{"operation":"document","citation":"PHMSA-2022-0167","title":"East Tennessee Natural Gas — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2023-03-31","effective_on":"2023-03-31","summary":"PHMSA-2022-0167, issued 2023-03-31 for East Tennessee Natural Gas's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2022-0167.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2022-0167.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2022-0167","source_url":"https://www.regulations.gov/docket/PHMSA-2022-0167","body":"PHMSA pipeline special permit PHMSA-2022-0167. Operator: East Tennessee Natural Gas. System: Gas Transmission. Issue date: 2023-03-31.\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSPECIAL PERMIT – Usage of Composite Pipe\nSpecial Permit Information:\nDocket Number: PHMSA-2022-0167\nRequested By: East Tennessee Natural Gas Transmission, LLC\nOperator ID#: 4070\nOriginal Date Requested: December 2, 2022\nOriginal Issuance Date: March 31, 2023\nEffective Dates: March 31, 2023 to March 31, 2033\nCode Section(s): 49 CFR 192.53(c), 192.121, 192.144, 192.149, 192.150,\n192.619(a), 192.624, 192.710, and 192.714 (effective May 24,\n2023)\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 permit\nto East Tennessee Natural Gas Transmission, LLC (ETNG)2 for a special permit segment totaling\napproximately 0.64 miles of 8.625-inch diameter gas transmission pipeline on Line 3320A-100\nlocated in Roanoke County, Virginia to allow for insertion of a 7.6-inch diameter composite pipe and\ncomponents. This special permit is for use of non-steel (composite) pipe in a gas transmission\npipeline. Composite pipe (Smartpipe®)3 is a type of flexible reinforced thermoplastic pipe (RTP)\nwhich is not authorized for use in regulated gas transmission pipelines.\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 East Tennessee Natural Gas, LLC is owned by Enbridge.\n3 Smartpipe® is defined as the composite pipe. Smartpipe® system is the Smartpipe® pipe and components.\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 1 of 29\n\n<<<PAGE 2>>>\n\nI. Purpose and Need:\nThis special permit allows ETNG to maintain the current maximum allowable operating pressure\n(MAOP) of 813 pounds per square inch gauge (psig). This segment is non piggable, and without a\nspecial permit, it would be subject to MAOP reconfirmation under 49 CFR § 192.624 assessment\nrequirements for Class 3 locations.\nThis special permit application request seeks a special permit to use composite pipe in a gas\ntransmission pipeline that operates at a MAOP of 813 psig. ETNG has requested a special permit for\napproximately 0.64 miles of natural gas transmission pipeline of the following 49 CFR Part 192\nsections:\nSection Section Title Description of Waived Requirements\n192.53(c) General Sub-paragraph (c) does not recognize Smartpipe® in meeting the\nrequirements of the Subpart.\n192.121 Design of Plastic Pipe\nThe qualification requirements are specific to plastic pipe, and do\nnot apply to flexible non-metallic Reinforced Thermoplastic Pipe\n(RTP) such as Smartpipe®.\n192.144 Qualifying metallic components There is no listed specification for the swaged steel connectors to use\nwith Smartpipe®.\n192.149 Standard fittings There is no listed specification for Smartpipe® connectors.\n192.150 Passage of internal inspection\ndevices\nThere are presently no ILI tools for composite pipe systems since the\ninternal wall of the composite is thermoplastic instead of steel.\n192.619(a) Maximum allowable operating\npressure: Steel or plastic pipelines This section does not provide a design formula for RTP.\n192.624\nMaximum allowable\noperating pressure\nreconfirmation: Onshore steel\ntransmission pipelines\nThe MAOP reconfirmation requirements do not expressly\ncontemplate the installation of composite RTP.\n192.710 Transmission lines: Assessments\noutside of high consequence areas\nThe assessment requirements are specific to onshore steel\ntransmission pipelines and do not expressly contemplate assessment\nof pipelines comprised of composite RTP.\n192.714\n(effective May\n24, 2023)4\nTransmission lines: Repair\ncriteria for onshore transmission\npipelines\nThe repair requirements are specific to onshore steel transmission\npipelines and do not expressly contemplate assessment of pipelines\ncomprised of composite RTP.\n4 Final Rule, Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic\nProtection, Management of Changes, and Other Related Amendments, 87 Fed. Reg. 522245 (Aug. 24, 2022) (with an\neffective date of May 24, 2023).\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 2 of 29\n\n<<<PAGE 3>>>\n\nSpecial Permit Segment:\nThis special permit pertains to the specified special permit segment defined in Table 1 – Special\nPermit Segment and is identified using the ETNG survey station (SS). The special permit segment is\ndefined as the Smartpipe®, fittings, monitoring devices, and related facilities to be installed to comply\nwith the special permit conditions.\nTable 1 – Special Permit Segment\nStart\nEnd\nOutside\nDiameter\nLine Name Length\n(feet)\nSurvey\nSurvey\nCounty,\nNo.\nYear\nSeam\nMAOP\nStation\nStation\nState\nDwellings\nInstalled\nType\n(psig)\n(inches)\n(SS)\n(SS)\n8.625 RURA-ELON –\nLine 3320A-100 3,403 0+00 34+03 Roanoke,\nVA 6 1965 ERW 813\nNote: ERW is a low frequency electric resistance welded pipe longitudinal seam.\nAttachment A is a general map that includes the pipeline route map showing the special permit\nsegment.\nThe current potential impact radius (PIR) for ETNG Line 3320A-100 is 170 feet, and there are 6\ndwelling units within the PIR. The MAOP of the special permit segment is 813 pounds per square\ninch gauge (psig), which ETNG does not propose to increase under this special permit. Thus, there\nwill be no change to the PIR for the special permit segment.\nPHMSA grants this special permit based on the findings set forth in the “Final Environmental\nAssessment and Finding of No Significant Impact” document, which can be read in its entirety in\nDocket No. PHMSA-2022-0167 in the Federal Docket Management System located on the internet at\nwww.regulations.gov.\nII. Conditions:\nPHMSA grants this special permit subject to ETNG implementing the following conditions on the\nspecial permit segment.\n1) Condition 1 - Maximum Allowable Operating Pressure and General Conditions\na) Maximum Allowable Operating Pressure: ETNG must continue to operate each special\npermit segment at or below a MAOP of 813 pounds per square inch gauge (psig). This MAOP\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 3 of 29\n\n<<<PAGE 4>>>\n\nhas been established based on the pipeline facilities that connect to the special permit segment,\nwhich is ETNG’s Line 3320A-100.\nb) Hydrostatic Test: Prior to ETNG putting the pipe in service, the pipe, connections, and\nappurtenances must be field hydrostatically tested at a pressure of 1.5 times the MAOP of 813\npsig (minimum test pressure of 1,220 psig) for a minimum of 12 hours with recording charts\n(pressure chart, temperature chart, dead weights and log, and calibration records of equipment,\ncalibrated within 30 days of test), the results of which must be made available to the Director,\nPHMSA Central Region, for review, including determination parameters of an acceptable test.\nETNG must compensate for temperature and elevation variations and such compensation must\nbe documented on test records.\nc) General Conditions:\ni) The Smartpipe® in the pipeline must operate at or below a design factor of 0.449 for all\nClass locations and road crossings within the special permit segment.\nii) Due to the composite design of Smartpipe®, Barlow’s formula in 49 CFR 192.105 cannot\nbe used to determine the pressure rating of this material, per API 15S, Second Edition,\nSection 5.3.3. In this case, the 7.6-inch diameter Smartpipe® has a minimum burst\npressure of 4,300 psig, which results in a maximum pressure rating of 813 psig.5\n2) Condition 2 - Procedure Updates\nWithin 90 days of the grant of the special permit, ETNG must develop and maintain procedures in\naccordance with 49 CFR 192.603 and 192.605 that incorporate the special permit condition\nrequirements as follows:\na) Operations and Maintenance Manual: ETNG must amend the applicable sections of its\nOperations and Maintenance (O&M) manual(s) and procedures to incorporate the special\npermit conditions, including but not limited to the following:\ni) ETNG must document its repair and replacement procedures and standards within the\ncomprehensive written specifications or standards required under 49 CFR 192.303 and the\nO&M Procedures required in 49 CFR 192.605.\n5 The 7.6-inch diameter Smartpipe® will be 6.0-inch inside diameter and 7.6-inch outside diameter with a rating of 813\npsig, empty weight of 5.7 pounds per foot, maximum pipe operating temperature of 120 degrees Fahrenheit (°F), and\nmaximum installation tension of 40,000 pounds.\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 4 of 29\n\n<<<PAGE 5>>>\n\nii) ETNG must develop O&M Procedures based upon safe operating conditions but must hand\ndig for initial location of the special permit segment pipeline and associated monitoring\ndevices or communication lines. ETNG must hand or shovel dig whenever excavation\noperations are within two (2) feet of the pipeline and associated monitoring devices’\ncommunication lines.\nb) Integrity Management Program:\ni) ETNG must incorporate each special permit segment into its written integrity management\nprogram (IMP) procedures as if the special permit segment is a “covered segment” as\ndefined in 49 CFR 192.903 and must develop and follow an integrity management (IM)\nprogram in accordance with the requirements of 49 CFR Part 192, Subpart O (except as\nwaived or modified herein) applicable to plastic transmission pipelines including the\nfollowing sections: 49 CFR 192.901, 192.917(b) through (e), 192.921(a)(2) or (a)(4),\n192.935, 192.937(c)(2) or (c)(4), and 192.939(b). This includes, but is not limited to, risk\nassessments, regular patrolling, participation in the national one-call system, direct\nassessment sections for periodic testing and installation of remote-controlled valves.\nii) The special permit segment must have integrity threats identified, assessed, and\nremediated in accordance with these special permit conditions, 49 CFR 192.917, and 49\nCFR Part 192, Subpart O.\niii) Any high consequence area (HCA) in a special permit segment must be assessed and\nremediated for threats in accordance with these special permit conditions and 49 CFR Part\n192, Subpart O.\niv) All permit conditions that are applicable to the special permit segment are applicable to\nHCAs where the HCA overlaps the special permit segment.\nv) The special permit segment must meet the requirements of 49 CFR 192, Subpart O, if\nSubpart O is more stringent than the special permit conditions.\nc) Damage Prevention Program: ETNG must incorporate within a special permit inspection\narea the applicable best practices of the Common Ground Alliance (CGA)6 in its damage\nprevention (DP) program. ETNG must prepare and follow a damage prevention program in\n6 Common Ground Alliance. (March 2020). Best Practices Guide. Retrieved from:\nhttps://commongroundalliance.com/BPguide.\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 5 of 29\n\n<<<PAGE 6>>>\n\naccordance with 49 CFR 192.614. ETNG must make this program part of its O&M\nProcedures prior to placing the special permit segment in natural gas service.\nd) Manuals - Design, Construction, Operating, Maintenance, and Emergency Response:\nETNG must submit manuals, procedures, specifications, or other documents pertaining to the\nDesign, Construction, O&M, and Emergency Response related to the special permit segment\nfor review by the Director, PHMSA Central Region, at least 30 days prior to operation of the\nspecial permit segment pipeline, unless otherwise indicated in writing by the Director,\nPHMSA Central Region.\n3) Condition 3 - General and Design Requirements\na) Branches: ETNG must not tap, branch, or split the special permit segment Smartpipe®\nwithout the use of the appropriate Smart Pipe Company Inc. (SPCI) manufactured fittings for\nthe specified application. Prior to installation of a tap, branch, or split, ETNG must submit a\nnotification to the Director, PHMSA Central Region, and receive a “no objection” letter.\nb) Road Crossings: Due to the nature of the installation method, all road crossings must be cased\nwith steel pipe. Any future road crossings using Smartpipe® must have a minimum of 36-\ninches cover and must be cased or 49 CFR Part 192 compliant steel pipe must be installed.\n4) Condition 4 - Material and Testing Requirements\na) Pipe Layers: ETNG must install line pipe in the special permit segment that is comprised of\nhigh-density polyethylene (HDPE) PE4710 inner layer made from natural gas pipe grade\nmaterial, which meet the material requirements of API 15S, Second Edition. All composite\ncomponents must be manufactured and tested in accordance with API 15S, Second Edition.\nb) Regrind and Rework of Polymeric Materials: Materials used in the manufacture of the pipe\ninstalled within the special permit segment, during construction or in future repairs or\nreplacement, may not contain any regrind or rework material.\nc) Outdoor Pipe Storage: ETNG must comply with API 15S, Second Edition requirements for\noutdoor storage and ultraviolet radiation exposure of polyethylene (PE) pipe for all\nSmartpipe® system materials used in the special permit segment. ETNG must document\ncompliance with API 15S, Second Edition in its Material Specifications and O&M Procedures.\nd) Factory Pressure Testing: To verify the pipe produced for the special permit segment two (2)\nsamples from beginning of production and two (2) samples from end of production must be\nfactory pressure tested by short term burst following API 15S, Second Edition, Section 6.4.2.2\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 6 of 29\n\n<<<PAGE 7>>>\n\nwith results compared to product variant testing to qualify production parameters. ETNG must\nmake available pressure test records demonstrating that special permit segment pipe was\nfactory pressure tested. Such records must be traceable to line pipe, repair pipe, and\nreplacement pipe used within the special permit segment and must include: pressure test\nreports, pressure testing parameters (pressure, time, procedure and/or standard number, date,\netc. and test acceptance parameters), and pressure testing recorders with current calibration\nrecords for pressure test recoding equipment. ETNG must provide a certification from the pipe\nmanufacturer that the tests were completed. ETNG must make available all pressure test\nrecords to the Director, PHMSA Central Region, prior to operation of the special permit\nsegment upon request.\ne) Testing of Reinforcement Materials: Smartpipe® samples that are same design and\nconstruction as the special permit segment must be obtained from Smartpipe® inventory.\nThe following testing must be performed:\ni) Conduct short-term burst testing on five (5) samples at ambient temperature per the\nrequirements of American Petroleum Institute, API 15S, Second Edition, Section 5.3.4.\nii) The reinforcement materials, prior to pipe construction, shall be destructively tested.\nSamples from each reinforcement material reel shall be tested for yield strength, and\nelongation. in accordance with American Society for Testing and Materials (ASTM),\nASTM D5035. The results of the tensile properties testing must be compared to the\nmanufacturer’s requirements for as-received reinforcement materials\niii) ETNG must obtain mechanical and chemical properties test reports that certify the\nreinforcement material used in manufacturing the Smartpipe®.\nf) Elevated Temperature Testing: One (1) sample obtained from Smartpipe® inventory, of the\nsame design and construction to be used in the special permit segment, must be subjected to\nelevated temperature testing per the requirements of API 15S, Second Edition, Section 5.4.3.2.\ng) Long-Term Integrity: In designing the pipeline, ETNG must consider and plan for all\npipeline integrity risk factors, including, but not limited to: Pressure and temperature cycling;\nperformance of multilayer Smartpipe® at minimum operating temperatures, and repairs under\na range of ambient conditions; long term performance of composite material and mechanical\nfittings; cathodic protection of metallic appurtenances; long term performance of pipe; risk\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 7 of 29\n\n<<<PAGE 8>>>\n\nmigration through damage to the pipe wall; and methods for assessment of buried or excavated\npipe.\ni) ETNG must schedule and perform three (3) inspections during which non-destructive and\ndestructive testing must be performed on the pipe material after installation.\nNondestructive testing must focus on the composition and degradation of the pipe material\nand destructive testing must include a hydrotest to burst pressure. ETNG must perform\nthese inspections and tests in years 1, 3, and 4.5 (not to exceed this timing by 90-days) after\ninstallation.\nii) A Direct Assessment7 segment must be installed in such a way that simulates the condition\nof the special permit segment in the immediate vicinity of the operating pipeline at\nMilepost 0.64 on or near ETNG’s property, see Appendix A - Pipeline Overview Map.\nThis Smartpipe® Direct Assessment segment must have 10 feet removed during the\nintervals defined in Condition 3(g)(i) above to be evaluated, including destructive testing.\nThe test results must be sent to the Director, PHMSA Central Region, and posted on the\ndocket at www.regulations.gov.\n(1) Each removed Direct Assessment sample must be disassembled, visually, and non-\ndestructively inspected, as appropriate, including any indications of corrosion or\nslippage of the end fitting.\n(2) The Smartpipe® Direct Assessment sample must be burst tested per the requirements\nof API 15S, Second Edition, Section 6.4.2.2.\niii) Perform removal, replacement, and installation of pipe and fittings, and other actions\nrelated to the removal of test segments, in accordance with the requirements of this special\npermit.\niv) ETNG must report the results of the inspections and tests to the Director, PHMSA Central\nRegion, within 60 days of completion of testing.\nv) In lieu of performing the testing requirements described in Conditions 4(g)(i) and\n4(g)(ii)(1) and (2), of this special permit, and since the special permit segment will be\n7 Direct Assessment Segment consists of multiple Smartpipe® samples that are from the same production run of the\ninstalled special permit segment. The Direct Assessment Segment is attached to the special permit segment and will\noperate at the same pressure, temperature, and flow as the special permit segment. The Direct Assessment segment\ncan be isolated for removal of Smartpipe® samples for testing as prescribed in the special permit conditions.\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 8 of 29\n\n<<<PAGE 9>>>\n\nconnected to the special permit segment installed under PHMSA-2022-0167, ETNG may\nuse the results of the destructive and non-destructive testing to determine the long-term\nintegrity of the pipeline. Any results from the analysis of these tests that require corrective\naction(s) shall be applied to the special permit segment.\n5) Condition 5 - Construction Operator Qualifications\na) If the performance of a construction task associated with construction or repair of the special\npermit segment could affect the integrity of the segment, ETNG must treat that task as a\n“covered task” notwithstanding the definition in 49 CFR 192.801(b), and must implement the\nrequirements of 49 CFR Part 192, Subpart N. ETNG’s construction operator qualification\n(COQ) procedures, training program, and qualification tests must include detailed information\non all construction-related tasks as a covered task.\nb) ETNG must develop and implement a COQ plan that specifically relates to construction\nactivities for the special permit segment. The purpose of the plan must be to ensure\nconstruction personnel and operations personnel are trained. The COQ plan must be followed\nthroughout the construction phase with respect to the following: pipe inspection, hauling and\nstringing, appurtenance inspection, installation of appurtenances, padding and backfilling as\nrequired, hydrostatic testing, pipe repairs made from hydrostatic testing, dewatering and\npurging, and inspection of work (i.e. trenching, excavating, etc.). These tasks can affect the\nintegrity of the special permit segment and must be treated as “covered tasks.” The\nSmartpipe® must be installed in one continuous section. Installation and end connections\nsystems must be completed by qualified SPCI personnel.\nc) ETNG must also treat in the following special permit segment tasks as covered COQ “covered\ntasks,” such tasks include: right-of-way soil stability determination, surveying, locating foreign\nlines, one call notifications, ditching or excavation, cathodic protection (CP) system surveys,\nmitigation, and installation, anomaly evaluations and repairs, right of way clean up (including\ninstallation of line markers), SCADA control point installation and verification, gas quality\nmonitoring, and quality assurance monitoring.\nd) ETNG must have SPCI personnel on-site when initial pipeline installation is conducted.\nETNG must have SPCI certified joining personnel onsite installing all SPCI end fittings.\ne) ETNG must develop and make available its COQ plan to the Director, PHMSA Central\nRegion, 30-days prior to beginning construction.\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 9 of 29\n\n<<<PAGE 10>>>\n\n6) Condition 6 - Excavation, Pipe Cover, and Damage Prevention\na) Pipe - Inspection for Damage:\ni) ETNG must develop and implement an inspection training and qualification plan and must\nsend the plan to the Director, PHMSA Central Region, 30 days prior to the start of\nconstruction. This plan must define the requirements and training necessary to inspect and\nevaluate damage to Smartpipe® and fittings. In addition, ETNG must have SPCI\nemployees on site during any insertion activities to not only to advise on any construction\nrelated activities but to assist in inspection, evaluation, and repair of any damage\nindications, should they be encountered. Note: The Smartpipe® configuration referenced\nbelow has a C-formed outer cover of 25 mil (.025 inch) thick that is intended to be\nsacrificial during pull-in.\nii) ETNG must certify and document all inspections with date, time, pipeline station, and\nSmartpipe® product identification number.\niii) ETNG must inspect the leading 50 feet of pull-through pipe for damage. All indications of\npipe damage must be evaluated and replaced or repaired as follows:\n(1) Prior to installation a 100-foot section (Beta) of Smartpipe® will be pulled through to\nverify the host pipe condition and Smartpipe® condition post pull through. If the\nSmartpipe® body that has a cut through the outer pipe covers greater than 75 mil\n(0.075 inch) and fully exposes the helical reinforcement fiber bundles, this shall be\ncause for further cleaning and inspection of the host pipe. A successful Beta run shall\nbe completed before the final pull through.\n(2) During the Smartpipe® installation, if the Smartpipe® pipe body is cut through the\nouter round pipe covers greater than 75 mil (0.075 inch) in depth and greater than six\ninches in length or width exposing the axial reinforcement layers, continue to pull\nthrough until there is 25 feet of undamaged section. All indications of pipe damage (as\ndescribed above) must be evaluated by SPCI qualified personnel and tested, replaced,\nor repaired as follows:\n(a) Any cuts greater than 100 mils (0.10 inch) of the outer pipe layers and exposing the\naxial fiber strength layers (pull tapes) shall be cause for burst testing a section of\npull-through pipe.\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 10 of 29\n\n<<<PAGE 11>>>\n\n(i) Cut out section, remove outer cover layers for inspection, re-round section and\nburst test to confirm integrity of helical reinforcement and core pipe.\n(ii) If burst test is successful, continue termination operations.\n(b) Any cuts greater than 200 mils (0.200 inch) through the outer pipe layers and axial\nreinforcement layers and into the of the helical reinforcement fiber bundles shall be\ncause for rejection of pull through section.\n(i) Pull through additional pipe to confirm condition.\n(ii) If pipe does not meet the above criteria, pipe at contingency termination\nlocations will be assessed.\niv) During the pre-installation, the operator must develop procedures for internally cleaning\nthe existing 8.625-inch diameter pipe (future casing pipe) to remove liquids and debris and\nto inspect the casing pipe for any hazards that could damage the Smartpipe® during the\ncasing pull through. See Condition 6(a)(iii)(1) above for Beta section confirmation.\nv) Prior to insertion, each insertion section of the special permit segment must be pigged with\na cleaning pig to verify the cleanness of the section. If any liquids are found as a result of\nthis cleaning pig run, additional cleaning pig runs must be performed until no unwanted\nliquids are found.\nvi) During the insertion process, the tensile force on the Smartpipe® must be monitored by use\nof a calibrated dynamometer, calibrated within six (6) months of use. This tensile force\nshall be limited to 40,000 pounds which is 44% of the Smartpipe® rating of 90,000 pounds\nforce.\nb) ETNG must develop and implement O&M Procedures and/or Construction Specifications to\nremove and replace any Smartpipe® with the following conditions:\n(1) Damage at any place that exceeds the criteria for wall damage defined in Condition\n6(a)(iii)(2).\n(2) All Smartpipe® must be newly produced after the grant of this special permit and not\nobtained from inventory.\n(3) ETNG must not install any Smartpipe® above grade (ground).\nc) Other possible signs of material damage or unsoundness must be reviewed by qualified\npersonnel, and if the integrity of the Smartpipe® is negatively affected, ETNG must remove\nand replace such pipe.\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 11 of 29\n\n<<<PAGE 12>>>\n\n7) Condition 7 - Corrosion Control\na) ETNG must apply cathodic protection (CP) on all buried Smartpipe® components and joints,\nand the existing 8.625-inch diameter steel pipe (where used as a casing for the Smartpipe®)\nwithin the special permit segment in accordance with 49 CFR Part 192 (except as waived or\nmodified herein).\ni) Each Smartpipe® end fitting or fitting enclosure must be installed with an anode and CP\ntest station.\nii) ETNG must install CP test stations at each metallic end fitting or end fitting enclosure.\nb) ETNG must perform external corrosion control monitoring on each buried metallic fitting and\nthe existing 8.625-inch diameter steel pipe (where used as a casing for the Smartpipe®) in\naccordance with 49 CFR 192.465. ETNG must perform CP monitoring at least once each\ncalendar year, not exceeding 15 months. Corrosion control monitoring of the buried metallic\nfittings by a sampling basis is not permitted.\ni) Each Smartpipe® end fitting must be installed with a test station and anode, coated and\ndirect buried or inside end fitting enclosure.\nii) ETNG must determine the native structure-to-electrolyte potential for each buried metallic\nfitting prior to energizing the CP system.\nc) ETNG must seal the pipeline casing ends to prevent water and other debris from entering the\ncasing annulus.\n8) Condition 8 - Pressure and Temperature Control and Monitoring\na) ETNG must install an annulus monitoring system (Condition 8(d) below) that will provide\ncontinuous integrity monitoring of the Smartpipe® to casing annulus.\nb) Over-Pressure Protection: ETNG must install over-pressure protection equipment necessary\nto keep the pipeline pressure from exceeding 813 psig plus allowable build-up at any time.\nAllowable build ups are those conditions which occur due to anomalous conditions outside of\nthe special permit segment. Occurrences resulting in pressures exceeding 813 psig plus\nallowable build-up of MAOP plus 4%, must be reported to the Director, PHMSA Central\nRegion, within 24 hours or the next business day of the occurrence for their review.\nc) Pressure Monitoring: ETNG must monitor operating pressures by the installation of pressure\ntransmitters and switches in the piping system that report to the facility’s SCADA system.\nETNG must monitor the special permit segment with continuous and redundant pressure\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 12 of 29\n\n<<<PAGE 13>>>\n\ntransmitters and switches. ETNG must provide a means to inform operator personnel\nperforming work on the pipeline of the pressure on the line.\nd) Annulus Monitoring: ETNG must install an annulus monitoring system that will provide\ncontinuous integrity monitoring of the Smartpipe® to casing annulus:\ni) ETNG must continuously monitor through SCADA the pressure of the annulus space\nbetween the Smartpipe® and casing along the entire special permit segment. These\npressure monitoring transmitters and pressure vents must be located at MP 0.64, see\nAppendix A - Pipeline - Special Permit Segment Maps.\nii) The annulus between Smartpipe® and casing is used to monitor casing integrity. This\nannulus is a pressure containing capable structure that is designed to contain pressure up to\n60 psig. Outlets on the end fittings will be outfitted with the necessary tubing to attach\npressure transmitters that must be incorporated into SCADA monitoring. With permeated\ngasses permitted to build to a predetermined level (15 to 25 psig), transmitters will be\nconfigured to alarm on indications of high or low pressure outside of the established\nacceptable range. Continuous pressure readings within acceptable ranges provide real time\nindication that several key integrity features are functioning as designed. Any breach of\nthe casing will result in a loss in pressure indicated by the “real time” annulus monitoring.\nThis monitoring will alert ETNG that third party damage, casing or liner failure may have\noccurred, allowing prompt response for further investigation. ETNG will use this\nmonitoring capability and monitor this annular pressure with a SCADA system on a\ncontinuous 24-hour basis.\niii) The Smartpipe® fittings must be designed to allow the annulus of each segment of pipe to\nbe common with each other, so that monitoring of the annular space can be conducted at\none end of the system.\niv) A pressure relief valve with a 60 psig set point must be installed with annulus monitoring\nequipment to maintain the predetermined level of annulus pressure (15 to 25 psig). This\nrelief and the associated annulus monitoring equipment must be located within fenced in\nlocations at mile post 0.64.\ne) Gas Temperature: ETNG must continuously monitor natural gas temperature at MP 0.64, see\nAppendix A - Special Permit Segment Maps, in order that the pipeline is not exposed to\ntemperatures exceeding 120 degrees Fahrenheit (°F). If the Smartpipe® is exposed to\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 13 of 29\n\n<<<PAGE 14>>>\n\ntemperatures exceeding 120°F8\n, ETNG must conduct an investigation to demonstrate the\nintegrity of the special permit segment pipeline. The results must be provided to the Director,\nPHMSA Central Region, for their review.\nf) Fiber Optic Monitoring: Smartpipe® must be installed with distributed fiber optic sensors\nalong the full length of special permit segment to monitor acoustic signatures, identifying third\nparty intrusion and leak detection. ETNG must continuously monitor the system through\nSCADA.\n9) Condition 9 – Mainline Valve – Monitoring and Remote Control for Ruptures:\nETNG must automate mainline valves9 for closure or demonstrate capability to manually close\nmainline valves in accordance with the requirements of this Condition 9. A special permit\nsegment must have upstream and downstream remote-controlled valves (RCVs) so that the\ndistance between the valves is no greater than 20 miles.10 ETNG must automate mainline valves\nto close in accordance with the requirements in Condition 9 within 12 months of the grant of this\nspecial permit.\nThe special permit segment is on a lateral line. ETNG must automate the valve at MP 0.0 for\nclosure or demonstrate capability to manually close valve in accordance with the requirements of\nthis Condition 9.\nThe special permit segment must have procedures for rupture isolation as follows:\na) Valve Locations: RCVs must be installed as shown in Table 2 - Valves and Lateral\nLocations with Isolations Methods. Each special permit segment must have telemetry\nconnections to the ETNG supervisory control and data acquisition (SCADA) system installed.\nb) Remote Monitoring and Control: Each special permit segment must be controlled by a\nSCADA system and must be equipped for remote monitoring and control, or remote\nmonitoring and automatic control, in accordance with 49 CFR 192.620(d)(3)(iii) and the below\nrequirements in this Condition 9(f).\n8 Smartpipe® has a maximum operating temperature of 140 degrees Fahrenheit, based on a Product Family\nRepresentative as established pursuant to API 15S, Second Edition Testing.\n9 A mainline valve is a sectionalizing valve used to isolate or stop gas flow upstream or downstream along the\npipeline.\n10 If the distance between mainline isolation valves exceeds 20 miles, additional mainline valve(s) must be added.\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 14 of 29\n\n<<<PAGE 15>>>\n\nc) Crossover or Lateral Pipe Connection Isolation: If any crossover or lateral pipe11 connects\nto the isolated segment between the upstream and downstream mainline valves, the nearest\nvalve on the crossover connection(s) or lateral(s) must be isolated such that, when all valves\nare closed, there is no flow path for gas to flow to the leak or rupture site (except for residual\ngas already in the shut-off segment). If the nearest valve for a gas receipt or delivery line to\nthe special permit segment is not isolated, isolation valves must be installed within 12 months\nof the grant of this special permit.12 Valves that are in the ETNG O&M procedures as locked\nclosed and that are only opened when manned by ETNG operating personnel do not require\nRCVs or ASVs for closure.\nd) Remote-Control Valve Status: RCVs must be constantly monitored for valve status (open,\nclosed, or partial closed/open), upstream pressure, and downstream pressure.\ne) Mainline Valve Closure: Closure of the appropriate valves following a pipeline leak or\nrupture must occur “as soon as practicable” and must not exceed 30 minutes from the\n“notification of potential rupture” as defined below:13\ni) “Notification of Potential Rupture” means any of the following events that involve an\nunintentional or uncontrolled release of a large volume of gas from a transmission pipeline:\n(1) A release of gas observed by or reported to ETNG (e.g., by its controller(s) in a control\nroom, field operations personnel, nearby pipeline or utility personnel, the public, local\n11 Table 2 - Valves and Lateral Locations with Isolations Methods has a listing of all lateral valves. ETNG must\nupdate Table 2 if a lateral or crossover valve (includes any blowdown valve at an isolation valve that can feed gas into\nthe rupture isolation segment) was not identified or is added after the grant of the special permit and submit this\nupdate in accordance with Condition 13 – Annual Report. ETNG has identified that no laterals exist between\nisolation valves for a special permit segment. ETNG must update Table 2 - Valves and Lateral Locations with\nIsolations Methods if a lateral or crossover valve (includes any blowdown valve at an isolation valve that can feed\ngas into the rupture isolation segment) was not identified or is added after the grant of the special permit and submit\nthis update in accordance with Condition 13 – Annual Report.\n12 Gas delivery or receipt pipelines must have a shutoff valve (gate or ball valve) either at the connection between the\nisolation valves for a special permit segment or at the delivery or receipt meter station. Any gas delivery or receipt\nstation over 5-miles in length that is connected between the isolation valves for a special permit segment must have a\nRCV or ASV within 5-miles of the pipeline tie-in. For gas delivery or receipt pipelines manual shutoff valves can be\nused for isolation but must be closed within 30-minutes of the pipeline leak or rupture confirmation. Check valves\ncannot be used for pipelines over 8-inch diameter.\n13 The pipeline valve section location to be closed and isolated (if there should be a rupture) must be confirmed by\nETNG through Gas Control or other field operations personnel monitoring of the appropriate pipeline pressures,\npressure changes, or flow rate changes through a compressor discharge section or by location confirmation from\nresponsible persons.\nPHMSA-2022-0167 – East Tennessee Natural Gas, LLC Special Permit – Composite Pipe – Virginia\nPage 15 of 29\n\n<<<PAGE 16>>>\n\nresponders, or public authorities) that may be representative of an unintentional or\nuncontrolled release event meeting paragraphs (2) or (3) of this definition;\n(2) ETNG observes an unanticipated or unplanned pressure loss outside of the pipeline’s\nnormal operating pressures, as defined in ETNG’s written procedures. If ETNG\nestablishes an unanticipated or unplanned pressure loss threshold that is greater than a\n10% pressure loss, occurring within a time interval of 15 minutes or less, ETNG must\ndocument in its written procedures the need for a greater pressure-change threshold due\nto pipeline flow dynamics (including the pipeline operating pressure, gas flow rate or\nvolume), that are caused by fluctuations in gas demand, gas receipts, or gas deliveries;\nor\n(3) ETNG observes an unexplained flow rate change, pressure change, equipment function,\nor other pipeline instrumentation indication that may be representative of an event\nmeeting paragraph (2) of this definition.\nNote: Notification of potential rupture occurs when an event, as defined in this\nsection/paragraphs (2) or (3) above, is first observed by or reported to ETNG.\nii) ETNG must evaluate and identify a rupture,14 as defined above, as being either an actual\nleak event, rupture event, or non-rupture event in accordance with operating procedures\nand 49 CFR 192.615.\nf) Gas Control Center Monitoring: The ETNG Gas Control Center must monitor the special\npermit inspection area 24 hours a day, seven (7) days a week, and must confirm the existence\nof a leak or rupture as soon as practicable in accordance with ETNG pipeline operating\nprocedures.\ng) Remote Monitoring: ETNG must maintain remote monitoring and automatic control\nequipment, mainline valves, mainline valve operators, and pressure sensors in accordance with\n49 CFR 192.631 and 192.745. All remote monitoring and automatic control equipment,\nincluding pressure sensors, must have backup power to maintain communications and control\nto the ETNG Gas Control Center during power outages.\n14 For all in-service and pressure test failures, ETNG must perform a root cause analysis, including examination of the\nfailed pipe, to determine if the failure is caused by a systemic or non-systemic issue. ETNG must provide the written\nresults of this root cause analysis to the Director, PHMSA Central Region, within 90 days of the failure and must\nsubmit a copy of the root cause analysis to the Director, PHMSA Engineering and Re","truncated":true,"body_characters":97219}