# Florida Gas Transmission — Pipeline Special Permit - **operation:** document - **citation:** PHMSA-2020-0001 - **title:** Florida Gas Transmission — Pipeline Special Permit - **source type:** permit - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** current - **official:** true - **published on:** 2023-08-22 - **effective on:** 2023-08-22 - **summary:** PHMSA-2020-0001, issued 2023-08-22 for Florida Gas Transmission's gas transmission system. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2020-0001.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2020-0001.md - **app url:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2020-0001 - **source url:** https://www.regulations.gov/docket/PHMSA-2020-0001 **body:** PHMSA pipeline special permit PHMSA-2020-0001. Operator: Florida Gas Transmission. System: Gas Transmission. Issue date: 2023-08-22. <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 June 24, 2022 Mr. Dave W. Shellhouse Vice President of Operations Florida Gas Transmission Company, LLC 2405 Lucien Way, Suite 200 Maitland, Florida 32751 Re: Docket No. PHMSA-2020-0001 Special Permit from June 24, 2022 to March 31, 2032 Dear Mr. Shellhouse: On March 31, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a special permit for Docket No. PHMSA-2020-0001. The attached special permit has been updated to rectify an error in a survey station number for special permit segment 170717, which was discovered by the company and communicated to PHMSA. The station was updated from Survey Station 60+17 to 24+75 and the overall special permit segment length of 3,668 feet was correct and remains unchanged in the special permit. 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 Mary McDaniel, Director, Office of Pipeline Safety, Southwest Region, may be contacted at (713) 272-2847, for operational matters specific to this special permit. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety <<>> Enclosure: Special Permit – PHMSA-2020-0001 Special Permit: PHMSA-2020-0001 – Florida Gas Transmission Company, LLC Letter of Decision – Class 1 and 2 to Class 3 Locations - Florida Page 2 of 2 <<>> 1200 New Jersey Avenue, SE Washington, D.C. 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration November 6, 2025 Mr. Dave Shellhouse Vice President of Operations Florida Gas Transmission Company, LLC 2301 Lucien Way Maitland, FL 32751 Re: Docket No. PHMSA-2020-0001 Amended Special Permit Effective Through March 31, 2032 Dear Mr. Shellhouse: On March 18, 2025, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Florida Gas Transmission Company, LLC (FGT) applied to the Pipeline and Hazardous Materials Safety Administration (PHMSA) for an amendment to the active special permit, PHMSA-2020-0001, effective through March 31, 2032. The special permit waives compliance with 49 CFR §§ 192.611(a) and (d) and 192.619 (a) for pipeline segments where the class location has changed to Class 3, allowing FGT to continue operating the original Class 1 design pipe in Class 3 locations, subject to the conditions set forth in the special permit. FGT has requested a new special permit segment of 3,587 feet (approximately 0.679 miles) of 26-inch FGT Mainline Loop STA18–STA19 line, and special permit segment extensions totaling 8,009 feet (approximately 1.517 miles) of 30-inch FGT MLV 18-1 to C/S 19 line. The combined length of the requested incorporated special permit segments is 11,596 feet (approximately 2.196 miles), located in Osceola and Brevard counties, Florida. On August 21, 2025, PHMSA published a Federal Register notice (90 FR 40886) announcing the special permit amendment request. The request letter and other pertinent documents are available in Docket No. PHMSA-2020-0001 on the Federal Docket Management System located at www.regulations.gov. 1 PHMSA received one anonymous public comment during the 30-day comment period from August 21, 2025 to September 22, 2025. The comment was submitted on September 8, 2025. Comment summary: The commenter questioned if the PHMSA 2020-0001 special permit 1 https://www.regulations.gov/docket/PHMSA-2020-0001 PHMSA-2020-0001 – 2025 Amendment – Florida Gas Transmission Company, LLC Letter of Decision, SPAF – Class 1 to Class 3 – Florida Page 1 of 2 <<>> conditions will apply to the new and extended special permit segments, including requiring use of remote-controlled valves. PHMSA response: The new special permit segment and extended special permit segments are subject to the conditions in the existing special permit PHMSA-2020-0001, including Condition 12, which requires FGT to automate mainline isolation valves for closure and remote monitoring. PHMSA has reviewed FGT’s request to incorporate two special permit segment extensions and one new special permit segment into special permit PHMSA-2020-0001, along with documentation substantiating the integrity of the pipeline segments. PHMSA determined that the incorporation would not require a material change in conditions and the modification is not inconsistent with pipeline safety. Accordingly, pursuant to 49 CFR § 190.341, by this order—and as outlined in the existing special permit—PHMSA grants the amendment of the special permit, PHMSA-2020-0001, effective through March 31, 2032, to FGT. The amendment continues to waive compliance with certain Federal regulations in 49 CFR §§ 192.611(a) and (d) and 192.619(a). My staff would be pleased to discuss this special permit or any other regulatory matter with you. For technical matters, contact Max Kieba, Director of Engineering and Research Division, at (202) 420-9169. For operational matters specific to this permit, contact James Urisko, Director of the Office of Pipeline Safety, Southern Region, at (404) 771-1905. Sincerely, LINDA GAIL DAUGHERTY Digitally signed by LINDA GAIL DAUGHERTY Date: 2025.11.06 12:51:29 -05'00' Linda Daugherty, Acting Associate Administrator for Pipeline Safety PHMSA-2020-0001 – 2025 Amendment – Florida Gas Transmission Company, LLC Letter of Decision, SPAF – Class 1 to Class 3 – Florida Page 2 of 2 <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration August 22, 2023 1200 New Jersey Avenue, SE Washington, DC 20590 Dave W. Shellhouse Vice President of Operations Florida Gas Transmission Company, LLC 2405 Lucien Way, Suite 200 Maitland, Florida 32751 Re: Docket Nos. PHMSA-2020-0001 and PHMSA-2023-0020 Special Permit from June 24, 2022, to March 31, 2032 Dear Mr. Shellhouse: On March 24, 2023, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Florida Gas Transmission Company, LLC (FGT) 1 applied to the Pipeline and Hazardous Materials Safety Administration (PHMSA) for a special permit (PHMSA 2023-0020) and a special permit segment extension for an existing special permit (PHMSA-2020-0001). FGT requested the special permit to waive compliance with 49 CFR §§ 192.611(a) and (d) and 192.619(a) for Class 1 to Class 3 location changes and an extension of an existing special permit segment. The class location changes includes six (6) pipeline segments consisting of approximately 0.098 miles (515 feet) of 26-inch diameter and approximately 1.849 miles (9,764 feet) of 30-inch diameter gas transmission pipeline (Pipeline) located in Lake, Orange, and Osceola Counties, Florida.2 A gas transmission pipeline operator is required by 49 CFR § 192.611 to confirm or revise the maximum allowable operating pressure of a pipeline segment where the class location has changed as defined in 49 CFR § 192.5. On April 20, 2023, and May 31, 2023, PHMSA published Federal Register notices (88 FR 24464 for Docket PHMSA-2023-0020 and 88 FR 34927 for Docket PHMSA-2020-0001) announcing the Special Permit Request for the five (5) special permit segments and one (1) special permit segment extension. The special permit conditions for Dockets PHMSA-2023-0020 and PHMSA-2020-0001 are being combined going forward into a single docket at Docket PHMSA- 1 Florida Gas Transmission Company, LLC is owned by Energy Transfer and Kinder Morgan, Inc. 2 The new pipeline segments are special permit segments 189579, 202967, 187434, 187440, and 202974 and total 9,824 feet in length. The extended special permit segment is special permit segment 16857 extension and total 455 feet in length. <<>> 2020-0001. The combination of the dockets is due to the special permit requests being in the same pipeline special permit inspection areas along the Pipeline. The Special Permit Request letter, Final Environmental Assessment (FEA) and Finding of No Significant Impact (FONSI), Special Permit Analysis and Findings (SPAF), and all other pertinent documents for this special permit are available in both Docket Nos. PHMSA-2020- 0001 and PHMSA-2023-0020 in the Federal Docket Management System located at www.regulations.gov.3 Subject to the stated terms and conditions, PHMSA grants this special permit (enclosed) based on the information provided by FGT and the findings set forth in the SPAF, FEA, and FONSI. This special permit provides relief from certain provisions of the Federal pipeline safety regulations for the Pipeline and requires FGT to comply with conditions and limitations designed to maintain pipeline safety as defined in the special permit. Note that in accordance with 49 CFR § 190.341(j), PHMSA reserves the right to revoke, suspend, or modify this special permit if circumstances occur in which its continuance would be inconsistent with pipeline safety. If FGT elects not to implement the special permit conditions, FGT must notify PHMSA within 60 days and comply with 49 CFR § 192.611(a) within 18 months of the date of this letter. My staff would be pleased to discuss this special permit or any other regulatory matter with you. Mary McDaniel, Acting Director of PHMSA Engineering and Research Division, may be contacted at (713) 272-2847, on technical matters; and Bryan Lethcoe, Director, Office of Pipeline Safety, Southwest Region, may be contacted at (713) 773-7215, for operational matters specific to this special permit. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosures: Special Permit – PHMSA-2020-0001 – Combined w/PHMSA-2023-0020 3 https://www.regulations.gov/docket?D=PHMSA-2020-0001. https://www.regulations.gov/docket?D=PHMSA-2023-0020.PHMSA-2020-0001 – Combined w/Docket PHMSA-2023-0020 Page 2 of 2 Letter of Decision – Florida Gas Transmission Company, LLC - Class Location – Florida <<>> U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION Special Permit Analysis and Findings Class 1 to Class 3 Locations Special Permit Information: Docket Number: PHMSA-2020-0001 and PHMSA 2023-00201 Requested By: Florida Gas Transmission Company, LLC Operator ID#: 5304 Original Date Requested: December 18, 2019 Original Issuance Date: March 31, 2022 New Segments Request Date:2 March 24, 2023 Effective Dates:3 June 24, 2022, to March 31, 2032 Code Section(s): 49 CFR 192.611(a) and (d) and 192.619(a) Purpose: The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), 4 provides this information to describe the facts of the subject special permit 1 Special permits PHMSA-2020-0001 and PHMSA-2023-0020 are being combined into special permit PHMSA- 2020-0001. The new special permit segments 189579, 202967, 187434, 187440, and 202974 and special permit segment 165857 extension are added in Table 1 and are in the same special permit inspection areas that existed in the original special permit PHMSA-2020-0001. 2 On March 24, 2023, FGT requested the addition of five (5) special permit segments 189579, 202967, 187434, 187440, and 202974. These special permit segments were Federal Register noticed in Docket PHMSA-2023- 0020 and going forward will be addressed under special permit Docket PHMSA-2020-0001. A 455-foot extension to special permit segment 165857 was Federal Register noticed in Docket PHMSA-2020-0001 and added to this special permit Docket PHMSA-2020-0001. 3 The effective date for the implementation of the special permit conditions for special permit segments 189579, 202967, 187434, 187440, and 202974 and the 455-foot extension to special permit segment 165857 is grant date for the special permit that includes the five (5) new special permit segments and one (1) special permit segment extension. 4 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. PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 1 of 16 <<>> application submitted by Florida Gas Transmission Company, LLC (FGT), 5 to discuss any relevant public comments received with respect to the application, to present the engineering and safety analysis of the special permit application, and to make findings regarding whether the requested special permit should be granted and, if so, under what conditions. FGT requested that PHMSA waive compliance from the 49 Code of Federal Regulations (CFR) 192.611(a) and (d) and 192.619(a) for natural gas transmission pipeline segments, where the class location has changed from Class 1 to a Class 3 locations and from Class 2 to Class 3 locations. Pipeline System Affected: This existing special permit applies to the FGT request for a waiver of the class location change requirements in 49 CFR 192.611(a) and (d) and 192.619(a) for approximately 3.761 miles of gas transmission pipelines located in Brevard, Lake, Orange, and Osceola Counties, Florida. Special permit application (2023-0020) for five (5) new special permit segments and one (1) special permit segment extension increases the special permit mileage in the existing permit from approximately 3.761 miles to 4.406 miles (23,266 feet) of gas transmission pipelines located in Lake, Orange, and Osceola Counties, Florida. These special permit segments are in red in Table 2 – Special Permit Segments. Pipe specifications including outside diameter, year installed, seam type, coating type, pipe grade, wall thickness, maximum allowable operating pressure (MAOP), minimum pressure test pressure, and pressure test factor based on the minimum test pressure are detailed in Table 1 – Pipe Specifications by Line Name. Table 1 – Pipe Specifications by Line Name Outside Wall Min. Test Pressure Year Line Name Diameter Installed Seam Type MAOP Coating Type Grade Thickness Pressure Test (psig) (inches) (inches) (psig) Factor Mainline Loop CMPR STA 17-18 26 1968/1969 DSAW Coal Tar Enamel / Fusion Bonded Epoxy X60 0.294 977 1,347 1.38 Mainline Loop STA18-STA19 26 1968 DSAW MLV 18-1 to C/S 19 30 1995 DSAW Coal Tar Enamel / Copolymer Fusion Bonded Epoxy X60 X70 0.294 0.291 974 / 977 975 1,347 1,305 1.38 1.34 Note: DSAW is double submerged arc welded seam pipe. 5 FGT is owned by Energy Transfer and Kinder Morgan, Inc. Energy Transfer operates FGT. PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 2 of 16 <<>> Without this special permit, 49 CFR 192.611(a) would require FGT to replace the special permit segments with stronger pipe or reduce the pipeline MAOP for a Class 1 to Class 3 location change. Special Permit Request: On December 18, 2019, FGT applied to PHMSA for a special permit seeking relief from 49 CFR 192.611(a) and (d) and 192.619(a) for the below-listed special permit segments, where a class location change occurred from the original Class 1 to a Class 3 location and from a Class 2 to Class 3 location on the 26-inch diameter Mainline Loop STA18-STA19, 26-inch diameter Mainline Loop CMPR STA 17-18, and 30-inch diameter MLV 18-1 to C/S 19 Pipelines in Brevard, Lake, Orange, and Osceola Counties, Florida. On March 24, 2023, FGT applied to PHMSA for five (5) new special permit segments and one (1) special permit segment extension on the pipeline special permit inspection areas identified in Table 3 – Special Permit Inspection Areas. This special permit applies to the special permit segments and special permit inspection areas described and defined as follows, using the FGT survey station references: Special Permit Segments: This special permit applies to the special permit segments and is identified using the FGT survey station (SS) references as detailed in Table 2 – Special Permit Segments. PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 3 of 16 <<>> Table 2 – Special Permit Segments Special Permit Start End Outside MAO Diameter Line Name Length (feet) Survey Station Survey Station County, State Class Year Segment Number Summary Installed Seam Type/ Coating Type P (inches) (psig) (SS) (SS) 165856 26 Mainline Loop CMPR STA 17-18 2,368 1835+77 1859+45 Lake, FL 2 to 3 1969 DSAW/CTE 977 165857 26 Mainline Loop CMPR STA 17-18 216 2075+20 2077+36 Lake, FL 2 to 3 1968 DSAW/CTE 977 165857 extension6 26 Mainline Loop CMPR STA 17-18 455 2077+36 2081+91 Lake, FL 2 to 3 1968 DSAW/CTE 977 165858 26 Mainline Loop CMPR STA 17-18 724 2081+91 2089+15 Lake, FL 2 to 3 1969 DSAW/CTE 977 165859 26 Mainline Loop CMPR STA 17-18 587 2089+15 2095+01 Lake, FL 2 to 3 1969 DSAW/CTE 977 165860 26 643 165897 26 Mainline Loop STA18-STA19 169426 26 169427 26 169428 26 Mainline Loop CMPR STA 17-18 3,191 2195+14 2201+57 2 to 3 1969 2967+96 2978+65 1 to 3 Orange, FL DSAW/CTE DSAW/CTE 1968 977 977 189579 26 165900 26 Orange, FL Brevard, FL 1968 Mainline Loop STA18-STA19 614 1100+68 1106+82 Orange, FL 1 to 3 1968 DSAW/ Copolymer7 974 Mainline Loop STA18-STA19 4,618 1106+82 1153+00 Orange, FL 1 to 3 1968 DSAW/ Copolymer 974 1184+91 1 to 3 DSAW/ Copolymer 974 DSAW / Copolymer 974 DSAW/CTE 977 1,069 Mainline Loop STA18-STA19 Mainline Loop STA18-STA19 1153+00 60 1213+93 1214+53 Orange, FL 1 to 3 1968 Mainline Loop STA18-STA19 291 3435+06 3437+97 Brevard, FL 2 to 3 1968 165909 26 Mainline Loop STA18-STA19 1,588 3859+58 3875+46 Brevard, FL 2 to 3 1968 DSAW/CTE 977 170717 30 MLV 18-1 to C/S 19 3,668 24+758 61+43 Osceola, FL 1 to 3 1995 DSAW/FBE 975 165997 30 MLV 18-1 to C/S 19 282 61+43 64+25 Osceola, FL 1 to 3 1995 DSAW/FBE 975 202967 30 MLV 18-1 to C/S 19 159 620+94 622+53 Osceola, FL 1 to 3 1995 DSAW/FBE 975 187434 30 MLV 18-1 to C/S 19 4,869 807+18 855+87 Osceola, FL 1 to 3 1995 DSAW/FBE 975 187440 30 MLV 18-1 to C/S 19 285 1223+57 1226+42 Osceola, FL 1 to 3 1995 DSAW/FBE 975 202974 30 MLV 18-1 to C/S 19 4,451 1056+52 1101+03 Osceola, FL 1 to 3 1995 DSAW/FBE 975 Note: DSAW is a double submerged arc welded pipe longitudinal seam. FBE is fusion bonded epoxy external pipe coating. CTE is coal tar enamel external pipe coating. Special Permit Inspection Areas: The special permit inspection areas are defined as the area that extends 220 yards on each side of the centerline along approximately 185.7 miles of 26-inch diameter Mainline Loop CMPR 6 On March 24, 2023, FGT notified PHMSA that the existing special permit segment 16857 had been extended 455 feet through the implementation of Condition 17. 7 This special permit segment is coated with a butadiene-styrene copolymer external pipe coating. It is a high temperature resistant coating by Esso in the 1960’s. This coating system resembles green FBE however it does not contain any epoxy. It was used on portions of the FGT system just downstream of compressor stations and has proven to be a very effective coating system. 8 Previously, Special Permit Segment 170717 was corrected from Survey Station 60+17 to 24+75 due to a typo error in Table 1. PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 4 of 16 <<>> STA 17-18, 26-inch diameter Mainline Loop STA18-STA19, and 30-inch diameter MLV 18-1 to C/S 19 Pipelines as shown in Table 3 – Special Permit Inspection Areas. Table 3 – Special Permit Inspection Areas Special End Outside Start Survey Permit Special Permit Segment Number(s) Diameter Line Name Station Survey Station Length9 (miles) Inspection Area Name (inches) (MP) (MP) FLMEB-17 165856, 165857 and 165857 extension, 165858, 165859, 165860 26 Mainline Loop CMPR STA 17-18 608.00 668.8 60.8 FLMEB-18 165897, 165900, 165909, 169426, 169427, 169428, 189579 26 Mainline Loop STA18-STA19 668.8 742.5 73.7 FLMED1819 170717, 165997, 202967, 187434, 187440, 202974 30 MLV 18-1 to C/S 19 683.3 734.5 51.2 The special permit inspection areas are in Brevard, Lake, Marion, Orange, and Osceola Counties, Florida. 10 Figures 1 through 3 are maps showing the 26-inch diameter Mainline Loop CMPR STA 17-18, 26-inch diameter Mainline Loop STA18-STA19, and 30-inch diameter MLV 18-1 To C/S 19 Pipelines special permit segments and special permit inspection areas. Public Notice: On March 26, 2020, PHMSA posted a notice of this special permit request in the Federal Register (85 FR 17176) with a closing date of April 27, 2020. PHMSA received no comments on this special permit application during the comment period. PHMSA received the same comment repeated three (3) times several months after the close of the comment period. The comment criticized special permit application processing delay, but the comment did not provide an opinion on the safety or merit of this specific proposed special permit. PHMSA published the special permit request for the extension of special permit segment 165857 in the Federal Register (88 FR 34927) for a 30-day public comment period from May 31, 2023, through June 30, 2023. The special permit application from FGT, draft environmental assessment, and draft special permit conditions are available in Docket No. PHMSA-2020-0001 on the Federal Docket Management System (FDMS) located on the internet at 9 If the special permit inspection area footage does not extent from launcher to receiver, then the special permit inspection area would need to be extended. 10 The special permit inspection areas include the special permit segments. PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 5 of 16 <<>> www.Regulations.gov. PHMSA received no comments on this special permit application during the comment period. PHMSA published the special permit request for the five (5) new special permit segments in the Federal Register (88 FR 24464) for a 30-day public comment period from April 20, 2023, through May 22, 2023, with public comments to be posted on Docket PHMSA-2023-0020. PHMSA sought comments on any potential environmental impacts that could result from the selection of either alternative, including the special permit conditions. PHMSA received one (1) public comment for the five (5) new special permit segments on Docket PHMSA-2023-0020 in the FDMS located on the internet at www.Regulations.gov. • The Anonymous Comment recommended the special permit to not be issued to protect the environment and speed up the transition to renewable energy. PHMSA has conducted a review of the special permit request and has determined that implementation of the special permit conditions by FGT will not harm the environment. The request to speed up the transition to renewable energy is beyond the scope of this notice. PHMSA has reviewed this special permit application to ensure the special permit conditions address pipeline safety and integrity threats to the pipeline in the special permit segments and special permit inspection areas. The special permit will require FGT’s Operations and Maintenance (O&M) Manual and Procedures to provide a systematic program to review and remediate the pipeline for safety concerns. Additional operational integrity reviews and remediation requirements will be required by this special permit for these special permit segments for Class 1 to 3 location changes or Class 2 to 3 location changes. The FGT special permit application letter, Federal Register notice, FEA and FONSI, special permit with conditions, special permit analysis and findings document, and all other pertinent documents are available for review in Docket Nos. PHMSA-2020-0001 and PHMSA-2023-0020 in the FDMS located on the internet at www.Regulations.gov. Analysis: Background: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the criteria it uses for the consideration of applications for class location change waivers, now being PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 6 of 16 <<>> granted or denied through a special permit. First, certain threshold requirements should be met on a pipeline special permit segment for a class location change special permit to be granted. Second, the age and manufacturing process of the pipe; system design, and construction; environmental, operating and maintenance histories; and integrity management program elements are evaluated as significant criteria. These significant criteria are presented in matrix form and can be reviewed in the FDMS, Docket No. PHMSA–RSPA-2004-17401. Third, special permits will only be granted when pipe conditions and active integrity management provides a level of safety greater than or equal to a pipe replacement or pressure reduction. The operator’s Federal pipeline safety regulation compliance history is also evaluated as part of the criteria matrix for acceptability prior to issuance of a special permit. Threshold Requirements: Each of the threshold requirements published by PHMSA in the June 29, 2004, Federal Register notice is discussed below regarding the FGT special permit request. 1) No pipeline segments in a class location changing to Class 4 location will be considered. • This special permit request is for the special permit segments on the FGT 26-inch diameter Mainline Loop CMPR STA 17-18, 26-inch diameter Mainline Loop STA18- STA19, and 30-inch diameter MLV 18-1 To C/S 19 Pipelines, where a change has occurred from a Class 1 location to a Class 3 location or a Class 2 location to a Class 3 location. • FGT has met this requirement. 2) No bare pipe will be considered. • The special permit segments are externally coated with coal tar epoxy or fusion bonded epoxy. FGT has met this requirement of no bare pipe. • FGT has not reported any coating issues such as disbonded coating. • FGT has met this requirement. 3) No pipe containing wrinkle bends will be considered. • There are no wrinkle bends in the special permit segments. • FGT has met this requirement. 4) No pipe segments operating above 72% of the specified minimum yield strength (SMYS) will be considered for a Class 3 special permit. • The special permit segments operate at or below 72% SMYS. PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 7 of 16 <<>> • The pipe for the special permit segments on the Mainline Loop CMPR STA 17-18 Pipeline is 26-inch diameter, 0.294-inch wall thickness, pipe strength of 60,000 psig. The pipe seam is a double submerged, arc-welded seam and was manufactured by Kaiser Steel in 1968. • The pipe for the special permit segments on the Mainline Loop STA18-STA19 Pipeline are 26-inch diameter, 0.294-inch wall thickness, pipe strength of 60,000 psig. The pipe seam is a double submerged, arc-welded seam and was manufactured by Kaiser Steel in 1968. • The pipe for the special permit segments on the MLV 18-1 To C/S 19 Pipeline are 30- inch diameter, 0.291-inch wall thickness, pipe strength of 70,000 psig. The pipe seam is a double submerged, arc-welded seam and was manufactured by Napa Pipe Corporation in 1993. • FGT has met this requirement. 5) Records must be produced that show a hydrostatic test to at least 1.25 x MAOP and 90% of SMYS. • The special permit segments on the Mainline Loop CMPR STA 17-18 Pipeline were pressure tested in 1968 at 1,349 psig for 24 hours. • The special permit segments on the Mainline Loop STA18-STA19 Pipeline were pressure tested in 1968 at 1,347 psig for 24 hours. • The special permit segments on the MLV 18-1 To C/S 19 Pipeline were pressure tested in 1994 at 1305 psig for eight (8) hours. • FGT has met this pressure requirement, but pressure test records must meet 49 CFR 192.517(a). 6) In-line inspection (ILI) must have been performed with no significant anomalies identified that indicate systemic problems such as stress corrosion cracking (SCC). • FGT ran ILI tools on the Mainline Loop CMPR STA 17-18 Pipeline in 2006, 2013, and 2020. • FGT ran ILI tools on the Mainline Loop STA18-STA19 Pipeline in 2004, 2011, and 2018. • FGT ran ILI tools on the MLV 18-1 To C/S 19 Pipeline in 2009 and 2015. PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 8 of 16 <<>> • FGT has had no SCC findings or failures on these segments. Due to the coating type and operational and environmental conditions of the pipeline, FGT has evaluated the special permit segments and special permit inspection areas as being not susceptible to SCC in accordance with ASME B31.8S. 7) Criteria for consideration of a class location change waiver, being considered through the special permit, published by PHMSA in the Federal Register (69 FR 38948), define a waiver inspection area (special permit inspection area) as up to 25 miles of pipe on either side of the waiver segment (special permit segment). • A special permit would be contingent upon FGT’s incorporation of the special permit segments in its written integrity management program as covered segments in a high consequence area in accordance with 49 CFR 192.903 and to assess and remediate threats to the special permit inspection areas. Criteria Matrix: The data submitted by FGT for the special permit segments have been compared to the class location change special permit criteria matrix. The data fall within the probable acceptance or the possible acceptance column of the criteria matrix, except for PHMSA enforcement findings which fall under the requires substantial justification. • The special permit segments fall in the probable acceptance column of the criteria matrix for: o Class 2 to 3 location, pipe manufacturer (MLV 18-1 To C/S 19 Pipeline), pipe material, design stress, coating type (MLV 18-1 To C/S 19 Pipeline), girth welds (Mainline Loop STA18-STA19 and MLV 18-1 To C/S 19 Pipelines), depth of pipe cover, test pressure, test failures, local geology, type service, pressure fluctuations, safety related conditions, direct assessment, ILI type, and damage prevention program. • The special permit segments fall in the possible acceptance column of the criteria matrix for: o Class 1 to 3 location, pipe manufacturer (Mainline Loop CMPR STA 17-18 and Mainline Loop STA18-STA19 Pipelines), pipe coating type (may shield cathodic protection (CP) Mainline Loop CMPR STA 17-18 and Mainline Loop STA18- STA19 Pipelines), leaks and failures, CP, HCA program, and ILI program. PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 9 of 16 <<>> • The special permit segments fall in the requires substantial justification column of the criteria matrix for: o Pipe girth weld records are not available for the Mainline Loop CMPR STA 17- 18 Pipeline. o Energy Transfer and Kinder Morgan, Inc. are co-owners of FGT. Energy Transfers overall enforcement findings fall in the requires substantial justification category. FGT enforcement findings do not fall within this category. Operational Integrity Compliance: To inform PHMSA’s decision about whether a special permit could provide a level of safety greater than or equal to a pipe replacement or pressure reduction and is consistent with pipeline safety, PHMSA reviewed this special permit request to understand the known type of integrity threats that are in the special permit segments and special permit inspection areas. This integrity information was used to design special permit conditions to provide a systematic program to review and remediate the pipeline for safety concerns. Additional operational integrity review and remediation requirements are required by this special permit to ensure that the operator has an ongoing program to locate and remediate safety threats. These threats to integrity and safety include any issues with the pipe coating quality, cathodic protection effectiveness, operations damage prevention program, pipe depth of soil cover, weld seam and girth weld integrity, anomalies in the pipe steel and welds, and material and structures either along or near the pipeline that could cause the cathodic protection system to be ineffective. PHMSA has carefully designed a comprehensive set of conditions that FGT must implement to comply with this special permit. Past Enforcement History – January 1, 2013, through June 30, 2023: During January 1, 2013, through June 30, 2023, FGT was cited in eight (8) enforcement actions with a total of $1,050,900 in assessed civil penalties. PHMSA issued two (2) Corrective Action Orders, three (3) Notice of Probable Violation, two (2) Notices of Amendments, and one (1) Warning Letter to FGT. Tables 4 and 5 below show PHMSA enforcement actions and civil penalties for FGT: PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 10 of 16 <<>> Table 4 - FGT Enforcement Matters from January 1, 2013, through June 30, 2023 Notice of Status Corrective Action Order Notice of Safety Probable Amendment Order Warning Letter Total Violation CLOSED 1 2 1 0 1 5 OPEN 1 0 2 0 0 3 Total 2 2 3 0 1 8 Table 5 - FGT Enforcement Matters from January 1, 2013, through June 30, 2023 Proposed Awaiting Order Assessed Withdrawn/Reduced Collected $1,050,900 $834,400 $216,500 $216,500 $0 From January 1, 2013, through June 30, 2023, Energy Transfer, the operator of FGT, was cited in 35 enforcement actions with a total of $4,064,612 in assessed civil penalties on their Energy Transfer Company (ETC), Florida Gas Transmission Company (FGT), Panhandle Eastern Company (PEPL), Transwestern Pipeline Company (Transwestern), and Trunkline Gas Company (Trunkline) pipeline systems. PHMSA issued two (2) Corrective Action Orders, ten (10) Notice of Amendments, thirteen (13) Notices of Probable Violations, one (1) Safety Order, and nine (9) Warning Letters to Energy Transfer. Tables 6 and 7 below show PHMSA’s enforcement actions and civil penalties for Energy Transfer Partners on these pipeline systems – ETC, FGT, PEPL, Transwestern, and Trunkline with operator identification numbers (OPID#) 32099, 5304, 15105, 19610, and 19730. Table 6 - Summary of Enforcement Findings for ETC, FGT, PEPL, Transwestern, and Trunkline from January 1, 2013, through June 30, 2023 Notice of Status Corrective Action Order Notice of Safety Probable Amendment Order Warning Letter Total Violation CLOSED 1 9 10 1 9 30 OPEN 1 1 3 0 0 5 Total 2 10 13 1 9 35 PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 11 of 16 <<>> Table 7 - ETC, FGT, PEPL, Transwestern, and Trunkline Civil Penalty Status January 1, 2013, through June 30, 2023 Proposed Awaiting Order Assessed Withdrawn/Reduced Collected $4,064,612 $3,308,312 $756,300 $0 $756,300 Summary of enforcement findings for the ETC, FGT, PELP, Transwestern, and Trunkline systems include: construction, corrosion control, integrity management, procedural manual, operations and maintenance procedures, qualification of operating personnel, public awareness, reporting, welding, design, transportation of underground natural gas storage, and transportation of hazard liquids. These 49 CFR Part 192 code violations are in the following code sections: • 49 CFR 191.5, 191.23, 192.12, 192.167, 192.225, 192.402, 192.452, 192.463, 192.465, 192.467, 192.469, 192.471, 192.479, 192.481, 192.605, 192.615, 192.616, 192.619, 192.709, 192.739, 192.745, 192.805, 192.905, 192.907, 192.917, 192.919, 192.927, 192.933, 192.935, and 192.937. Table 8 below gives a complete summary of the findings and the specific 49 CFR Part 191 and 192 violations: Table 8 - Summary of Enforcement Findings for ETC, FGT, PEPL, Transwestern, and Trunkline January 1, 2013, through June 30, 2023 Construction 1 Corrosion Control 13 Integrity Management 29 OME Procedural Manual 17 Operation and/or Maintenance 14 Operator Qualification 2 Public Awareness 3 Reporting 4 Welding 1 Transportation of Design 1 Underground 2 Transportation of HL 2 Natural Gas Storage Grand Total: 89 PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 12 of 16 <<>> Findings: Based on the information submitted by FGT and PHMSA’s analysis of the technical, operational, and safety issues, PHMSA finds that granting this special permit to FGT to operate the special permit segments including five (5) new special permit segment and the extension of one (1) special permit segment on the 26-inch diameter Mainline Loop STA18-STA19, 26-inch diameter Mainline Loop CMPR STA 17-18, and 30-inch diameter MLV 18-1 to C/S 19 Pipelines in Brevard, Lake, Orange, and Osceola Counties, Florida, for approximately 4.406 miles (previous mileage was 3.761 miles) of Class 1 or Class 2 location pipe in a Class 3 location is consistent with pipeline safety. FGT’s enforcement record does not reflect sustained and substantial noncompliance with 49 CFR Part 192. PHMSA has designed special permit conditions to effectively assess and remediate threats to the special permit segments and special permit inspection areas, including assessments to evaluate pipe girth welds that have not been non-destructively tested, and any pipe with inadequate pressure test or material records. To ensure FGT properly implements the special permit conditions, FGT will be required to give PHMSA an annual review of their compliance with the special permit. PHMSA finds that no significant negative impact to human safety and the environment will result from the issuance and full implementation of a special permit that waives the requirements of 49 CFR 192.611(a) and (d) and 192.619(a) for class location changes to a Class 3 location. This permit requires FGT to implement the special permit conditions which include safety requirements on the operations, maintenance, and integrity management of the special permit segments and the special permit inspection areas. Completed in Washington DC on: August 22, 2023 Prepared by: PHMSA - Engineering and Research Division PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 13 of 16 <<>> Figure 1 – FGT Special Permit Segments and Inspection Areas PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 14 of 16 <<>> Figure 2 – FGT Special Permit Segments and Inspection Area PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 15 of 16 <<>> Figure 3 – FGT Special Permit Segments and Inspection Area Final Page of the Special Permit Analysis and Findings PHMSA-2020-0001 – Florida Gas Transmission Company Special Permit Analysis and Findings – Class 1 and 2 to Class 3 Locations - FL Page 16 of 16 <<>> U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 March 25, 2022 Mr. Dave W. Shellhouse Vice President of Operations Florida Gas Transmission Company, LLC 2405 Lucien Way, Suite 200 Maitland, Florida 32751 Re: Docket No. PHMSA-2020-0001 Special Permit from March 25, 2022 to March 25, 2032 Dear Mr. Shellhouse: On December 18, 2019, pursuant to the 49 Code of Federal Regulations (CFR) § 190.341, Florida Gas Transmission Company, LLC (FGT)1 applied to the P - **truncated:** true - **body characters:** 396608