{"operation":"document","citation":"PHMSA-2021-0052","title":"Sabal Trail — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2023-09-19","effective_on":"2023-09-19","summary":"PHMSA-2021-0052, issued 2023-09-19 for Sabal Trail's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2021-0052.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2021-0052.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2021-0052","source_url":"https://www.regulations.gov/docket/PHMSA-2021-0052","body":"PHMSA pipeline special permit PHMSA-2021-0052. Operator: Sabal Trail. System: Gas Transmission. Issue date: 2023-09-19.\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSpecial Permit Analysis and Findings\nClass 1 to 3 Location\nSpecial Permit Information:\nDocket Number: PHMSA-2021-0052\nRequested By: Sabal Trail Transmission, LLC\nOperator ID#: 39167\nOriginal Date Requested: August 5, 2021\nOriginal Issuance Date: September 19, 2023\nCode Section(s): 49 CFR 192.611\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS),\n1 provides this information to describe the facts of the subject special permit\napplication submitted by Sabal Trail Transmission (STT),\n2 to discuss any relevant public\ncomments received with respect to the application, to present the engineering, and safety analysis\nof the special permit application, and to make findings regarding whether the requested special\npermit should be granted and, if so, under what conditions. STT requested that PHMSA waive\ncompliance from the 49 Code of Federal Regulations (CFR) 192.611 for a natural gas\ntransmission pipeline segment, where the class location has changed from a Class 1 to a Class 3\nlocation.\n1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of\nTransportation’s Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety.\n2 STT is a joint venture comprised of Spectra Energy Partners, LP (Enbridge), NextEra Energy, Inc., and Duke\nEnergy, and is operated by Enbridge Inc. STT operates under operator identification (OPID) number 39617\nissued by PHMSA\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 1 of 10\n\n<<<PAGE 2>>>\n\nPipeline System Affected:\nThis special permit application applies to the STT request for a waiver of the Class location\nchange requirements in 49 CFR 192.611 for 53,486 feet (approximately 10.13 miles) of the 36-\ninch diameter Line 1 Pipeline in Sumter County, Florida (special permit segment). This special\npermit, if granted, would allow STT to operate the Line 1 pipeline special permit segment at a\nreduced maximum allowable operating pressure (MAOP) from 1,456 pounds per square inch\ngauge (psig) to 1,355 psig.\nSpecial Permit Request:\nOn March 26, 2021, STT applied to PHMSA for a special permit seeking relief from 49 CFR\n192.611 for the below-listed special permit segment, where class location changes have occurred\nfrom the original Class 1 locations to Class 3 locations in Sumter County, Florida.\nSpecial Permit Segment:\nThis special permit applies to the special permit segment in Table 1 – Special Permit Segment\nand are identified using the STT survey station (SS) references.\nTable 1 – Special Permit Segment\nSpecial\nOutside\nCounty or\nPermit\nDiameter\nLine Name Segment\nLength\n(feet)\nStart Survey\nEnd Survey\nNo.\nYear\nParish,\nStation (SS)\nStation (SS)\nDwellings\nInstalled\n(inches)\nState\nNumber\n1 36 Line 1 53,486 22251+50\n(MP 421.43)\n22786+36\n(MP 431.56) Sumter, FL 680+ 2017 Note: HSAW is helical arc welded seam type.\nSAWL is longitudinal submerged arc welded seam type.\nSpecial Permit Inspection Area:\nThe special permit inspection area is defined as the area that extends 220 yards on each side of\nthe centerline as listed in Table 2 – Special Permit Inspection Area.\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 2 of 10\nSeam\nType\nHSAW,\nSAWL\n\n<<<PAGE 3>>>\n\nTable 2 – Special Permit Inspection Area\nSpecial\nSpecial\nOutside\nStart Survey\nEnd Survey\nPermit\nPermit\nLength3\nDiameter\nLine Name\nStation\nStation\nInspection\nSegment(s)\n(miles)\n(inches)\n(SS)\n(SS)\nArea Number\nIncluded\n1 1 36 Line 1 15797+96\n(MP 299.14)\n25468+07\n(MP 482.37) 183.23\nThe special permit inspection area is in Marion and Sumter Counties, Florida.4\nPublic Notice:\nOn August 26, 2021, PHMSA posted a notice of this special permit request in the Federal\nRegister (86 FR 47734) with a closing date of September 27, 2021. PHMSA received one (1)\ncomment from the Pipeline Safety Trust as a result of this notice.\nThe Pipeline Safety Trust (PST) noted that the location of the STT Line 1 was a rural class 1 area\nwhen the pipeline was constructed. However, substantial development was predictable since the\nportion of the pipeline for the special permit was located just south of the one of the fastest\ngrowing census districts over the past decade, primarily because of a very large 55+ housing\ndevelopment, The Villages. The PST stated that the operator may not have known when its\nFERC certificate was granted in February of 2016 that the area in the permit application would\nbe developed by the Villages within months, it certainly should have known that it was within\nthe city limits of Wildwood, planned for dense development and should have built the line to\nClass 3 standards from the start. The PST also believed that the request to grant a future\nextension of a permit without another application should be denied. Any future class location\nchanges in this area, while as foreseeable as these were, should require the operator to file a new\napplication, with another opportunity for public and agency review of the operator’s operational\nhistory.\nPHMSA acknowledges PST’s comments and has structured the special permit conditions\nrequiring STT to reduce the MAOP by 101 psig for the approximately 80-mile section of pipe\nthat includes the special permit segment. This restricts the operating pressure to no greater than\n3 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.\n4 The special permit inspection area includes the special permit segment.\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 3 of 10\n\n<<<PAGE 4>>>\n\n67% specified minimum yield strength (SMYS) in Class 3 locations. In addition, the special\npermit conditions require integrity management type assessments to maintain safety along the\nspecial permit segment. Finally, STT will have to apply for further class changes on the pipeline\nto facilitate public and PHMSA review. PHMSA has limited the special permit to the special\npermit segment initially requested and if an extension of the segment is necessary due to a class\nchange, STT must either replace the pipe with stronger pipe, lower the MAOP of the pipeline, or\napply for an additional special permit at that time.\nThe STT application letter, Federal Register notice, and all other pertinent documents are\navailable for review in Docket No. PHMSA-2021-0052 in the Federal Docket Management\nSystem (FDMS) located on the internet at www.Regulations.gov.\nAnalysis:\nBackground: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the\ncriteria it uses for the consideration of applications for class location change waivers, now being\ngranted or denied through a special permit. First, certain threshold requirements should be met\non a pipeline special permit segment for a class location change special permit to be granted.\nSecond, the age and manufacturing process of the pipe; system design, and construction;\nenvironmental, operating and maintenance histories; and integrity management program\nelements are evaluated as significant criteria. These significant criteria are presented in matrix\nform and can be reviewed in the FDMS, Docket No. PHMSA–RSPA-2004-17401. Third,\nspecial permits will only be granted when pipe conditions and active integrity management\nprovides a level of safety greater than or equal to a pipe replacement or pressure reduction. The\noperator’s Federal pipeline safety regulation compliance history is also evaluated as part of the\ncriteria matrix for acceptability prior to issuance of a special permit.\nThreshold Requirements: Each of the threshold requirements published by PHMSA in the June\n29, 2004, Federal Register notice is discussed below regarding the STT special permit request.\n1) No pipeline segments in a class location changing to Class 4 location will be considered.\n• This special permit request is for one (1) special permit segment on the STT Line 1\npipeline, where a change has occurred from a Class 1 location to a Class 3 location.\n• STT has met this requirement.\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 4 of 10\n\n<<<PAGE 5>>>\n\n2) No bare pipe will be considered.\n• The STT special permit segment is externally coated with fusion bonded epoxy.\n• STT has met the requirement.\n3) No pipe containing wrinkle bends will be considered.\n• There are no wrinkle bends in the special permit segment.\n• STT has met this requirement.\n4) No pipe segments operating above 72% of the SMYS will be considered for a Class 3\nlocation special permit.\n• The special permit segment operates at or below 72% SMYS.\n• The special permit segment pipe for Line 10 is 36-inch diameter, 0.520-inch wall\nthickness, and pipe yield strength of 70,000 psig. The pipe seam is a helical submerged\narc welded (HSAW) seam and was manufactured in 2016 by Berg Steel Pipe\nCorporation.\n5) Records must be produced that show a hydrostatic test to at least 1.25 x MAOP and 90% of\nSMYS.\n• STT records submitted show that the special permit segment being considered met this\nrequirement.\n• Special permit segment was pressure tested in 2017 at 2,183 psig.\n• STT has met this requirement.\n6) In-line inspection (ILI) must have been performed with no significant anomalies identified\nthat indicate systemic problems such as stress corrosion cracking (SCC).\n• No “immediate” defects or anomalies with corrosion greater than 30% of the wall\nthickness were found on the most recent ILI for the special permit inspection area.\n• STT has met this requirement.\n7) Criteria for consideration of a class location change waiver, being considered through the\nspecial permit, published by PHMSA in the Federal Register (69 FR 38948), define a waiver\ninspection area (special permit inspection area) as up to 25 miles of pipe on either side of\nthe waiver segment (special permit segment).\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 5 of 10\n\n<<<PAGE 6>>>\n\n• A special permit would be contingent upon STT’s incorporation of the special permit\ninspection area in its written integrity management program as covered segments in a\nhigh consequence area (HCA) in accordance with 49 CFR 192.903.\nCriteria Matrix: The data submitted by STT for the special permit segment has been compared\nto the class location change special permit criteria matrix.\n• The special permit segment falls in the probable acceptance column of the criteria matrix\nfor:\no Pipe manufacture, pipe material, design stress, pipe girth welds, pipe coating, test\npressure, test failures, depth of cover, local geology, leaks and failures, type service,\npressure fluctuations, cathodic protection, safety related condition reports, and ILI type.\n• The special permit segment falls in the possible acceptance column of the criteria matrix for:\no Class Location Change (1 to 3), HCA, and ILI program.\n• The special permit segment falls in the requires substantial justification column of the\ncriteria matrix for:\no Enbridge Inc., overall enforcement findings fall in the requires substantial justification\ncategory. STT’s 10-year enforcement findings do not fall within this category.\no This special permit requires STT to implement the special permit conditions that include\nsafety requirements on the operations, maintenance, and integrity management of the\nspecial permit segment (10.130 miles) and the special permit inspection area (183.23\nmiles). Therefore, the safety benefits are obtained well beyond the portion of the pipeline\nthat experienced a class location change.\no STT will be required to submit an annual report for this special permit on integrity threats\nto the pipeline in the special permit segment and the special 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 segment and special permit inspection area. This integrity\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 6 of 10\n\n<<<PAGE 7>>>\n\ninformation was used for any special permit conditions to provide a systematic program to\nreview and remediate the pipeline for safety concerns if a special permit was granted. Additional\noperational integrity review and remediation requirements would be required by a special permit\nto ensure that the operator has an ongoing program to locate and remediate safety threats. These\nthreats to integrity and safety include any issues with the pipe coating quality, cathodic\nprotection effectiveness, operations damage prevention program, pipe depth of soil cover, weld\nseam and girth weld integrity, anomalies in the pipe steel and welds, and material and structures\neither along or near the pipeline that could cause the cathodic protection system to be ineffective.\nPHMSA would have to carefully design a comprehensive set of conditions that STT would have\nto implement for the special permit to be granted.\nPast Enforcement History – January 1, 2013, through February 14, 2023:\nFrom January 1, 2013 (STT started transporting gas in 2017), through February 14, 2023, STT\nwas cited in one (1) enforcement case with a total of $19,000 in assessed civil penalties.\nPHMSA initiated one (1) Notice of Probable Violations against STT due to 49 CFR Part 192\nviolations. The enforcement case was for test requirements and welding of steel in pipeline. The\ntype of 49 CFR Part 192 enforcement violations against STT from 2013 through 2023 includes:\n49 CFR 192.225(a), 192.235, and 192.505(d).\nSummary of Enforcement Findings for Enbridge:\nFrom January 1, 2013 through February 14, 2023, Enbridge, the operator of STT, was cited in 53\nenforcement actions with a total of $1,901,900 in assessed civil penalties on its Algonquin Gas\nTransmission, LLC, (OPID 288), East Tennessee Natural Gas (OPID 04070), Enbridge\nPipelines, LLC (OPID 31448), Enbridge Pipelines, LLC (Ozark) (OPID 31947), Enbridge\nPipelines, LLC (Southern Lights) (OPID 32502), Maritimes & Northeast Pipeline, LLC (OPID\n31335), Nexus Gas Transmission, LLC (OPID 39192), Sabal Trail Transmission (OPID 39167),\nSteckman Ridge, LP (OPID 32380), and Texas Eastern Transmission, LP (OPID 19235) pipeline\nsystems. PHMSA issued three (3) Corrective Action Orders, 22 Notices of Probable Violation,\n13 Notices of Amendment, and 15 Warning Letters to Enbridge.\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 7 of 10\n\n<<<PAGE 8>>>\n\nTables 3 and 4 below show PHMSA’s enforcement actions and civil penalties for Enbridge on\nthese 10 pipeline systems.\nTable 3: Enbridge Enforcement Matters from\nJanuary 1, 2013, through February 14, 2023\nNotice of\nStatus Corrective\nAction Order\nNotice of\nProbable\nAmendment\nSafety\nOrder\nWarning\nLetter Total\nViolation\nCLOSED 2 19 13 0 15 49\nOPEN 1 3 0 0 0 4\nTotal 3 22 13 0 15 53\nTable 4: Enbridge Enforcement Civil Penalty Status\nJanuary 1, 2013, through February 14, 2023\nProposed Awaiting Order Assessed Withdrawn/Reduced Collected\n$2,233,700 $193,700 $1,901,900 $105,300 $1,261,600\nThe type of 49 CFR Part 192 enforcement violations against Enbridge on these 10 pipeline\nsystems from January 1, 2013, through February 14, 2023, were as follows:\nSummary of Enforcement Endings for the 10 Enbridge pipeline systems include:\nAtmospheric Corrosion Control: Monitoring; Construction: Compliance with specifications\nor standards, General Inspection, and Repair; Corrosion Control: Corrosion Control Records;\nDesign: Compressor Stations Emergency Shutdown; Enforcement Procedures: Inspections and\nInvestigations, Integrity Management (IM): Conducting IM Baseline Assessment, Continual\nProcess of Evaluation and Assessment, Elements and Implementation, Preventative and\nMitigative Measures, Program Elements, Record Keeping, and Threat Identification; OME\nProcedural Manual: Abnormal Operations, General, and Maintenance and normal operations;\nMaintenance: Auxiliary Power Sources, Control Systems, Procedures, Transmission lines-leak\nsurveys, Transmission lines-patrolling, Transmission lines-Record keeping, and Valve\nMaintenance Transmission Lines; Operations: Change in Class Location (Confirmation or\nRevision of MAOP), Change in Class Location (Required Study), Continuing Surveillance,\nEmergency Plans, General, Procedures, and Transfer Procedures; Operator Qualification:\nQualification Program; Public Awareness: Develop and Implement Public Awareness, Follow\nAPI RP 1162, and Justification for not following API RP 1162; Test Requirements: SMYS >\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 8 of 10\n\n<<<PAGE 9>>>\n\n30%; Gas Transportation: Underground Natural Gas Storage Facilities; Welding: Preparation\nfor Welding, Procedures, and Qualification of Welders.\n• 49 CFR 192.7, 192.105, 192.12, 192.167, 192.225, 192.227, 192.233, 192.235, 192.303,\n192.305, 192.307, 192.455, 192.461, 192.463, 192.465, 192.469, 192.475, 192.481,\n192.491, 192.503, 192.505, 192.507, 192.517, 192.603, 192.605, 192.609, 192.611,\n192.613, 192.615, 192.616, 192.619, 192.705, 192.706, 192.709, 192.736, 192.745,\n192.801, 192.805, 192.907, 192.911, 192.917, 192.921, 192.933, 192.935, 192.937, and\n192.947.\nTable 5 below gives a complete summary of the findings and the specific 49 CFR Parts 191 and\n192 violation:\nTable 5: Summary of Enforcement Findings for Enbridge\nJanuary 1, 2013, through February 14, 2023\nNotice of Amendment\nConstruction 4 Integrity Management 3 OME Procedural Manual 4\nOperator Qualification 1 Public Awareness 6 Transportation of Gas 2\nWelding of Steel in Pipelines 3\nNotice of Amendment Total: 23\nNotice of Probable Violation\nConstruction 2 Corrosion Control 6 Design 1\nIntegrity Management 5 OME Procedural Manual 5 Operation and/or Maintenance 4\nPublic Awareness 2 Reporting 2 Welding of Steel in Pipelines 2\nNotice of Probable Violation Total: 29\nWarning Letter\nConstruction 4 Corrosion Control 5 Integrity Management 2\nNational Pipeline Mapping\nSystem 1 OME Procedural Manual 9 Operation and/or Maintenance 6\nOperator Qualification 1 Public Awareness 4 Test Requirements 1\nTransportation of Gas 1 Welding of Steel in Pipelines 1\nWarning Letter Total: 35\nGrand Total: 87\nFindings:\nBased on the information submitted by STT and PHMSA’s analysis of the technical, operational,\nand safety issues, PHMSA finds that granting this special permit to STT to operate the special\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 9 of 10\n\n<<<PAGE 10>>>\n\npermit segment on the 36-inch diameter Line 1 pipeline in Sumter County, Florida, for 53,486\nfeet (approximately 10.13 miles) of Class 1 location pipe in a Class 3 location is consistent with\npipeline safety.\nPHMSA has designed special permit conditions to effectively assess and remediate threats to the\nspecial permit segment and special permit inspection area, including assessments to evaluate\nthe pipeline for corrosion, cracking, 3rd party damage, leaks, and other identified threats to the\nspecial permit segment. To ensure STT properly implements the special permit conditions, STT\nwill be required to give PHMSA an annual review of their compliance with the special permit.\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 permit requires STT to\nimplement the special permit conditions with include safety requirements on the operations,\nmaintenance, and integrity management of the special permit segment and the special permit\ninspection area.\nPrepared by: PHMSA OPS - Engineering and Research Division\nDate: September 19, 2023\nLast Page of the Special Permit Analysis and Findings\nPHMSA-2021-0052: Special Permit Analysis and Findings Sabal Trail Transmission – Sumter County, Florida\nPage 10 of 10\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nSeptember 19, 2023\nThomas V. Wooden, Jr.\nVice President, Engineering and Asset Management\nEnbridge, Inc.\n5400 Westheimer Court\nHouston, Texas 77056\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nRe: Docket No. PHMSA-2021-0052\nSpecial Permit from September 19, 2023, to September 19, 2033\nDear Mr. Wooden:\nOn April 5, 2021, pursuant to the 49 Code of Federal Regulations (CFR) § 190.341, Sabal Trail\nTransmission, LLC (STT)1 applied to the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) for a special permit to waive compliance with 49 CFR § 192.611 for\nClass 1 to Class 3 location changes of approximately 10.13 miles of the 36-inch diameter Line 1\npipeline (Pipeline) located in Sumter County, Florida. A gas transmission pipeline operator is\nrequired by 49 CFR § 192.611 to confirm or revise the maximum allowable operating pressure\n(MAOP) of a pipeline segment where the class location has changed as defined in 49 CFR\n§ 192.5.\nOn August 26, 2021, PHMSA published a Federal Register notice (86 FR 47734), announcing\nthe Special 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-2021-0052 in the Federal Docket Management System located at\nwww.regulations.gov.2\nPHMSA grants this special permit (enclosed) based on the information provided by STT and the\nfindings set forth in the SPAF, FEA, and FONSI. This special permit permits STT to operate the\n36-inch diameter Line 1 from the outlet of Dunnellon compressor station (Mile Post (MP)\n395.73) to the inlet of the Reunion compressor station (MP 482.3) at or below a MAOP of 1,355\n1 Sabal Trail Transmission, LLC is a subsidiary of Enbridge, Inc.\n2 https://www.regulations.gov/docket?D=PHMSA-2021-0052.\n\n<<<PAGE 2>>>\n\npounds per square inch gauge (psig). STT is required to comply with conditions and limitations\ndesigned to maintain pipeline safety as defined in the special permit. If STT elects not to\nimplement the special permit conditions, STT must notify PHMSA within 60 days and comply\nwith 49 CFR § 192.611 within 18 months of the date of this letter.\nMy staff is available to discuss this special permit or any other regulatory matter with you. Mary\nL. McDaniel, Acting Director of PHMSA Engineering and Research Division, may be contacted\nat (713) 272-2847, on technical matters, and Greg Ochs, Director, Office of Pipeline Safety,\nCentral Region may be contacted at (816) 329-3814, for operational matters specific to this\nspecial permit.\nSincerely,\nLINDA GAIL\nDAUGHERTY\nDigitally signed by\nLINDA GAIL DAUGHERTY\nDate: 2023.09.19\n16:40:29 -04'00'\nAlan K. Mayberry\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit – PHMSA-2021-0052\nSpecial Permit: PHMSA-2021-0052 – Sabal Trail Transmission, LLC\nLetter of Decision – Class 1 to 3 Locations - Florida Page 2 of 2","truncated":false,"body_characters":23712}