{"operation":"document","citation":"PHMSA-2020-0007","title":"Southern Natural Gas Company, LLC — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2022-07-27","effective_on":"2022-07-27","summary":"PHMSA-2020-0007, issued 2022-07-27 for Southern Natural Gas Company, LLC's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2020-0007.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2020-0007.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2020-0007","source_url":"https://www.regulations.gov/docket/PHMSA-2020-0007","body":"PHMSA pipeline special permit PHMSA-2020-0007. Operator: Southern Natural Gas Company, LLC. System: Gas Transmission. Issue date: 2022-07-27. Renewal: Extension.\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 Locations\nSpecial Permit Information:\nDocket Number: PHMSA-2020-0007\nRequested By: Southern Natural Gas Company, LLC\nOperator ID#: 18516\nOriginal Date Requested: December 23, 2019\nOriginal Issuance Date: July 27, 2022\nCode Section(s): 49 CFR 192.611(a) and (d) and 192.619(a)\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS),\n1 provides this information to describe the facts of the subject special permit\napplication submitted by Southern Natural Gas Company, LLC (SNG),\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. SNG requested that PHMSA\nwaive compliance from the 49 Code of Federal Regulations (CFR) 192.611(a) and (d) and\n192.619(a) for natural gas transmission pipeline segments, where the class location has changed\nfrom Class 1 to a Class 3 locations.\nPipeline System Affected:\nThis special permit application applies to the SNG request for a waiver of the class location\nchange requirements in 49 CFR 192.611(a) and (d) and 192.619(a) for approximately 0.621\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 Southern Natural Gas Company, LLC is owned by Kinder Morgan, Inc.\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 1 of 11\n\n<<<PAGE 2>>>\n\nmiles of gas transmission pipelines located in Effingham and Harris Counties, Georgia; and\nClarke County, Mississippi.\nPipe specifications including outside diameter, year installed, seam type, coating type, pipe\ngrade, wall thickness, maximum allowable operating pressure (MAOP), minimum pressure test\npressure, and pressure test factor based on the minimum test pressure are detailed in Table 1 –\nPipe Specifications by Line Name.\nTable 1 – Pipe Specifications by Line Name\nOutside\nWall\nMin Test\nPressure\nYear\nSeam\nLine Name\nDiameter\nInstalled\nType\nCoating\nType MAOP\nGrade\nThickness\nPressure\nTest\n(psig)\n(inches)\n(inches)\n(psig)\nFactor\nCypress\nLine 24 2007 ERW-HF FBE X70 0.298 1,250 1,602 1.28\nSouth Main\n2nd Loop\nLine\n26 1967 DSAW Coal Tar\nEnamel X60 0.375 1,200 1,600 1.33\nSouth Main\n3rd Loop\nLine\n36 2003 /\n2004 DSAW Polymer\nConcrete X70 0.562 0.438 /\n1,200 1,552 /\n1,881 1.29\nNotes: ERW-HF is Electric Resistance Welded-High Frequency.\nDSAW is double submerged arc welded pipe weld seam type.\nPSIG is pounds per square inch gauge.\nWithout this special permit, 49 CFR 192.611(a) would require SNG to replace the special permit\nsegments with stronger pipe or reduce the pipeline MAOP for a Class 1 to Class 3 location\nchange.\nSpecial Permit Request:\nOn December 23, 2019, SNG applied to PHMSA for a special permit seeking relief from 49 CFR\n192.611(a) and (d) and 192.619(a) for the below-listed special permit segments, where a class\nlocation change occurred from the original Class 1 to a Class 3 location on the 24-inch diameter\nCypress Line, 26-inch diameter South Main 2nd Loop Line, and 36-inch diameter South Main 3rd\nLoop Line Pipelines in Effingham and Harris Counties, Georgia; and Clarke County,\nMississippi.\nThis special permit applies to the special permit segments and special permit inspection areas\ndescribed and defined as follows, using the SNG survey station references:\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 2 of 11\n\n<<<PAGE 3>>>\n\nSpecial Permit Segments:\nThis special permit applies to the special permit segments in Table 2 – Special Permit\nSegments and are identified using the SNG mile post (MP) and survey station (SS) references.\nTable 2 – Special Permit Segments\nSpecial Permit\nOutside\nStart Survey\nEnd Survey\nSegment\nDiameter\nLine Name Number3\nLength\n(feet)\nCounty,\nNo.\nYear\nSeam\nMAOP\nStation (MP\nStation (MP\nState\nDwellings\nInstalled\nType\n(psig)\n(inches)\n- SS)\n- SS)\n1\n(KM 555) 24 Cypress Line 1,503.00 2 – 3968 3 – 191 GA Effingham,\n1 2007 ERW-\nHF 1,250\n2\n(KM 556) 26 South Main 2nd\nLoop Line 224.78 77 – 1899 77 – 2124 Clarke,\nMS 3 1967 DSAW 1,200\n4\n(KM 558) 36 South Main 3rd\nLoop Line 329.96 77 – 1728 77 – 2058 Clarke,\nMS 4 2003 DSAW 1,200\n5\n(KM 559) 36 South Main 3rd\nLoop Line 1,220.32 315 – 1862 315 – 3083 Harris, GA 7 2004 DSAW 1,200\nNote: ERW-HF is a high frequency electric resistance welded pipe longitudinal seam.\nDSAW is double submerged arc welded pipe longitudinal seam.\nSpecial Permit Inspection Areas:\nThe special permit inspection areas are defined as the area that extends 220 yards on each side\nof the centerline as listed in Table 3 – Special Permit Inspection Areas.\nTable 3 – Special Permit Inspection Areas\nSpecial\nSpecial\nPermit\nOutside\nStart Survey\nEnd Survey\nPermit\nLength4\nInspection\nDiameter\nLine Name Master Segment\nStation\nStation\nSegment(s)\n(miles)\nArea\n(inches)\n(SS)\n(SS)\nIncluded\nNumber\n24 87.63\n1 1\n(KM 555) Cypress Line Cypress Line 1 00 – 24.78 87 – 4810 2 2\n(KM 556) 26 South Main 2nd Loop Line Enterprise to York 67 – 1394 102 – 4372 35.57\n3 4\n(KM 558) 36 South Main 3rd Loop Line Enterprise Station 67 – 1631 97 – 2268 30.06\n4 5\n(KM 559) 36 South Main 3rd Loop Line D/S of Ellerslie 311 - 3355 328 - 1743 16.46\nPublic Notice:\nOn January 22, 2021, PHMSA posted a notice of this special permit request in the Federal\nRegister (86 FR 6737) with a closing date of February 22, 2021. PHMSA received no comments\n3 On February 3, 2022, SNG rescinded requested special permit segments number 3 (KM 557) and 6 (KM 560).\nThese segments were withdrawn at the request of PHMSA\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.\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 3 of 11\n\n<<<PAGE 4>>>\n\non this special permit application during the comment period.\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 areas. The special permit will require SNG’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 SNG special permit application letter, Federal Register notice, Final Environmental\nAssessment and Finding of No Significant Impact, special permit with conditions, special permit\nanalysis and findings document, and all other pertinent documents are available for review in\nDocket No. PHMSA-2020-0007 in the Federal Docket Management System (FDMS) located on\nthe 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 regarding the SNG special permit request.\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 4 of 11\n\n<<<PAGE 5>>>\n\n1) No pipeline segments in a class location changing to Class 4 location will be considered.\n• This special permit request is for the special permit segments the 24-inch diameter\nCypress Line, 26-inch diameter South Main 2nd Loop Line, and 36-inch diameter South\nMain 3rd Loop Line Pipelines, where a change has occurred from a Class 1 location to a\nClass 3 location.\n• SNG has met this requirement.\n2) No bare pipe will be considered.\n• The special permit segments are externally coated with poly concrete, epoxy, coal tar\nenamel, or fusion bonded epoxy.\n• SNG has met this requirement.\n3) No pipe containing wrinkle bends will be considered.\n• There are no wrinkle bends in the special permit segments.\n• SNG has met 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• SNG has met this requirement.\n5) Records must be produced that show a hydrostatic test to at least 1.25 times MAOP and 90%\nof SMYS. The records should include test pressure, year of the test, test duration, and\npressure test percent of MAOP for each pipeline:\n• The special permit segments on the Cypress Line, South Main 2nd Loop Line, and\nSouth Main 3rd Loop Line Pipeline were all pressure tested for 8 hours to at least 1.25\ntimes the pipeline MAOP.\n• SNG has met 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• SNG ran ILI tools on the Cypress Line Pipeline in 2016.\n• SNG ran ILI tools on the South Main 2nd Loop Line Pipeline in 2010.\n• SNG ran ILI tools on the South Main 3rd Loop Line Pipeline one segment was\ncompleted in 2014 and the other in 2019.\n• SNG has met this requirement.\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 5 of 11\n\n<<<PAGE 6>>>\n\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).\n• A special permit would be contingent upon SNG’s incorporation of the special permit\nsegments in its written integrity management program as covered segments in a high\nconsequence area in accordance with 49 CFR 192.903 and to assess and remediate\nthreats to the special permit inspection areas.\nCriteria Matrix: The data submitted by SNG for the special permit segments have been\ncompared to the class location change special permit criteria matrix and are as follows:\n• The special permit segments fall in the probable acceptance column of the criteria\nmatrix for:\no Design stress, test failures, pressure fluctuations, safety related condition reports,\nprogram, ILI type, direct assessment, coating assessment, and damage prevention.\n• The special permit segments fall in the possible acceptance column of the criteria\nmatrix for:\no Class 1 to 3 location, pipe manufacture, pipe girth welds, pipe coating, test\npressure, depth of cover, local geology, leaks and failures, service, cathodic\nprotection (CP), ILI timeframe, and inspection findings.\n• The special permit segments fall in the requires substantial justification column of the\ncriteria matrix for:\no Kinder Morgan, Inc. overall enforcement findings fall in the requires substantial\njustification category. SNG’s 11-year enforcement findings do not fall within this\ncategory.\no This special permit requires SNG to implement the special permit conditions that\ninclude safety requirements on the operations, maintenance, and integrity\nmanagement of the special permit segments (approximately 0.621 miles) and the\nspecial permit inspection areas (169.72 miles). Therefore, the safety benefits are\nobtained well beyond the portion of the pipeline that experienced a class location\nchange.\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 6 of 11\n\n<<<PAGE 7>>>\n\no SNG will be required to submit to PHMSA an annual report for this special\npermit on integrity threats to the pipeline in the special permit segment and the\nspecial permit inspection area.\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 areas. This\nintegrity information was used to design special permit conditions to provide a systematic\nprogram to review and remediate the pipeline for safety concerns. Additional operational\nintegrity review and remediation requirements are required by this special permit to ensure that\nthe operator has an ongoing program to locate and remediate safety threats. These threats to\nintegrity and safety include any issues with the pipe coating quality, CP effectiveness, operations\ndamage prevention program, pipe depth of soil cover, weld seam and girth weld integrity,\nanomalies in the pipe steel and welds, and material and structures either along or near the\npipeline that could cause the CP system to be ineffective. PHMSA has carefully designed a\ncomprehensive set of conditions that SNG must implement to comply with this special permit.\nPast Enforcement History – January 1, 2011 through January 31, 2022:\nDuring January 1, 2011 through January 31, 2022, SNG was cited in four (4) enforcement actions.\nPHMSA issued one (1) Notice of Amendment, one (1) Notice of Probable Violation and two (2)\nWarning Letters to SNG. Tables 4 and 5 below show PHMSA’s enforcement actions and civil\npenalties for SNG:\nTable 4: SNG Enforcement Matters from\nJanuary 1, 2011, through January 31, 2022\nNotice of\nStatus Corrective\nAction Order\nNotice of\nSafety\nProbable\nAmendment\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 0 1 1 0 2 4\nOPEN 0 0 0 0 0 0\nTotal 0 0 1 0 2 4\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 7 of 11\n\n<<<PAGE 8>>>\n\nTable 5: SNG Enforcement Civil Penalty Status\nJanuary 1, 2011 through January 31, 2022\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$72,900 $0 $72,900 $0 $72,900\nSummary of Enforcement Findings for SNG includes: Reporting, welding, conversion of\nservice, operations and maintenance procedures, records, and integrity management:\n• 49 CFR 192.161, 192.163, 192.3, 192.465, 192.475, 192.605, 192.705, 192.709, 192.735,\n192.745, and 192.911,\nTable 6 below shows PHMSA’s enforcement actions and civil penalties for SNG and the specific 49\nCFR Part 191 and 192 violations:\nTable 6: Summary of Enforcement Findings for SNG\nJanuary 1, 2011 through January 31, 2022\nNotice of Amendment\nOME Procedural Manual 4 Integrity Management 7\nNotice of Amendment Total: 11\nNotice of Probable Violation\nCorrosion Control 2 Operation and/or Maintenance 1 Integrity Management 3\nOME Procedural Manual 2 Design 1\nNotice of Probable Violation Total: 10\nWarning Letter\nDesign 1 Operation and/or Maintenance 2\nWarning Letter Total: 3\nGrand Total: 24\nSummary of Enforcement Findings for the Kinder Morgan Gas Pipelines Companies - CIG,\nEPNG, NGPL, SNG, TEJAS, and TGP:\nFrom January 1, 2011, through January 31, 2022, Kinder Morgan, the operator of NGPL, was cited in\n64 enforcement actions with a total of $1,077,800 in assessed civil penalties on its Colorado Interstate\nGas Company (CIG), El Paso Natural Gas Company (EPNG), Natural Gas Pipeline of America\n(NGPL), Southern Natural Gas Company (SNG), Tejas Pipeline (TEJAS), and Tennessee Gas Pipeline\nCompany (TGP) pipeline systems. PHMSA issued sixteen (16) Notice of Amendments, twenty-two\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 8 of 11\n\n<<<PAGE 9>>>\n\n(22) Notices of Probable Violations, twenty-one (21) Warning Letters, one (1) Safety Order, and six\n(6) Corrective Action Orders to Kinder Morgan.\nTables 7 and 8 below show PHMSA’s enforcement actions and civil penalties for Kinder\nMorgan on these pipeline systems – CIG, EPNG, NGPL, SNG, TEJAS, and TGP with operator\nidentification numbers (OPID#) 2564, 4280, 13120, 18516, 4900, and 19160.\nTable 7 - Kinder Morgan Enforcement Matters from\nJanuary 1, 2011, through January 31, 2022\nNotice of\nStatus Corrective\nAction Order\nNotice of\nSafety\nProbable\nAmendment\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 5 16 21 1 21 64\nOPEN 3 1 1 0 0 5\nTotal 8 17 22 1 21 69\nTable 8 - Kinder Morgan Enforcement Civil Penalty Status\nJanuary 1, 2011 through January 31, 2022\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$1,461,500 $0 $1,077,800 $383,700 $1,077,800\nThe type of 49 CFR Part 192 enforcement violations against Kinder Morgan on these six (6)\npipeline systems from January 1, 2011, through January 31, 2022, were as follows:\nSummary of Enforcement Findings for CIG, EPNG, NGPL, SNG, TEJAS, and TGP\nincludes: reporting, design, welding, compliance with specifications or procedures, corrosion\ncontrol, operations and maintenance procedures, continuing surveillance, public awareness,\nemergency plans, maximum allowable operating pressure, control room management, relief\ndevices, maintenance of valves, qualification of operating personnel, and integrity management:\n• 49 CFR 191.5, 191.14, 191.15, 191.22, 191.25, 191.27, 192.12, 192.14, 192.161, 192.199,\n192.225, 192.227, 192.229, 192.303, 192.459, 192.463, 192.465, 192.469, 192.475, 192.479,\n192.481, 192.603, 192.605, 192.613, 192.615, 192.616, 192.619, 192.625, 192.631, 192.705,\n192.706, 192.707, 192.709, 192.713, 192.735, 192.736, 192.739, 192.743, 192.745, 192,805,\n192.807, 192.905, 192.911, 192.917, 192.921, 192.933, 192.935, and 192.937.\nTable 9 below gives a complete summary of the findings and the specific 49 CFR Part 191 and 192\nviolation:\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 9 of 11\n\n<<<PAGE 10>>>\n\nTable 9 – Summary of Enforcement Findings for CIG, EPNG, Tejas, NGPL, SNG, and TGP\nJanuary 1, 2011 through January 31, 2022\nNotice of Amendment\nOME Procedural Manual 11 Operation and/or Maintenance 2 Operator Qualification 3\nPublic Awareness 8 Reporting 3 Transportation of Gas 5\nIntegrity Management 10 Control Room Management 4 Construction 1\nWelding of Steel in Pipelines 3\nNotice of Amendment Total: 50\nNotice of Probable Violation\nCorrosion Control 13 OME Procedural Manual 14 Operation and/or Maintenance 26\nOperator Qualification 7 Public Awareness 2 Reporting 5\nIntegrity Management 10 Control Room Management 1 Welding of Steel in Pipelines 1\nDesign 2\nNotice of Probable Violation Total: 81\nWarning Letter\nCorrosion Control 10 OME Procedural Manual 9 Operation and/or Maintenance 31\nOperator Qualification 2 Public Awareness 4 Reporting 1\nTransportation of Gas 1 Integrity Management 1 Design 1\nNotice of Amendment Total: 60\nGrand Total: 191\nFindings:\nBased on the information submitted by SNG and PHMSA’s analysis of the technical,\noperational, and safety issues, PHMSA finds that granting this special permit to SNG to operate\nthe special permit segments on the 24-inch diameter Cypress Line, 26-inch diameter South Main\n2nd Loop Line, and 36-inch diameter South Main 3rd Loop Line Pipelines in Harris and\nEffingham Counties, Georgia, and Clarke County, Mississippi, for approximately 0.621 miles of\nClass 1 location pipe in a Class 3 location is consistent with pipeline safety.\nPHMSA has designed the special permit conditions to effectively assess and remediate threats to\nthe special permit segments and special permit inspection areas, including pressure testing,\nobtaining pipe material records, and conducting assessments to evaluate pipe girth welds that\nhave not been non-destructively tested, any pipe with missing material records, and SCC. To\nensure SNG properly implements the special permit conditions, SNG will be required to give\nPHMSA an annual review of their compliance with the special permit.\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 10 of 11\n\n<<<PAGE 11>>>\n\nPHMSA finds that no significant negative impact to human safety and the environment will\nresult from the issuance and full implementation of a special permit that waives the requirements\nof 49 CFR 192.611 for class location changes to a Class 3 location. This special permit requires\nSNG to implement the special permit conditions that include safety requirements on the\noperations, maintenance, and integrity management of the special permit segments and the\nspecial permit inspection areas. SNG will be required to implement the special permit\nconditions along the special permit segments and special permit inspection areas in pipeline\nsegments that are not high consequence areas and would not normally be required by 49 CFR\nPart 192 to be assessed on a periodic interval for threats.\nCompleted in Washington DC on: July 27, 2022\nPrepared by: PHMSA - Engineering and Research Division\nFinal Page of the Special Permit Analysis and Findings\nPHMSA-2020-0007 – Southern Natural Gas Company, LLC Special Permit Analysis and Findings – Class 1 to Class 3 Locations – MS and GA\nPage 11 of 11\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nJuly 27, 2022\nMr. Kenneth W. Grubb\nChief Operating Officer\nKinder Morgan Natural Gas Division\n1001 Louisiana Street, Suite 1000\nHouston, Texas 77002\nRe: Docket No. PHMSA-2020-0007\nSpecial Permit from July 27, 2022 to July 27, 2032\nDear Mr. Grubb:\nOn December 23, 2019, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Southern\nNatural Gas Company, LLC (SNG)1 applied to the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) for a special permit. SNG requested a special permit to waive\ncompliance with 49 CFR §§ 192.611(a) and (d), and 192.619(a) for Class 1 to Class 3 location\nchanges on four (4) pipeline segments for approximately 0.621 miles of 24-inch, 26-inch, and\n36-inch diameter gas transmission pipelines (Pipelines) located in Effingham and Harris\nCounties, Georgia; and Clarke County, Mississippi. A gas transmission pipeline operator is\nrequired by 49 CFR § 192.611 to confirm or revise the maximum allowable operating pressure of\na pipeline segment where the class location has changed as defined in 49 CFR § 192.5.\nOn January 22, 2021, PHMSA published a Federal Register notice (86 FR 6737) announcing the\nSpecial Permit Request. The Special Permit Request letter, Final Environmental Assessment\n(FEA) and Finding of No Significant Impact (FONSI), Special Permit Analysis and Findings\n(SPAF), and all other pertinent documents for this special permit are available in Docket No.\nPHMSA-2020-0007 in the Federal Docket Management System located at\nwww.regulations.gov.\n2\nSubject to the stated terms and conditions, PHMSA grants this special permit (enclosed) based\non the information provided by SNG and the findings set forth in the SPAF, FEA, and FONSI.\nThis special permit provides relief from certain provisions of the Federal pipeline safety\n1 Southern Natural Gas Company, LLC is owned by Kinder Morgan, Inc.\n2 https://www.regulations.gov/docket?D=PHMSA-2020-0007.\n\n<<<PAGE 2>>>\n\nregulations for the Pipelines and requires SNG to comply with conditions and limitations\ndesigned to maintain pipeline safety as defined in the special permit. Note that in accordance\nwith 49 CFR § 190.341(j), PHMSA reserves the right to revoke, suspend, or modify this special\npermit if circumstances occur in which its continuance would be inconsistent with safety. If\nSNG elects not to implement the special permit conditions, SNG must notify PHMSA within 60\ndays and comply with 49 CFR § 192.611 within 18 months of the date of this letter.\nMy staff would be pleased to discuss this special permit or any other regulatory matter with you.\nSentho White, Director of PHMSA Engineering and Research Division, may be contacted at\n(202) 366-2415, on technical matters; and James Urisko, Director, Office of Pipeline Safety,\nSouthern Region, may be contacted at (404) 832-1150, for operational matters specific to this\nspecial permit.\nSincerely,\nLINDA GAIL\nDAUGHERTY\nDigitally signed by LINDA\nGAIL DAUGHERTY\nDate: 2022.07.27 15:42:54\n-04'00'\n(on behalf of)\nAlan K. Mayberry\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit – PHMSA-2020-0007\nSpecial Permit: PHMSA-2020-0007 – Southern Natural Gas Company, LLC Letter of Decision – Class 1 to 3 – Georgia and Mississippi\nPage 2 of 2\n\n<<<PAGE 1>>>\n\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nDecember 19, 2025\nZach Ragain\nDirector – Engineering: Codes and Standards\nKinder Morgan\n1001 Louisiana St, Suite 1000\nHouston, TX 77002\nRe: Docket No. 2020-0007 – Southern Natural Gas Company, LLC –\nHarris County, Georgia\nDear Mr. Ragain:\nOn September 26, 2024, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Southern\nNatural Gas Company, LLC1 (SNG) applied to the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) seeking an extension to a special permit segment to be incorporated in\nthe special permit PHMSA-2020-0007, effective through July 27, 2032. The special permit\nwaives compliance with 49 CFR §§ 192.611(a) and (d) and 192.619 for Class 3 pipeline\nsegments and allows SNG to continue operation of the original Class 1 design pipe in Class 3\nlocations subject to the conditions set forth in the special permit.\nSNG has requested one special permit segment extension, 0.19 miles of 36-inch-diameter natural\ngas transmission pipeline located in Harris County, Georgia. The amended special permit would\nconsist of two special permit segments of 0.70 miles in total of 24-inch and 36-inch-diameter\nnatural gas transmission pipeline located in Effingham and Harris Counties, Georgia.\nOn October 31, 2025, PHMSA published a Federal Register notice (90 FR 209) announcing the\nspecial permit request and seeking public comment. The special permit amendment request letter\nand other pertinent documents are available for review under Docket No. PHMSA-2020-0007 in\nthe Federal Docket Management System (FDMS) located at www.regulations.gov.\n2\nSummary of Public Comments: PHMSA received two public comments submitted by\nanonymous commenters during the 30-day comment period. Both commenters opposed the\nmodification request; one commenter cited concerns of pipeline incidents related to deregulation,\n1 Southern Natural Gas Company, LLC is a subsidiary of Kinder Morgan Inc.\n2 https://www.regulations.gov/docket?D=PHMSA-2020-0007\nModification of Class Location Special Permit PHMSA-2020-0007\nLetter of Decision and Special Permit Findings and Analysis – Georgia Page 1\n\n<<<PAGE 2>>>\n\nand the other communicated concerns of increased risk associated with grant of waivers from the\nFederal pipeline safety regulations in areas of population growth.\nPHMSA Response: PHMSA has authority to grant amendments to waivers from compliance\nwith class location change requirements to applicants who demonstrate that their request is not\ninconsistent with pipeline safety. PHMSA has conducted a review of this request and decided\nthat the incorporation of the extended special permit segments would not require a material\nchange in conditions. Based on the information provided by SNG, PHMSA decided that\namendment of the special permit would not be inconsistent with pipeline safety. Details of the\nincorporated segments and access to maps were published previously and can be viewed in the\nFDMS.\nOn September 25, 2025, PHMSA reviewed the special permit request for compliance with the\nNational Environmental Policy Act (NEPA). PHMSA determined that the following Categorical\nExclusion (CE) is applicable to the special permit segment extension: Granting, renewing, or\ndenying a special permit related to waiving class location or odorization requirements, following\nthe procedures set forth in 49 CFR § 190.341, including the identification of any enforceable\nconditions, imposed pursuant to 49 CFR § 190.341(d)(2), that are required to prevent and\naddress pipeline safety and environmental risk. PHMSA has further determined that no\nextraordinary circumstances apply. In order to ensure continued human and environmental\nsafety, the operator must fulfill the mitigation conditions of the special permit; continue to\nemploy good operating practices; and continue to follow any additional applicable permitting\nrequirements, State laws, or other pre-existing Federal requirements related to environmental\nprotection. Should conditions change, or should extraordinary circumstances materialize, the\noperator must contact PHMSA for reevaluation. The proposed action is hereby categorically\nexcluded from further NEPA review, and the finalized CE will be published online.3\nAccordingly, pursuant to 49 CFR § 190.341, by this Order—and as outlined in the existing\nspecial permit—PHMSA grants the amendment of special permit PHMSA-2020-0007, effective\nthrough July 27, 2032, to SNG. This special permit amendment Order continues to waive\ncompliance with certain Federal regulations in 49 CFR §§ 192.611(a) and (d) and 192.619(a).\nMy staff would be pleased to discuss this special permit or any other regulatory matter with you.\nMax Kieba, Director of Engineering and Research Division, may be contacted at (202) 420-9169\nfor technical matters; and James Urisko, Director, Office of Pipeline Safety, Southern Region,\nmay be contacted at (404) 832-1150 for operational matters specific to this special permit.\nSincerely,\nLinda Daugherty\nActing Associate Administrator for Pipeline Safety\n3 https://www.phmsa.dot.gov/planning-and-analytics/environmental-analysis-and-compliance/implementing-procedures\nModification of Class Location Special Permit PHMSA-2020-0007\nLetter of Decision and Special Permit Findings and Analysis – Georgia Page 2","truncated":false,"body_characters":31440}