnetic flux leakage (HR-MFL) and high resolution (HR) Deformation
inline inspection (ILI) must be conducted at the frequency specified for HCAs in 49 CFR
192, Subpart O.
b) If GSPC identifies threats within the special permit segment and special permit
inspection area that require running additional ILI tools, pursuant to 49 CFR Part 192,
Subpart O, such as for crack detection5 or pipe movement from soil or geologic stresses,
GSPC must use the appropriate ILI tools or other evaluation methods for pipeline
assessments.
3) Operations and Maintenance Manual: GSPC must amend applicable sections of its
operations and maintenance (O&M) Manual(s) and Procedures to incorporate the procedures,
inspections, assessments, reassessments, remediation, reporting, documentation, permitting,
and timing or time intervals required by the special permit conditions. The O&M Manual
and Procedures must include requirements to address each condition in this special permit for
the special permit segment and the special permit inspection area.
4) Close Interval Surveys:
a) CIS: GSPC must conduct close interval surveys (CIS) at a maximum 5-foot spacing and
with interrupted on/off current on the special permit segment and special permit
inspection area in accordance with 49 CFR 192.463 and 192.465.
b) CIS Timing: GSPC must perform periodic CIS of the special permit segment and
special permit inspection area at the applicable reassessment interval(s) for a “covered
segment” determined in concert and integrated with ILI in accordance with 49 CFR 192,
5 “Pipe Crack” activity shall be defined as over both 20% wall thickness depth and 2-inches in length.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
Page 4 of 20

<<<PAGE 5>>>

Subpart O, reassessment intervals as required in 49 CFR 192.937(a) and (b) and 192.939.
If a CIS was not conducted with the last ILI survey, it must be conducted within one (1)
year of issuance of this special permit.
c) CIS Timing Delay: If environmental permitting or right-of-way factors beyond GSPC’s
control prevent the completion of the CIS and remediation6 within six (6) months from
the issuance of this special permit, GSPC must complete the CIS and subsequent
remediation including coating repair as soon as practicable. GSPC must submit a letter
justifying the CIS and remediation delays, no later than one (1) month prior to the end of
six (6) month interval, and must provide the anticipated date of completion to the
Director, PHMSA Central Region.7
d) CIS Reassessments: GSPC must perform periodic CIS of the special permit segment
and special permit inspection area at the applicable reassessment interval(s) for a
“covered segment” determined in concert and integrated with ILI in accordance with 49
CFR 192, Subpart O, reassessment intervals as required in 49 CFR 192.937(a) and (b)
and 192.939. CIS assessments within the reassessment interval are not required to be
performed in the same year as ILI reassessments.
5) Cathodic Protection Test Stations:
a) Test Station Locations: At least one (1) cathodic protection (CP) pipe-to-soil test station
must be located within the special permit segment with a maximum spacing of one-half
mile between test stations. In cases where obstructions or restricted areas prevent test
station placement, the test station must be installed in the closest practical location.
b) Monitoring: Annual monitoring of cathodic protection pipe-to-soil test stations must be
performed in accordance with 49 CFR 192.463 and 192.465.
6) Annual Cathodic Protection Test Station Readings:
a) CP Findings: If any annual CP test station readings on the special permit inspection
area fall below 49 CFR Part 192, Subpart I requirements, remediation must occur within
6 The terms “remediate” or “remediation” of pipe coating shall include repair of damaged external pipe coating,
where required to maintain cathodic protection of the pipeline in accordance with 49 CFR 192.463.
7 Upon notice to GSPC by the Director, PHMSA Central Region, PHMSA may change the reporting responsibilities
for this special permit to another PHMSA Region Director.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
Page 5 of 20

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six (6) months of the survey and must include a CIS on each side of the affected test
station to the next test station. GSPC must implement corrosion system modifications
that are identified through the CP test station readings and remediation findings to ensure
corrosion control.
b) Remediation Timing: If factors beyond GSPC’s control prevent the completion of
remediation within six (6) months, GSPC must complete the remediation as soon as
practicable and submit a letter justifying the delay with the anticipated date of completion
to the Director, PHMSA Central Region, no later than one (1) month prior to the end of
the six (6) month remediation period. GSPC must receive a letter of “No Objection”
from the Director, PHMSA Central Region, prior to implementing an extended
remediation interval.
7) Interference Currents Control: GSPC must incorporate measures to control induced
alternating current (AC) from parallel electric transmission lines and other interference issues
in the special permit inspection area, that may affect the pipeline. An induced AC program
to protect the pipeline from corrosion caused by stray currents must be in place within one
(1) year of the date of this special permit.
8) Anomaly Assessment and Remediation:
a) General: GSPC must conduct anomaly assessments using ILI that meets the assessment
intervals of special permit PHMSA-2006-26533 and 49 CFR Part 192, Subpart O. GSPC
must account for ILI tool tolerance8,9 and corrosion growth rates in scheduled response
times and repairs, and document and justify the values used.
8 ILI tool calibration excavations may include previously excavated anomalies or recent anomaly excavations with
known dimensions that were field measured for length, depth, and width, externally re-coated, CP maintained, and
documented for ILI calibrations prior to the ILI tool run. ILI tool calibrations must use ILI tool run results and
anomaly calibrations from either the special permit inspection area or from the complete ILI tool run segment, if
the continuous ILI segment is longer than the special permit inspection area. A minimum of four (4) calibration
excavations must be used for unity plots or as an alternative a minimum of one (1) calibration excavation and
compliance with API 1163-2013, In-Line Inspection Systems Qualification Standard (API 1163), Level 1 criteria
must be used. For API 1163, Level 1 criteria to be used, all anomalies greater than 20-percent wall loss must be
excavated and remediated unless Director, PHMSA Central Region gives GSPC a “No Objection” to an
alternative ILI tool calibration procedure (see Footnote 9).
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
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b) Dents: GSPC must repair dents to the Index 817 Pipeline in the special permit
inspection area in accordance with the 49 CFR 192.933 repair criteria. The special
permit inspection area must have a high resolution (HR) deformation tool inspection as
part of the ILI. The HR deformation ILI can be from past inspections. The timing for
these dent repairs should follow GSPC’s O&M Procedures, but must not be longer than
one (1) year after discovery.
c) Anomaly Evaluation Repair Criteria and Timing: The following provisions provide
the required timing for excavation and investigation of anomalies based on ILI results.
GSPC must evaluate ILI data by using either the ASME Standard B31G, “Manual for
Determining the Remaining Strength of Corroded Pipelines”,
10 the modified B31G
(0.85dL) or R-STRENG for calculating the predicted failure pressure ratio (FPR) to
determine anomaly responses.
i) Special permit segment:
- Immediate response time – repair immediately:
o Any anomaly within a special permit segment that meets either: (1) a FPR
equal to or less than 1.25; or (2) an anomaly depth equal to or greater than
60% wall thickness loss.
- One-year response:
o Any anomaly within a special permit segment with pipe operating over 56%
SMYS and up through 67% SMYS that meets either: (1) a FPR equal to or
less than 1.50; or (2) an anomaly depth equal to or greater than 40% wall
thickness loss.
9 Note: Other known and documented pipeline features that are appropriate for the type ILI tool used may be used
as calibration excavations for ILI tool calibration with technical documentation of their validity. To use other
known and documented pipeline features as calibration excavations for ILI tool calibration GSPC must submit a
plan for using known and documented pipeline features as calibration excavations to, and receive a “No
Objection” from the Director, PHMSA Central Region, prior to performing the ILI tool calibration using pipeline
features. PHMSA must reply to GSPC within 90-days of GSPC’s request. The plan must include at least the
following information: (1) reason that known and documented pipeline features will be used in place of anomalies
on the pipelines; the pipeline features that will be used for the ILI tool calibration, and the technical justification
for using the pipeline features for ILI tool calibration; and (2) submit a report to the Director, PHMSA Central
Region and to the Director, PHMSA Engineering and Research with the results of the use of pipeline features for
the ILI tool calibration that includes technical documentation establishing the validity of using the pipeline
features for the ILI tool calibration. GSPC must submit the report to PHMSA within 90-days after completion of
the ILI tool calibration.
10 Standards used in this special permit must be the edition incorporated by reference in 49 CFR 192.7.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
Page 7 of 20

<<<PAGE 8>>>

o Any anomaly within a special permit segment with pipe operating over 67%
SMYS and up through 72% SMYS that meets either: (1) an FPR equal to or
less than 1.39; or (2) an anomaly depth equal to or greater than 40% wall
thickness loss.
o Any anomaly within a special permit segment with pipe operating over 72%
SMYS and up through 80% SMYS that meets either: (1) an FPR equal to or
less than 1.25; or (2) an anomaly depth equal to or greater than 40% wall
thickness loss.
o Any anomaly within a special permit segment with pipe operating up through
56% SMYS that meets either: (1) an FPR equal to or less than 1.80; or (2) an
anomaly depth equal to or greater than 40% wall thickness loss.
- Monitored response:
o Any anomaly within a special permit segment with pipe operating over 56%
SMYS and up through 67% SMYS that meets either: (1) an FPR over 1.50; or
(2) an anomaly depth less than 40% wall thickness loss.
o Any anomaly within a special permit segment with pipe operating over 67%
SMYS and up through 72% SMYS that meets either: (1) an FPR over 1.39; or
(2) an anomaly depth less than 40% wall thickness loss.
o Any anomaly within a special permit segment with pipe operating over 72%
SMYS and up through 80% SMYS that meets either: (1) an FPR over 1.25; or
(2) an anomaly depth less than 40% wall thickness loss.
o Any anomaly within a special permit segment with pipe operating up through
56% SMYS that meets either: (1) an FPR over 1.80; or (2) an anomaly depth
less than 40% wall thickness loss.
ii) Special permit inspection area:
- Immediate response time – repair immediately:
o Any anomaly within a special permit inspection area that meets either: (1) an
FPR equal to or less than 1.10; or (2) an anomaly depth equal to or greater
than 80% wall thickness loss.
- One-year and monitored response:
o The anomaly assessment remediation and response time for a special permit
inspection area must be in accordance with: (1) 49 CFR Part 192, Subpart O;
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
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<<<PAGE 9>>>

(2) Special Permit PHMSA-2006-26533, Condition 43, for the Index 817
Pipeline; and (3) 49 CFR 192.620(d)(11). The assessment response that has a
shorter repair timing or more conservative anomaly remediation requirements
must be implemented by GSPC.
o Any anomaly within the special permit inspection area with a depth equal to
or greater than 40% wall thickness loss must be remediated within one-year of
GSPC finding the anomaly.
9) Damage Prevention Program: GSPC must ensure its damage prevention program
incorporates the applicable best practices of the Common Ground Alliance within the special
permit inspection area.
10) Annual Report to PHMSA: Annually,11 after the grant of this special permit, GSPC must
submit an annual pipeline integrity report to the Director, PHMSA Central Region,
summarizing any significant integrity threats and the following items:12
a) In the first annual report, GSPC must describe the economic benefits of the special
permit, including both the costs avoided from not replacing the pipe and the added costs
of the inspection program. Subsequent annual reports must address any changes to these
economic benefits.
b) In the first annual report, GSPC must fully describe how the public benefits from energy
availability. GSPC must address the benefits of avoided disruptions as a consequence of
pipe replacement and the benefits of maintaining system capacity. Subsequent reports
must indicate any changes to this initial assessment.
c) Any new integrity threats identified during the previous year in the special permit
segment, and the results of any ILI or direct assessments performed (including any
remediated anomalies with the associated wall loss, length, and unrepaired failure
pressure; any un-remediated anomalies over 30% pipe wall loss and the associated wall
loss, length and failure pressure; cracking found in the pipe body; weld seam or girth
11 Annual reports must be received by PHMSA by the last day of the month in which the special permit is granted.
For example, the annual report for a special permit granted on July 15, 2020, must be received by PHMSA no
later than July 31 each year beginning in 2021.
12 GSPC must submit a copy of the annual reports on the special permit docket - PHMSA-2019-0207, at
www.regulations.gov.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
Page 9 of 20

<<<PAGE 10>>>

welds; and dents with metal loss, cracking or stress riser) during the previous year in the
special permit segment;
d) Summaries of any close interval surveys that resulted in low cathodic protection levels in
the special permit segment and a remediation schedule;
e) Any reportable incident or any leak normally indicated on the DOT Annual Report, and
all repairs on the pipeline that occurred during the previous year in the special permit
segment;
f) Any pressure test leaks or failures with a description of the cause in the special permit
segment;
g) Any mergers, acquisitions, transfer of assets, or other events affecting the regulatory
responsibility of the company operating the pipeline;
h) Any emergency events that cause closure of mainline valves as described in Condition
12, including the location (Mile Post) of valves and closure times.
11) Special Permit Segment Specific Conditions: GSPC must comply with the following
requirements:
a) Line-of-Sight Markers: GSPC must install and maintain line-of-sight markers within
the special permit inspection area in accordance with 49 CFR 192.620(d)(4)(iv) to the
extent practicable. Line-of-sight markers must be installed within three (3) months of
issuance of this special permit and replaced as necessary by GSPC within 30 days of
discovering the marker is removed or missing.
b) Data Integration: GSPC must maintain data integration of all special permit condition
findings and remediation in the special permit inspection area. Data integration must
include the following information: (1) Pipe diameter, wall thickness, grade, and seam
type; (2) pipe coating; (3) MAOP; (4) class location (including boundaries on aerial
photography); (5) HCAs (including boundaries on aerial photography); (6) hydrostatic
test pressure including any known test failures; (7) casings; (8) any in-service ruptures or
leaks; (9) ILI survey results including HR-MFL, HR-geometry/caliper or deformation
tools; (10) CISs – most recent; (11) depth of cover surveys; rectifier readings – past five
years; (12) cathodic protection test point survey readings – past five years; (13) AC/DC
interference surveys; (14) pipe coating surveys; (15) pipe coating and anomaly
evaluations from pipe excavations; (16) stress corrosion cracking excavations and
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
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<<<PAGE 11>>>

findings; and (17) pipe exposures from encroachments.13 Structures must be validated
every three (3) years by obtaining new aerial imagery or by ground patrol.
i) Data integration must be performed in accordance with 49 CFR 192.917 for threat
identification, evaluation, remediation, and mitigation.
ii) Data integration documentation and drawings, with four (4) years of prior data, to
meet Condition 11(b), must be completed and must be submitted, if requested by
PHMSA, beginning with the 2nd annual report of this special permit.
iii) Data integration must be updated on an annual basis. GSPC must conduct, at least, an
annual review of integrity issues to be remediated.
iv) GSPC must maintain data integration as a composite of all applicable data elements
in a data viewer.
c) Pipeline Patrolling: Pipeline patrolling must be conducted at least monthly (12 times
per calendar year), not to exceed 45 days, to inspect the special permit inspection area
for excavation activities, ground movement, wash-outs, leakage or other activities and
conditions affecting the safe operation of the pipeline.
d) Environmental Assessments and Permits: GSPC must evaluate the potential
environmental consequences and affected resources of any land disturbances and water
body crossings needed to implement the special permit conditions for special permit
segment or special permit inspection area prior to the disturbance. If a land disturbance
or water body crossings is required, GSPC must obtain and adhere to all applicable
(Federal, state, and local) environmental permit requirements when conducting the
special permit conditions activity.
e) Root Cause Analysis for Failure or Leak: If a leak or rupture (incident as defined by 49
CFR 191.3) occurs in any of the special permit inspection area, GSPC must notify the
Director, PHMSA Central Region, within five (5) days of the leak or rupture. A root
cause analysis must be performed to determine the cause of the failure and must be sent
to the Director, PHMSA Central Region, and the Director, PHMSA Engineering and
Research, within 90 days of the incident. If a root cause analysis cannot be performed
13 Hydrostatic test failures, in-service ruptures, rectifier readings, cathodic protection test point survey readings,
AC/DC interference surveys, pipe coating surveys, pipe coating and anomaly evaluations from pipe excavations,
SCC excavations and findings, and pipe exposures from encroachments must be maintained for data integration
into a comparable data viewer. These data elements may not be on a drawing.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
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<<<PAGE 12>>>

within 90 days of the incident, GSPC must submit to the Director, PHMSA Central
Region, a request for an extension of time. GSPC must receive a letter of “No Objection”
from the Director, PHMSA Central Region, prior to implementing an extended timeframe
to perform the root cause analysis. PHMSA will review the root cause analysis report to
determine if revocation, suspension, or modification of the special permit is warranted
based upon incident findings.
12) Mainline Valve – Monitoring and Remote Control for Leaks or Ruptures: GSPC must
automate the nearest existing mainline valves on both sides of the special permit segment for
closure, or demonstrate the capability to manually close the mainline valves in accordance
with the requirements of Condition 12. The mainline valves must be within a maximum 20-
mile total spacing, upstream and downstream, of the special permit segment. GSPC
mainline valves are located at Index 817 Pipeline Mile Posts 168.5 (SS 8897+01) and 183.06
(SS 9665+82). GSPC must develop and implement procedures to initiate closure of each
mainline valve as follows:
a) Supervisory Control and Data Acquisition System and Remote Monitoring: The
special permit segment must be controlled by a supervisory control and data acquisition
(SCADA) system and must be equipped for remote monitoring and control, or remote
monitoring and automatic control in accordance with 49 CFR 192.620(d)(3)(iii) and the
below requirements of Condition 12;
b) Crossovers or Lateral Pipe Isolation: If any crossover or lateral pipe for gas receipts or
deliveries connects to the isolated segment between the upstream and downstream
mainline valves, the nearest valve on the crossover connection(s) or lateral(s) must be
isolated, such that, when all valves are closed, there is no flow path for gas to flow to the
leak or rupture site (except for residual gas already in the shut-off segment). If the
nearest valve for a gas receipt or delivery line to the special permit segment is not
isolated, isolation valves must be used;14
14 Gas delivery pipelines must have a remote-controlled shutoff valve (gate or ball valve) either at the connection to
the Index 817 Pipeline or at the delivery meter station. Any gas delivery or receipt station over 5 miles in length
that is connected to the Index 817 Pipeline must have a remote-controlled shutoff valve within 5 miles of the
Index 817 Pipeline. For gas delivery or receipt pipelines, manual shutoff valves can be used for isolation, but must
be closed within 30 minutes from the pipeline leak or rupture confirmation.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline – Class 1 to 3 Location Change
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c) Remote Control Valve Monitoring for Valve Status and Operating Pressure:
Mainline valves must be constantly monitored for valve status (open, closed, or partial
closed/open), upstream pressure, and downstream pressure;
d) Valve Closure for a Leak or Rupture: Closure of the appropriate valves following a
pipeline leak or rupture meeting the criteria specified in this Condition 12(d)(i) must
occur as soon as practicable from the time the pipeline leak or rupture location is
confirmed, not to exceed 30 minutes from such confirmation;15
i) “Rupture” means a significant breach of a pipeline that results in a large-volume,
uncontrolled release of gas. For purposes of this special permit, GSPC must treat any
of the following as ruptures unless and until determined otherwise:
1) A release of gas observed or reported to the operator by its field personnel, nearby
pipeline or utility personnel, the public, local responders, or public authorities,
and that may be representative of an unintentional and uncontrolled release event
defined in paragraphs (2) or (3) of this definition;
2) An unanticipated or unplanned pressure loss of 10 percent or greater, occurring
within a time interval of 15 minutes or less, unless the operator has documented in
advance of the pressure loss the need for a higher pressure-change threshold due
to pipeline flow dynamics that cause fluctuations in gas demand that are typically
higher than a pressure loss of 10 percent in a time interval of 15 minutes or less;
or
3) An unexplained flow rate change, pressure change, instrumentation indication, or
equipment function that may be representative of an event defined in paragraph
(2) of this definition.
Note: Rupture identification occurs when a rupture, as defined in this section, is
first observed by or reported to pipeline operating personnel or a controller.
ii) Within five (5) minutes of the initial notification to GSPC, GSPC must evaluate and
identify a rupture, as defined above, as being either an actual leak event, rupture event
or non-rupture event in accordance with operating procedures and 49 CFR 192.615.
15 The pipeline valve section location to be closed and isolated (if there should be a rupture) must be confirmed by
GSPC through Gas Control or other field operations personnel monitoring of the appropriate pipeline pressures,
pressure changes, or flow rate changes through a compressor discharge section or by location confirmation from
responsible persons.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
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<<<PAGE 14>>>

e) 24-Hour Monitoring by Gas Control Center: The GSPC Gas Control Center must
monitor the special permit segment 24 hours a day, 7 days a week and must confirm the
existence of a leak or rupture in accordance with Condition 12(d)(i) and as soon as
practicable, in accordance with the GSPC pipeline operating procedures;
f) Remote Monitoring of Valves: GSPC must maintain remote monitoring and automatic
control equipment, mainline valves, mainline valve operators, and pressure sensors in
accordance with 49 CFR 192.631 and 192.745. All remote monitoring and automatic
control equipment including pressure sensors must have backup power to maintain
communications and control to the GSPC Gas Control Center during power outages;
g) Point-to-Point Verification: GSPC must conduct a point-to-point verification between
SCADA displays and the mainline valve, sensors, and communications equipment in
accordance with 49 CFR 192.631(c) and (e), or an equivalent verification;
h) Maintenance of Valves: All valves used to isolate a leak or rupture must be maintained
in accordance with this special permit and 49 CFR 192.745;
i) Inoperable Valves: GSPC must take remedial measures to correct any valve used to
isolate a leak or rupture that is found to be inoperable or unable to maintain shut-off, as
follows:
i) Repair or replace the valve as soon as practicable but no later than six (6) months
after the finding;
ii) Designate an alternative valve within seven (7) calendar days of the finding while
repairs are being made. Repairs must be completed within six (6) months; and
iii) If valve repair or replacement cannot be met due to circumstances beyond GSPC’s
control, GSPC must notify the Director, PHMSA Central Region, in writing of
the reasons the schedule cannot be met and obtain a letter of “No Objection”
from PHMSA prior to implementing the schedule change.
j) Communications: GSPC must establish and maintain adequate means of communication
with the appropriate public safety access point (9-1-1 emergency call center) and must
notify them if there is a leak or rupture, as well other emergency responders as required
in 49 CFR 192.615;
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<<<PAGE 15>>>

k) Notifications: GSPC must immediately and directly notify the appropriate public safety
access point (9-1-1 emergency call center) or other coordinating agency for the
communities and jurisdictions in which the pipeline is located when a release is
indicated;16 and
l) Operator Actions During an Emergency: GSPC must establish actions required to be
taken by a pipeline controller, or the appropriate emergency response coordinator,
during an emergency in accordance with these special permit conditions and as required
in 49 CFR 192.615 and 192.631.
13) Documentation: GSPC must maintain the following records for each special permit
segment:
a) Documentation showing that each special permit segment has received a hydrostatic
test for eight (8) continuous hours and at a minimum pressure of 1.25 times MAOP in
accordance with 49 CFR 192.505, Subpart J. If GSPC does not have hydrostatic test
documentation, then the special permit segment must be hydrostatically tested to
meet this requirement within one (1) year of receipt of this special permit.
b) Documentation (mill test reports) showing that the pipe in the special permit segment
meets the wall thickness, yield strength, tensile strength and chemical composition of
either the American Petroleum Institute Standard 5L, 5LX or 5LS, “Specification for
Line Pipe” (API 5L)17 approved by the 49 CFR Part 192 code at the time of
manufacturing, or if the pipe was manufactured and placed in-service prior to the
inception of 49 CFR Part 192, then the pipe meets the API 5L standard in usage at
that time. Any special permit segment that does not have mill test reports for the
pipe cannot be authorized per this special permit.
c) Documentation of compliance with all conditions of this special permit must be kept
for the life of this special permit for the referenced special permit segment and
special permit inspection area.
14) Extension of the Special Permit Segment: PHMSA may extend the special permit segment
to include contiguous segments of the Index 817 Pipeline up to the limits of the special
16 GSPC must designate the pipeline controller or the appropriate operator emergency response coordinator in its
operating procedures and train the pipeline controller or the appropriate operator emergency response coordinator
for coordinating with emergency responders.
17 Standards used for this special permit must be the edition incorporated by reference in 49 CFR 192.7.
Special Permit: PHMSA-2019-0207 - Gulf South Pipeline Company, LP
Index 817 Pipeline
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