{"operation":"document","citation":"PHMSA-2020-0040","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":"2020-07-24","effective_on":"2020-07-24","summary":"PHMSA-2020-0040, issued 2020-07-24 for Gulf South Pipeline Company, LP's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2020-0040.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2020-0040.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2020-0040","source_url":"https://www.regulations.gov/docket/PHMSA-2020-0040","body":"PHMSA pipeline special permit PHMSA-2020-0040. Operator: Gulf South Pipeline Company, LP. System: Gas Transmission. Issue date: 2020-07-24.\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 24, 2020\nMr. Tony Rizk\nVice President, Technical Services\nGulf South Pipeline Company, LP\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nDocket No. PHMSA-2020-0040\nDear Mr. Rizk:\nOn March 17, 2020, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Gulf South\nPipeline Company, LP (GSPC) applied to the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) for a special permit to waive § 192.14(a). Section 192.14(a) requires a\nhydrostatic pressure test when converting an existing pipeline not subject to 49 CFR Part 192 to\ngas service. The special permit request is for approximately 57.7 miles of the 16-inch diameter\nIndex 818-9 Pipeline (Pipeline). GSPC requested to waive the required hydrostatic pressure test\non the Pipeline for conversion to gas service, and instead implement alternative integrity\nmanagement safety measures on the Pipeline.\nGSPC will convert the Pipeline from carbon dioxide service to natural gas transmission service.\nThe Pipeline, located in Jasper, Clarke, Lauderdale, and Kemper Counties, Mississippi, was\npressure tested in 2013 to 49 CFR Part 195 requirements.\nOn June 2, 2020, PHMSA published a Federal Register notice (85 FR 33790), 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-2020-0040 in the Federal Docket Management System located at www.regulations.gov.\nPHMSA grants this special permit (enclosed) based on the information provided by GSPC\nand the findings set forth in the SPAF, FEA and FONSI. This special permit provides relief\nfrom the Federal Pipeline Safety Regulations for the Pipeline and requires GSPC to comply\nwith certain conditions and limitations designed to maintain pipeline safety as defined in thespecial permit.\n\n<<<PAGE 2>>>\n\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\n202-366-2415, on technical matters; and Allan Beshore, Director, Office of Pipeline Safety,\nCentral Region, may be contacted at 816-329-3811, for operational matters specific to this\nspecial permit.\nSincerely,\nALAN\nDigitally signed by\nALAN KRAMER\nKRAMER\nMAYBERRY\nDate: 2020.07.24\nMAYBERRY\n16:04:22 -04'00'\nAlan K. Mayberry\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit – PHMSA-2020-0040\nPHMSA-2020-0040 – Gulf South Pipeline Company\nLetter of Decision - Conversion to Gas Service – Index 818-9 Pipeline\nPage 2 of 2\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSPECIAL PERMIT – Conversion to Gas Service\nSpecial Permit Information:\nDocket Number: PHMSA-2020-0040\nRequested By: Gulf South Pipeline Company, LP\nOperator ID#: 31728\nDate Requested: March 17, 2020\nOriginal Issuance Date: July 24, 2020\nEffective Date: July 24, 2020\nCode Section(s): 49 CFR 192.14(a)\nGrant of Special Permit:\nBy this order, subject to the terms and conditions set forth below, the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),1 grants this special\npermit to Gulf South Pipeline Company, LP (GSPC)2. This special permit waives compliance\nwith the 49 Code of Federal Regulations (CFR) 192.14(a) for the conversion to natural gas\ntransmission service and grants that GSPC conduct alternative safety measures in-lieu of\nhydrostatically pressure testing the Index 818-9 Pipeline. This special permit requires GSPC to\nimplement additional conditions for the operations, maintenance, and integrity management (IM)\nof the Index 818-9 Pipeline.\nI. Purpose and Need:\nThe Index 818-9 Pipeline is an existing 61.1-mile, 16-inch diameter pipeline that GSPC will\nconvert from carbon dioxide service (49 CFR Part 195) to natural gas service (49 CFR Part 192)\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 GSPC is a wholly-owned, subsidiary of Boardwalk Pipeline Partners, LP.\nPHMSA-2020-0040 – Gulf South Pipeline Company, LP\nSpecial Permit – Conversion to Gas Service – 16-inch Index 818-9 Pipeline\nPage 1 of 12\n\n<<<PAGE 2>>>\n\nfor approximately 57.7 miles, with a 3.4-mile portion of the pipeline to be idled and physically\nseparated from the special permit segment as defined below. The Index 818-9 Pipeline will\ntransport natural gas from a point near Heidelberg, Mississippi to the Kemper County power\nplant, northwest of Daleville, Mississippi. The Index 818-9 Pipeline was installed in 2013.\nThe Index 818-9 Pipeline was hydrostatically tested to a minimum pressure of 3,726 pounds per\nsquare inch gauge (psig) for eight (8) hours in 2013. The test pressure was performed at a\nminimum of 90 percent (%) of the pipeline specified minimum yield strength (SMYS). There\nwere no hydrostatic test failures.\nThe Federal pipeline safety regulations in 49 CFR 192.14(a) require a pipeline to be pressure\ntested when converting to natural gas service. This special permit waives the hydrostatic\npressure test requirement for the special permit segment being converted from carbon dioxide\nservice to natural gas transmission service and requires GSPC to implement the conditions in this\nspecial permit.\nII. Special Permit Segments:\nJasper, Clarke, Lauderdale, and Kemper Counties, Mississippi\nThis special permit applies to the special permit segment defined using the GSPC survey station\n(SS) references as follows:\n• Special permit segment – Index 818-9 Pipeline - approximately 57.7 miles, SS 0+00 to\nSS 3044+12.\nThe special permit segment is in Jasper, Clarke, Lauderdale, and Kemper Counties,\nMississippi and will operate at a maximum allowable operating pressure (MAOP) of\n1,480 psig, which is a maximum stress of 37% of the SMYS.\n• The entire special permit segment must be treated as a high consequence area (HCA).\nPHMSA grants this special permit for the special permit segment based on the findings set forth\nin the “Final Environmental Assessment and Finding of No Significant Impact” and the “Special\nPermit Analysis and Findings” documents, which can be read in their entirety in Docket No.\nPHMSA-2020-0040 in the Federal Docket Management System located on the internet at\nwww.regulations.gov.\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 2 of 12\n\n<<<PAGE 3>>>\n\nIII. Conditions:\nPHMSA grants this special permit subject to GSPC implementing the following conditions on\nthe special permit segment as detailed below:\n1. General Conditions and Maximum Allowable Operating Pressure:\na) The special permit conditions must be included into GSPC Operations and\nMaintenance (O&M) Procedures in accordance with 49 CFR 192.603 and 192.605.\nb) GSPC must operate the special permit segment at or below an MAOP of 1,480\npsig.\nc) The special permit segment must be capable of inline inspection (ILI) in accordance\nwith 49 CFR 192.150.\n2. Integrity Management Program: GSPC must incorporate the requirements of this special\npermit into its written IM program and standard operating procedures (SOPs).3\na) GSPC must conduct a baseline assessment of the special permit segment using high\nresolution magnetic flux leakage (HR-MFL) and high resolution (HR) Deformation\nILI tools within twelve (12) months after the grant of this special permit.\nb) GSPC must conduct integrity re-assessments in accordance with the 49 CFR\n192.939(a) assessment intervals using in-line inspection tools along the special\npermit segment and in compliance with 49 CFR Part 192, Subpart O – IM\nregulations.\nc) GSPC must treat the special permit segment as a “covered segment” in a “HCA” in\naccordance with 49 CFR Part 192, Subpart O. Reassessments of the special permit\nsegment using HR-MFL and HR Deformation ILI must be conducted at the\nfrequency specified for HCAs in 49 CFR 192, Subpart O.\nd) If GSPC identifies threats within the special permit segment that require running\nadditional ILI tools, pursuant to 49 CFR Part 192, Subpart O, such as for crack\n3 Pipeline operating procedures such as GSPC SOPs are required by 49 CFR 192.603(b) and 192.605.\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 3 of 12\n\n<<<PAGE 4>>>\n\ndetection4 or pipe movement from soil or geologic stresses, GSPC must use the\nappropriate ILI tools or other evaluation methods for pipeline assessments.\n3. Anomaly Response and Repair:\na) General: GSPC must account for ILI tool tolerance and corrosion growth rates\nwithin the scheduled response times and repairs, and must document and justify the\nvalues used.\ni) GSPC must demonstrate ILI tool tolerance accuracy for each ILI tool run\nby usage of calibration excavations5, 6 and unity plots that demonstrate ILI\ntool accuracy to meet the tool accuracy specification provided by the\nvendor ( typical for depth within +/- 10% accuracy for 80% of the time).\nGSPC must incorporate ILI tool accuracy by ensuring that each ILI tool\nservice provider determines the tolerance of each tool and includes that\ntolerance in determining the size of each anomaly feature reported to\nGSPC. GSPC must compare previous indications to current indications\nthat are significantly different. If a trend is identified where the tool has\n4 “Pipe Crack” activity shall be defined as over both 20% wall thickness depth.\n5 ILI tool calibration excavations may include previously excavated anomalies or recent anomaly excavations with\nknown dimensions that were field measured for length, depth, and width, externally re-coated, CP maintained, and\ndocumented for ILI calibrations prior to the ILI tool run. ILI tool calibrations must use ILI tool run results and\nanomaly calibrations from either the special permit segment or from the complete ILI tool run segment, if the\ncontinuous ILI segment is longer than the special permit segment. A minimum of four (4) calibration excavations\nmust be used for unity plots or as an alternative a minimum of one (1) calibration excavation and compliance with\nAPI 1163-2013, In-Line Inspection Systems Qualification Standard (API 1163), Level 1 criteria must be used. For\nAPI 1163, Level 1 criteria to be used, all anomalies greater than 20-percent wall loss must be excavated and\nremediated unless Director, PHMSA Central Region gives GSPC a “No Objection” to an alternative ILI tool\ncalibration procedure (see Footnote 6).\n6 Other known and documented pipeline features that are appropriate for the type ILI tool used may be used as\ncalibration excavations for ILI tool calibration with technical documentation of their validity. To use other known\nand documented pipeline features as calibration excavations for ILI tool calibration GSPC must submit a plan for\nusing known and documented pipeline features as calibration excavations to, and receive a “No Objection” from\nthe Director, PHMSA Central Region, prior to performing the ILI tool calibration using pipeline\nfeatures. PHMSA must reply to GSPC within 90-days of GSPC’s request. The plan must include at least the\nfollowing information: (1) reason that known and documented pipeline features must be used in place of\nanomalies on the pipelines; the pipeline features that will be used for the ILI tool calibration, and the technical\njustification for using the pipeline features for ILI tool calibration; and (2) submit a report to the Director,\nPHMSA Central Region and to the Director, PHMSA Engineering and Research with the results of the use of\npipeline features for the ILI tool calibration that includes technical documentation establishing the validity of\nusing the pipeline features for the ILI tool calibration. GSPC must submit the report to PHMSA within 90-days\nafter completion of the ILI tool calibration.\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 4 of 12\n\n<<<PAGE 5>>>\n\nbeen consistently over-calling or under-calling, the remaining ILI features\nmust be re-graded accordingly.\nii) The unity plots must show actual anomaly depth versus predicted depth.\niii) ILI tool evaluations for metal loss must use “6t x 6t”7 interaction criteria\nfor determining anomaly failure pressures and response timing.\niv) Discovery date8 must be within 150 days of any ILI tool run for each type\nof ILI tool (e.g. HR-geometry, HR-deformation or HR-MFL tools).\nb) Dents: GSPC must repair dents in the special permit segment in accordance with\nthe 49 CFR 192.933 repair criteria. The special permit segment must have a HR\ndeformation ILI as part of the initial ILI. The timing for these dent repairs should\nfollow the GSPC O&M Manual but must be no longer than one (1) year after\ndiscovery or the timing intervals in 49 CFR 192.933(d), whichever is shorter.\nc) Repair Criteria and Response Time for ILI Results: The following provisions\nprovide the required timing for excavation and investigation of anomalies based on\nILI results. GSPC must evaluate ILI data by using either the ASME Standard B31G,\n“Manual for Determining the Remaining Strength of Corroded Pipelines”,9 the\nmodified B31G (0.85dL) or R-STRENG10 for calculating the predicted failure\npressure ratio (FPR) to determine corrosion anomaly responses.\nThe special permit segment baseline assessment and first reassessment anomaly\nfindings must be remediated in accordance with the below criteria, or the timing\nintervals in 49 CFR 192.933(d) for other threats, whichever timing interval is shorter\nor more stringent. Thereafter, subsequent reassessments after the first reassessment\nmust be remediated in accordance with 49 CFR Part 192 criteria for either HCAs or\nmoderate consequence areas, as applicable.\ni) Immediate response: Any anomaly within the special permit segment that\nmeets either: (l) a failure pressure ratio (FPR) equal to or less than 1.25; or\n7 “6t” means pipe wall thickness times six.\n8 Discovery date is the day, month and year that an Operator receives the ILI tool run results from the ILI tool\nservice provider.\n9 The applicable edition incorporated by reference is listed in 49 CFR 192.7.\n10 The applicable edition incorporated by reference is listed in 49 CFR 192.7.\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 5 of 12\n\n<<<PAGE 6>>>\n\n(2) an anomaly depth equal to or greater than 70% wall thickness loss.\nii) One-year response: Repair any anomaly in the special permit segment\nthat meets either: (l) a FPR less than or equal to 1.39 in a Class 1 location;\n(2) FPR less than or equal to 1.67 in a Class 2 location; (3) a FPR less than\nor equal to 2.00 in a Class 3 or 4 location; or (4) an anomaly depth greater\nthan 40% of pipe wall thickness.\niii) Monitored response: Any anomaly within the special permit segment\nthat meets both: (1) a FPR greater than 1.39 in a Class 1 location; a FPR\ngreater than 1.67 in a Class 2 location; a FPR greater than 2.00 in a Class 3\nor 4 location; and (2) an anomaly depth less than or equal to 40% wall\nthickness loss. The schedule for the response must take tool tolerance11\nand corrosion growth rates into account.\niv) Special permit segment – Crack Type Anomalies - All cracking\nexceeding 30% of the pipe wall thickness, having a FPR below 1.39, or\nhaving defects that meet the 49 CFR Part 192 requirements must be\nremediated within 180 days of discovery.12, 13\n4. Close Interval Surveys: GSPC must perform a close-interval survey (CIS)14 and\nremediate15 any areas of inadequate cathodic protection in the special permit segment\nwithin one (1) year after the grant of this special permit. If environmental permitting or\nright-of-way factors beyond GSPC’s control should prevent the completion of the CIS\n11 Tool tolerance shall be applied only to FPR calculations, and not to the anomaly depth criteria.\n12 Should any cracking anomalies above 30% of the pipe wall thickness be found in the special permit segment,\nGSPC must remediate the cracks or have a crack anomaly evaluation procedure submitted to the Director,\nPHMSA Central Region with a “No Objection” reply prior to using the crack evaluation procedure for cracking\nanomalies left in the pipeline above 30% of the pipe wall thickness without remediation. If GSPC does not\nreceive a “No Objection” letter or a request for additional review time from PHMSA within 90 days of the\nnotification, GSPC may proceed.\n13 A fracture mechanics and pressure cycling evaluation is required where an un-remediated crack of 20% or more\n(of wall thickness) is detected by ILI or direct inspection tools. The pipe must have toughness tests (Charpy V-\nnotch impact values) of the pipe body, seam, or girth weld so that fracture mechanics modeling can be used, if\nneeded.\n14 CIS must be conducted at a maximum 5-foot spacing and with interrupted on/off current.\n15 The terms “remediate” or “remediation” of pipe coating must include repair of damaged external pipe coating,\nwhere required to maintain cathodic protection of the pipeline in accordance with 49 CFR 192.463.\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 6 of 12\n\n<<<PAGE 7>>>\n\nwithin one (1) year from the grant of this special permit, (1) GSPC must complete a CIS and\nperform subsequent remediation including coating repair as soon as practicable, (2) GSPC\nmust submit a letter justifying the delay and provide the anticipated date of completion to\nthe Director, PHMSA Central Region, no later than one (1) month prior to the end of one\n(1) year after the grant of this special permit, and (3) must receive a letter of “No\nObjection” from the Director, PHMSA Central Region, for a delay.16 CIS remediation\nactivities must be completed within one (1) year of the finding. GSPC must submit a\nwritten request to the Director, PHMSA Central Region, for any extended evaluation and\nremediation schedules. GSPC must receive a letter of “No Objection” from PHMSA prior\nto implementing an extended CIS and remediation interval.\n5. Close Interval Surveys – Reassessment Interval:\na) GSPC must perform periodic CIS of the special permit segment at the applicable\nreassessment interval(s) for a “covered segment” determined in concert and\nintegrated with ILI in accordance with 49 CFR 192.937 (a) and (b) and 192.939.\nGSPC must not exceed the 7-calendar year reassessment interval in 49 CFR\n192.939(a). CIS assessments within the reassessment interval are not required to be\nperformed in the same year as ILI reassessments.\nb) CIS data must be integrated with ILI data. Condition 10 (Data Integration) –\ngives a complete description of data integration information that GSPC must\nmaintain for the special permit segment, including CIS and ILI data.\n6. Right-of-Way Patrols and Leakage Surveys: In addition to the requirements of 49 CFR\n192.705, GSPC must perform right-of-way patrols as follows:\na) Aerial flyover patrols or ground patrols by walking or driving of the special permit\nsegment right-of-way once each month, not to exceed 45 days, contingent on\nweather conditions. Should mechanical availability of the patrol aircraft or weather\nconditions become an extended issue, the special permit segment pipeline aerial\nflyover patrol must be completed within 60 days of the last patrol by other methods\nsuch as walking or driving the pipeline route, as feasible.\n16 PHMSA has assigned this special permit to the Director, PHMSA Central Region, but upon notice to GSPC could\nassign this special permit to a different PHMSA Region.\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 7 of 12\n\n<<<PAGE 8>>>\n\nb) If the schedule for either ground patrols or aerial flyover patrols cannot be met due\nto circumstances beyond GSPC’s control, GSPC must notify the Director, PHMSA\nCentral Region, in writing of the reasons the schedule cannot be met and obtain a\nletter of “No Objection” within three (3) business days of the exceedance.\nc) GSPC must conduct a leakage survey, referenced in 49 CFR 192.706, within 45 days\nof placing the special permit segment into gas service and thereafter in accordance\nwith 49 CFR 192.706 leakage survey intervals.\n7. Line-of-Sight Markers: GSPC must install and maintain line-of-sight markers within the\nspecial permit segment in accordance with 49 CFR 192.620(d)(4)(iv) to the extent\npracticable. Any removed or missing line-of-sight markers must be replaced within 60\ndays of discovering the marker has been removed or missing.\n8. Mainline Valve – Monitoring and Remote Control for Leaks or Ruptures: Mainline\nvalves at Mile Post 0, 17.7, 23.2, 44.9, and 56.7 in the special permit segment must be\ncontrolled by a supervisory control and data acquisition (SCADA) system and must be\nequipped for remote monitoring and control, or remote monitoring and automatic control.\nGSPC must also implement the following requirements:\na) Crossovers or Lateral Pipe Isolation: If any crossover or lateral pipe for gas\nreceipts or deliveries connects to the isolated segment between the upstream and\ndownstream mainline valves, the nearest valve on the crossover connection(s) or\nlateral(s) must be isolated, such that, when all valves are closed, there is no flow\npath for gas to flow to the leak or rupture site (except for residual gas already in the\nshut-off segment);\nb) Remote Control Valve Monitoring for Valve Status and Operating Pressure:\nMainline valves must be continuously monitored for valve status (open, closed, or\npartial closed/open), upstream pressure, and downstream pressure;\nc) Point-to-Point Verification: GSPC must conduct a point-to-point verification\nbetween SCADA displays and the mainline valve, sensors, and communications\nequipment in accordance with 49 CFR 192.631(c) and (e), or an equivalent\nverification; and\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 8 of 12\n\n<<<PAGE 9>>>\n\nd) Maintenance of Valves: All valves used to isolate a leak or rupture must be\nmaintained in accordance with this special permit and 49 CFR 192.745.\n9. Interference Currents Control: Within one (1) year of the grant of this permit, GSPC must\nperform surveys and remediation, with corrosion control implemented, for induced currents\nfrom electric transmission lines and other known sources of potential interference that may\naffect the special permit segment. An induced alternating current (AC) or direct current\n(DC) program and remediation plan to protect the pipeline from corrosion caused by stray\ncurrents must be written and implemented within one (1) year of the grant date of this\nspecial permit.\n10. Data Integration: GSPC must maintain data integration of special permit condition\nfindings and remediation in the special permit segment. Data integration must include the\nfollowing information: (1) Pipe diameter, wall thickness, grade, and seam type; (2) pipe\ncoating; (3) MAOP; (4) class location (including boundaries on aerial photography); (5)\nHCAs (including boundaries on aerial photography); (6) hydrostatic test pressure including\nany known test failures; (7) casings; (8) any in-service ruptures or leaks; (9) ILI survey\nresults including HR-MFL, HR-Deformation tools; (10) CISs – most recent; (11) rectifier\nreadings; (12) cathodic protection test point survey readings; (12) AC/DC interference\nsurveys; (14) pipe coating surveys; (15) pipe coating and anomaly evaluations from pipe\nexcavations; (16) stress corrosion cracking (SCC) excavations and findings; and (17) pipe\nexposures from encroachments.17 Structures must be validated every three (3) years by\nobtaining new aerial imagery or by ground patrol.\na) Data integration documentation and drawings, with four (4) years of prior data, must\nbe maintained and must be submitted, if requested by PHMSA, beginning with the 2nd\nannual report of this special permit.\nb) Data integration must be updated on an annual basis. GSPC must conduct, at least, an\nannual review of integrity issues to be remediated.\nc) GSPC must maintain data integration as a composite of all applicable data elements\n17 Hydrostatic test failures, in-service ruptures, rectifier readings, cathodic protection test point survey readings,\nAC/DC interference surveys, pipe coating surveys, pipe coating and anomaly evaluations from pipe excavations,\nSCC excavations and findings, and pipe exposures from encroachments must be maintained for data integration\ninto “IntegraLink” or a comparable data viewer. These data elements may not be on a drawing.\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 9 of 12\n\n<<<PAGE 10>>>\n\nin a data viewer.\n11. Environmental Assessments and Permits: GSPC must evaluate the potential\nenvironmental consequences and affected resources of any land disturbances and water\nbody crossings needed to implement the special permit conditions for the special permit\nsegment prior to the disturbance. GSPC must obtain all applicable (Federal, state, and\nlocal) environmental permits and adhere to all applicable (Federal, state, and local)\nenvironmental permit requirements when conducting the special permit conditions activity.\n12. Documentation: GSPC must maintain documentation for Conditions 1 through 11 and\n13 for the special permit segment for the life of this special permit.\n13. Certification: A GSPC senior executive officer, vice president or higher, must certify in\nwriting the following:\na) The special permit segment meets the conditions described in this special permit;\nb) The written manual of O&M procedures required by 49 CFR 192.603 and 192.605\nfor the special permit segment has been updated to include all additional operating\nand maintenance requirements of this special permit; and\nc) GSPC has implemented all conditions as required by this special permit.\nWithin 12 months after the grant of this special permit, GSPC must send the certifications\nrequired in Condition 13(a) through (c) with special permit condition status and procedure\ncompletion date, compliance documentation summary, and the required senior executive\nsignature and date of the signature to the PHMSA Associate Administrator for Pipeline\nSafety, with copies to Director, PHMSA Central Region; and to the Federal Register Docket\n(PHMSA-2020-0040) at www.regulations.gov.\nIV. Limitations:\nThis special permit is subject to the limitations set forth in 49 CFR 190.341 as well as the\nfollowing limitations:\n1) PHMSA has the sole authority to make all determinations on whether GSPC has\ncomplied with the specified conditions of this special permit. Failure to comply with any\ncondition of this special permit may result in revocation of the permit.\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 10 of 12\n\n<<<PAGE 11>>>\n\n2) Any work plans and associated schedules for the special permit segment are\nautomatically incorporated into this special permit and are enforceable in the same\nmanner.\n3) Failure by GSPC to submit the certifications required by Condition 13 (Certification)\nwithin the time frames specified may result in revocation of this special permit.\n4) As provided in 49 CFR 190.341, PHMSA may issue an enforcement action for\nfailure to comply with this special permit. The terms and conditions of any\ncorrective action order, compliance order or other order applicable to a pipeline\nfacility covered by this special permit will take precedence over the terms of this\nspecial permit.\n5) If GSPC sells, merges, transfers, or otherwise disposes of all or part of the assets known\nas the GSPC special permit segment, GSPC must provide PHMSA with written notice of\nthe change within 30 days of the consummation date. In the event of such transfer,\nPHMSA reserves the right to revoke, suspend, or modify the special permit if the transfer\nconstitutes a material change in conditions or circumstances underlying the permit.\nAUTHORITY: 49 U.S.C. 60118(c)(1) and 49 CFR 1.97.\nIssued in Washington, DC on July 24, 2020.\nALAN\nKRAMER\nMAYBERRY\nAlan K. Mayberry,\nDigitally signed by\nALAN KRAMER\nMAYBERRY\nDate: 2020.07.24\n16:01:32 -04'00'\nAssociate Administrator for Pipeline Safety\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 11 of 12\n\n<<<PAGE 12>>>\n\nAttachment A – 16-inch Index 818-9 Route Map with Class Locations\nPHMSA-2020-0040 - Gulf South Pipeline Company, LP\nSpecial Permit – Alternative Measures for Pressure Test – Index 818-9 Pipeline\nPage 12 of 12\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSpecial Permit Analysis and Findings – Conversion to Gas Service\nSpecial Permit Information:\nDocket Number: PHMSA-2020-0040\nRequested By: Gulf South Pipeline Company, LP\nOperator ID#: 31728\nOriginal Date Requested: March 17, 2020\nOriginal Issuance Date: July 24, 2020\nEffective Date: July 24, 2020\nCode Section(s): 49 CFR 192.14(a)\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA)1 provides this\ninformation to describe the facts of the subject special permit application submitted by Gulf\nSouth Pipeline Company, LP2 (GSPC), to discuss any relevant public comments received with\nrespect to the application, to present the engineering and safety analysis of the special permit\napplication, and to make findings regarding whether the requested special permit should be\ngranted and if so under what conditions. GSPC requested that PHMSA waive compliance from\nthe pressure test required in the 49 Code of Federal Regulations (CFR) 192.14(a) for\napproximately 57.7-miles of the 16-inch diameter Index 818-9 Pipeline that is being converted\nfrom carbon dioxide service pipeline (49 CFR Part 195) to a natural gas pipeline (49 CFR Part\n192).\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 GSPC is a wholly-owned, operating subsidiary of Boardwalk Pipeline Partners, LP.\nPHMSA-2020-0040 - Gulf South Pipeline Company Special Permit Analysis and Findings – Index 818-9 Pipeline\nPage 1 of 16\n\n<<<PAGE 2>>>\n\nPipeline System Affected:\nThis special permit applies to the GSPC request for a waiver of the hydrostatic pressure test\nrequirements in 49 CFR 192.14(a) for approximately 57.7 miles of 16-inch diameter Index 818-9\nPipeline (Index 818-9 Pipeline) located in Jasper, Clarke, Lauderdale, and Kemper Counties,\nMississippi. This special permit allows GSPC to operate the Index 818-9 Pipeline special\npermit segment, defined below, without re-hydrostatically pressure testing the Index 818-9\nPipeline. Without the special permit, 49 CFR 192.14(a) requires GSPC to retest the Index 818-9\nPipeline which was previously hydrostatically pressure tested to a minimum of 3,726 pounds per\nsquare inch gauge (psig) for eight (8) hours in 2013. The previous hydrostatic pressure test was\nat a minimum of 90 percent (%) of the pipeline specified minimum yield strength (SMYS).\nThere were no hydrostatic test failures.\nThe Index 818-9 Pipeline will have a maximum allowable operating pressure (MAOP) of 1,480\npsig and will operate at a maximum stress of 37 % of the pipeline SMYS. The Index 818-9\nPipeline was installed in 2013.\nSpecial Permit Request:\nGSPC applied to PHMSA on March 17, 2020, for a special permit seeking relief from the\nFederal pipeline safety regulations in 49 CFR 192.14(a) for approximately 57.7 miles of the\nIndex 818-9 Pipeline, where a change has occurred from an original carbon dioxide service\npipeline (49 CFR 195) to natural gas transmission pipeline (49 CFR 192) located in Jasper,\nClarke, Lauderdale, and Kemper Counties, Mississippi.\nThe Index 818-9 Pipeline special permit segment is described below.\n• This special permit applies to the special permit segment defined as follows using the\nGSPC Index 818-9 Pipeline survey station (SS) references:\no Special permit segment – Index 818-9 Pipeline — approximately 57.7 miles, SS\n0+00 to SS 3044+12 and is in Jasper, Clarke, Lauderdale, and Kemper Counties,\nMississippi.\nAttachment A is a route map of the Index 818-9 Pipeline special permit segment.\nPHMSA-2020-0040 - Gulf South Pipeline Company Special Permit Analysis and Findings – Index 818-9 Pipeline\nPage 2 of 16\n\n<<<PAGE 3>>>\n\nPublic Notice:\nOn June 2, 2020, PHMSA posted a notice of this special permit request in the Federal Register\n(85 FR 33790). The Federal Register notice period ended on July 2, 2020. The Special Permit\nRequest letter, Final Environmental Assessment (FEA) and Finding of No Significant Impact\n(FONSI), Special Permit Analysis and Findings, and all other pertinent documents for this\nspecial permit are available in Docket No. PHMSA-2020-0040 in the Federal Docket\nManagement System (FDMS) located on the internet at www.regulations.gov. PHMSA did not\nreceive any comments in response to the notice.\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 segment. The\nspecial permit will require GPSC’s Operations and Maintenance (O&M) Manual and Procedures\nto provide a systematic program to review and remediate the pipeline for safety concerns.\nAdditional operational integrity reviews and remediation requirements will be required by this\nspecial permit for the special permit segment as outlined in the Operational Integrity\nCompliance section of this document.\nAnalysis:\nPHMSA is using the class location special permit criteria to evaluate and determine the type\nspecial permit conditions needed in-lieu of a new hydrostatic pressure test for the conversion of\nthe Index 818-9 Pipeline from a carbon dioxide service pipeline (49 CFR Part 195) to a natural\ngas transmission pipeline (49 CFR Part 192).\nBackground: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the\ncriteria it uses for the consideration of class location change waivers, now being granted through\na special permit. First, certain threshold requirements must be met for a pipeline section to be\nfurther evaluated for a class location change special permit. Second, the age and manufacturing\nprocess of the pipe; system design and construction; environmental, operating and maintenance\nhistories; and integrity management program elements are evaluated as significant criteria.\nThese significant criteria are presented in matrix form and can be reviewed in the FDMS, Docket\nNumber PHMSA-RSPA-2004-17401. Third, such special permits will only then be granted\nPHMSA-2020-0040 - Gulf South Pipeline Company Special Permit Analysis and Findings – Index 818-9 Pipeline\nPage 3 of 16\n\n<<<PAGE 4>>>\n\nwhen pipe conditions and active integrity management provide a level of safety greater than or\nequal to a pipe replacement or pressure reduction. For this special permit a 49 CFR 192.14(a)\nrequired hydrostatic pressure test is being replaced with special permit conditions that GSPC\nmust implement to identify and remediate integrity threats to the special permit segment.\nThreshold Requirements: Each of the threshold requirements published by PHMSA in the\nJune 29, 2004, Federal Register notice is discussed below in regards to the GSPC’s special\npermit application.\n1) No pipeline segments changing to Class 4 location will be considered.\n• The special permit segment is in predominately Class 1 locations with a few miles of\nClass 2 and 3 locations. GSPC has met this requirement.\n2) No bare pipe will be considered.\n• The special permit segment is coated with fusion bonded epoxy coating. GSPC has met\nthis requirement.\n3) No pipe containing wrinkle bends will be considered.\n• There are no wrinkle bends in the special permit segment. GSPC has met this\nrequirement.\n4) No pipe segments operating above 72% of SMYS will be considered for a Class 3 special\npermit.\n• The special permit segment operates at or below 72% SMYS. GSPC has met this\nrequirement.\n• The 57.7 miles of special permit segment pipe is 16-inch diameter, 0.457-inch wall\nthickness, pipe strength of 70,000 psig and the pipe seams are a high frequency electric\nresistance welded (HR-ERW). The special permit segment pipe will operate at less than\n37.012% SMYS at an MAOP of 1,480 psig.\n• Attachment B – Index 818-9 Pipeline – Design, Construction, and O&M Parameters\ngives an overview of the pipeline material, design, construction, and O&M parameters of\nthe special permit segment.\n5) Records must be produced that show a hydrostatic test to at least 1.25 x MAOP and 90% of\nSMYS.\nPHMSA-2020-0040 - Gulf South Pipeline Company Special Permit Analysis and Findings – Index 818-9 Pipeline\nPage 4 of 16\n\n<<<PAGE 5>>>\n\n• Records submitted by GSPC show that the special permit segment was hydrostatically\ntested in 2013 to a minimum of 3,726 psig for eight (8) hours. GSPC has met this\nrequirement.\n6) In-line inspection (ILI) must have been performed with no significant anomalies identified\nthat indicate systemic problems.\n• The special permit segment will be required by the special permit to be inspected\nwith a high resolution (HR) magnetic flux leakage and HR-Deformation ILI tools.\n7) Additional information: The special permit segment is composed of pipe manufactured in\n2012 and 2013 with HF-ERW seams at Corinth Pipeworks.\nThe special permit segment meets the threshold requirements; however, certain required ILI tool\nruns, anomaly remediation, and other integrity surveys are necessary to ensure safety, and\ntherefore, will be required in the special permit conditions.\nCriteria Matrix: The original and supplemental data submitted by GSPC for the special permit\nsegment have been compared to the class location change special permit criteria matrix,\ndescribed above. The data falls within the probable acceptance column of the criteria matrix for\na class location change in the areas of pipe manufacture, pipe material, design stress level, non-\ndestructive examination of all girth welds, fusion bonded epoxy pipe external coating,\nhydrostatic test pressure used for the 2013 test, no hydrostatic test failures, depth of cover meets\nboth 49 CFR 192 and 195 requirements, local geology, no operational leaks or failures, cathodic\nprotection, no safety related condition reports, integrity management program will be required,\nfuture ILI time frame, coating assessments, damage prevention program, and no PHMSA\nenforcement actions on the Index 818-9 Pipeline.\nPHMSA has determined that imposing the special permit conditions will address any concerns\nfrom not conducting a new pressure test prior to placing the special permit segment into a gas\ntransmission service and will provide an equivalent level of safety for the public and will protect\nthe environment.\nOperational Integrity Compliance:\nPHMSA reviewed this special permit request to ensure that integrity threats to the pipeline in the\nPHMSA-2020-0040 - Gulf South Pipeline Company Special Permit Analysis and Findings – Index 818-9 Pipeline\nPage 5 of 16\n\n<<<PAGE 6>>>\n\nspecial permit segment are in the Operator’s O&M Procedures to provide a systematic program\nto review and remediate the pipeline for safety concerns. 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