{"operation":"document","citation":"PHMSA-2023-0126","title":"Gulf South Pipeline Company, LLC — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-09-02","effective_on":"2025-09-02","summary":"PHMSA-2023-0126, issued 2025-09-02 for Gulf South Pipeline Company, LLC's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2023-0126.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2023-0126.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2023-0126","source_url":"https://www.regulations.gov/docket/PHMSA-2023-0126","body":"PHMSA pipeline special permit PHMSA-2023-0126. Operator: Gulf South Pipeline Company, LLC. System: Gas Transmission. Issue date: 2025-09-02.\n\n<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nSeptember 2, 2025\nMr. Tony Rizk\nVice President, Technical Services\nGulf South Pipeline Company, LLC\n9 Greenway Plaza, Suite 2800\nHouston, TX 77046\nRe: Docket No. PHMSA-2023-0126 – Gulf South Pipeline Company, LLC – Grayson\nCounty, Texas, Special Permit from September 2, 2025 to September 2, 2035\nDear Mr. Rizk:\nOn November 15, 2023, pursuant to 49 Code of Federal Regulations (CFR) § 190.341, Gulf South\nPipeline Company, LLC (GSPC)1 applied to the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) for a special permit. GSPC requested a special permit to waive\ncompliance with 49 CFR §§ 192.611(a) and (d) and 192.619(a) for Class 1 to Class 3 location\nchanges on two pipeline segments. Both segments consist of approximately 2.283 miles of 16-\ninch diameter gas transmission pipeline and are located in Grayson County, Texas. A gas\ntransmission pipeline operator is required by 49 CFR § 192.611 to confirm or revise the\nmaximum allowable operating pressure of a pipeline segment or reduce it according to the limits\nrequired by 49 CFR § 192.619(a), where the class location has changed as defined in 49 CFR\n§ 192.5.\nOn September 4, 2024, PHMSA published a Federal Register notice (89 FR 72152) 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- 2023-0126 in the Federal Docket Management System located at\nwww.regulations.gov.\n2\nSubject to the stated terms and conditions, PHMSA grants this special permit (enclosed) based\non the information provided by GSPC and the findings set forth in the SPAF, FEA, and FONSI.\nThis special permit provides relief from certain regulations and requires GSPC to comply with\nconditions and limitations designed to maintain pipeline safety as defined in the special permit.\n1 Gulf South Pipeline Company, LLC is owned by owned by Boardwalk Pipelines, LP.\n2 https://www.regulations.gov/docket?D=PHMSA-2023-0126\nSpecial Permit: PHMSA-2023-0126 – Gulf South Pipeline Company, LLC Letter of Decision – Class 1 to Class 3 Location – Texas\nPage 1 of 2\n\n<<<PAGE 2>>>\n\nIn accordance with 49 CFR § 190.341(j), PHMSA reserves the right to revoke, suspend, or\nmodify this special permit if circumstances occur in which its continuance would be inconsistent\nwith pipeline safety. If GSPC elects not to implement the special permit conditions, GSPC must\nnotify PHMSA within 60 days and comply with 49 CFR § 192.611 within 18 months of the date\nof this letter.\nPHMSA notes that the conditions imposed by this special permit are consistent with those\noriginally noticed. However, PHMSA is in the process of reforming its process for reviewing and\nissuing special permits in order to streamline conditions imposed and reduce unnecessary\nregulatory burden on use of domestic energy resources in accordance with EO 14154,\nUnleashing American Energy.\n3 PHMSA has offered operators of special permits previously\nnoticed the opportunity to seek reconsideration of their special permits and resubmit their\napplications for notice and comment in line with the new process. GSPC declined to do so at this\ntime and elected to maintain its current application, but this decision does not preclude GSPC\nfrom reapplying in the future.\nMy staff is available to discuss this special permit or any other regulatory matter with you. Max\nKieba, Director, Engineering and Research Division, Office of Pipeline Safety, may be contacted\nat PipelineSPEngineeringDirector@dot.gov or 202-420-9169 on technical matters; and Dave\nBarrett, Acting Director, Central Region, Office of Pipeline Safety, may be contacted at 816-\n329-3817 for operational matters specific to this special permit.\nSincerely,\nLinda Daugherty\nActing Associate Administrator for Pipeline Safety\nEnclosure: Special Permit – PHMSA-2023-0126\n3 Exec. Order. No. 14,154, 90 Fed. Reg. 8353 (Jan. 29, 2025). For further information on PHMSA’s efforts to reform special permits, see Pipeline\nSafety: Rationalize Special Permit Conditions, 90 Fed. Reg. 28590 (July 1, 2025).\nSpecial Permit: PHMSA-2023-0126 – Gulf South Pipeline Company, LLC Letter of Decision – Class 1 to Class 3 Location – Texas\nPage 2 of 2\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY\nADMINISTRATION\nSPECIAL PERMIT – Class 1 to Class 3 Location\nSpecial Permit Information:\nDocket Number: PHMSA-2023-0126\nRequested By: Gulf South Pipeline Company, LLC\nOperator ID#: 31728\nOriginal Date Requested: November 15, 2023\nOriginal Issuance Date: September 2, 2025\nEffective Dates: September 2, 2025 to September 2, 2035\nCode Section(s): 49 CFR §§ 192.611(a) and (d) and 192.619(a)\nGrant of Special Permit:\nBy this order, subject to the terms and conditions set forth below, the Pipeline and Hazardous\nMaterials Safety Administration’s (PHMSA) Office of Pipeline Safety (OPS)1 grants this special\npermit to Gulf South Pipeline Company, LLC (GSPC)2 for two special permit segments\nconsisting of approximately 2.28 miles of 16-inch diameter gas transmission pipeline located in\nGrayson County, Texas. This special permit waives compliance from 49 Code of Federal\nRegulations (CFR) §§ 192.611(a) and (d) and 192.619(a) for the two special permit segments\nwhich have undergone changes from Class 1 to Class 3.\n3 Federal pipeline safety regulations in\n49 CFR § 192.611(a) require natural gas pipeline operators to confirm or revise the maximum\nallowable operating pressure (MAOP) of a pipeline segment or reduce it according to the limits\nrequired by 49 CFR § 192.619(a) after a change in class location.\nTo avoid confusion, PHMSA has clarified the conditions applicable to GSPC by removing\nconditions that were either duplicative with existing 49 CFR Subpart D requirements or are not\napplicable to the Index 819-10 pipeline based on its characteristics and history as documented in\nGSPC records and verified by PHMSA. PHMSA reviewed material and pressure test records and\n1 Throughout this special permit, the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of Transportation’s Pipeline and\nHazardous Materials Safety Administration Office of Pipeline Safety.\n2 Gulf South Pipeline Company, LLC is owned by Boardwalk Pipelines, LP.\n3 GSPC anticipates that Special Permit Segment 1 will be within a Class 3 location after completion of a planned development by Austin College.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 1 of 33\n\n<<<PAGE 2>>>\n\nverified the Index 819-10 pipeline does not contain electric frequency welded or vintage seam\ntypes. The pipeline was installed in 2013 and 2014 and has only high-frequency electric\nresistance welded and seamless seam types. Both the pipe material data and pressure test\ndocumentation have been evaluated and determined by PHMSA to be adequate.\nI. Purpose and Need\nGSPC sought this special permit for Class 1 to Class 3 location changes occurring on the 16-inch\ndiameter Index 819-10 pipeline. Provided GSPC complies with the terms and conditions set forth\nbelow, the special permit waives compliance from 49 CFR §§ 192.611(a)4 and (d) and\n192.619(a) for approximately 2.28 miles of natural gas transmission pipeline. This special permit\nallows GSPC to maintain the current MAOP as shown in Table 1 – Special Permit Segments.\nII. Special Permit Segments and Special Permit Inspection Area\nThis permit pertains to the specified special permit segments and corresponding special permit\ninspection area defined in this section.\nSpecial Permit Segments:\nThis special permit applies to the special permit segments in Table 1 – Special Permit\nSegments and locations are identified using the GSPC survey station (SS) references.\nTable 1 – Special Permit Segments\nSpecial\nStart\nEnd\nOutside\nPermit\nLine\nDiameter\nName\nLength\n(feet)\nSurvey\nStation\nSurvey\nStation\nCounty or\nParish,\nNo.\nYear\nSeam\nMAOP\nSegment\nNumber\nDwellings\nInstalled\nType\n(psig)5\n(inches)\nState\n(SS)\n(SS)\n1 16 Index\n819-10 4580 585+22 631+32 Grayson,\nTX 06 2014 HF–\nERW, 1350\n2 16 Index\n819-10 7472 728+40 803+12 TX Grayson,\n240 2013,\n2014\nHF–\nERW,\nSMLS\n1350\nNote: HF-ERW is a high frequency electric resistance welded pipe longitudinal seam.\nSMLS is a seamless longitudinal seam.\n4 PHMSA is granting this special permit for Class 1 to Class 3 location changes where the pipeline has been pressure tested to 1.25 times MAOP\nor greater for eight hours to meet 49 CFR §§ 192.619(a)(2), 192.611(a), and 192.517. Each special permit segment must meet the documentation\nrequirements in Condition 16 – Documentation.\n5 Pressure tests were conducted after July 1, 1965; see 49 CFR § 192.619(a)(3) for applicability.\n6 As of the Original Issuance Date of this Special Permit, Special Permit Segment 1 is within a Class 1 location. GSPC applied for Special Permit\nSegment 1 in anticipation of a future development project of Austin College.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 2 of 33\n\n<<<PAGE 3>>>\n\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.\nTable 2 – Special Permit Inspection Area\nSpecial\nSpecial Permit\nOutside\nPermit\nInspection\nDiameter\nLine Name Start SS End SS Length\n(miles)\nArea Number\nSegments\nIncluded\n(inches)\n1 1, 2 16 Index 819-10 0+00 871+73 16.53\nExtended Special Permit Segments:\nThe extended special permit segments are defined as the special permit segments and the five\ncontiguous miles past each endpoint.\nAppendix B contains general maps that include the pipeline route map showing the special\npermit segments and special permit inspection area and more detailed maps showing the area\nnear the special permit segments.\nPHMSA grants this special permit based on the findings set forth in the “Special Permit Analysis\nand Findings” and “Final Environmental Assessment and Finding of No Significant Impact”\ndocuments, which can be read in their entirety in Docket No. PHMSA-2023-0126 in the Federal\nDocket Management System located at www.regulations.gov.\nIII. Conditions\nPHMSA grants this special permit subject to GSPC implementing the following conditions on\nthe special permit segments and special permit inspection area. Each condition detailed in this\nsection applies to the special permit inspection area and the corresponding special permit\nsegments unless otherwise noted in the condition:\n1) Condition 1 – Maximum Allowable Operating Pressure\na) Maximum Allowable Operating Pressure: GSPC must continue to operate each\nspecial permit segment and special permit inspection area at or below the existing\nMAOP of 1350 pounds per square inch gauge (psig) (Index 819-10).\nb) Pressure Test: GSPC has furnished pressure test records to PHMSA for each special\npermit segment, which meet 49 CFR § 192.517(a) and have been determined to be\nadequate.\n2) Condition 2 – Procedure Updates\nWithin 90 days of the grant of the special permit, GSPC must develop and maintain procedures\nin accordance with 49 CFR §§ 192.603 and 192.605 that incorporate the special permit condition\nrequirements as follows:\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 3 of 33\n\n<<<PAGE 4>>>\n\na) Operations and Maintenance Manual: GSPC must amend the applicable sections of\nits operations and maintenance (O&M) manuals and procedures to incorporate the\nspecial permit conditions.\nb) Integrity Management Program:\ni) GSPC must incorporate each special permit segment into its written integrity\nmanagement program (IMP) as if the special permit segments are “covered\nsegments” as defined in 49 CFR § 192.903, except for the reporting requirements\ncontained in 49 CFR § 192.945.7 The portions of the special permit inspection area\nthat fall outside of the special permit segments are not required to be included as a\n“covered segment” in accordance with 49 CFR § 192.903.\nii) The special permit inspection area and special permit segments must have integrity\nthreats identified, assessed, and remediated in accordance with these special permit\nconditions and 49 CFR Part 192, Subpart O.\niii) Any high consequence area (HCA) in either a special permit segment or the special\npermit inspection area must be assessed and remediated for threats in accordance\nwith these special permit conditions and 49 CFR Part 192, Subpart O.\niv) All permit conditions that are applicable to special permit segments or to the special\npermit inspection area are applicable to HCAs where the HCA overlaps a special\npermit segment or the special permit inspection area.\nv) All special permit conditions that are applicable to the special permit inspection area\nare also applicable to the special permit segments. The special permit segments must\nmeet the requirements of 49 CFR Part 192, Subpart O, if Subpart O is more stringent\nthan the special permit conditions.\nvi) The special permit inspection area must be able to be assessed using in-line\ninspection (ILI) tools, including tethered or remotely controlled tools, in accordance\nwith 49 CFR §§ 192.150 and 192.493.\nc) Damage Prevention Program: GSPC must incorporate within the special permit\ninspection area the applicable best practices of the Common Ground Alliance8 in its\ndamage prevention (DP) program.\n3) Condition 3 – Corrosion Control\na) Cathodic Protection Test Station Spacing: At least one cathodic protection (CP) pipe-\nto-soil test station must be located within each special permit segment, with a spacing\nnot to exceed ½ mile between CP pipe-to-soil test stations. In cases where obstructions\nor restricted areas prevent such test station placement, the test station must be placed in\n7 GSPC must follow the reporting requirements in Condition 15 – Annual Report, as well as those noted throughout the conditions contained\nherein.\n8 Common Ground Alliance. (March 2020). Best Practices Guide. Retrieved from: https://commongroundalliance.com/BPguide.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 4 of 33\n\n<<<PAGE 5>>>\n\nthe closest practical location, not to exceed a 3,000-foot spacing. CP pipe-to-soil test\nstations must be installed within 12 months of the grant of this special permit.\nb) Annual Monitoring of Test Station Potential Measurements: At least once every\ncalendar year, not to exceed 15 months, GSPC must monitor CP pipe-to-soil test\nstations to meet 49 CFR §§ 192.463 and 192.465 for each special permit segment and\nmust include “on and off” potential measurements. Pipe-to-soil potential measurements\nmust comply with Appendix D – Section I.A. (1) of 49 CFR Part 192 or remediation\ndetailed in paragraph (c) of this condition is required. If hard spots are identified with a\nBrinell Hardness (HB) of 300 HB or greater, CP voltage levels must be maintained\nmore electro-positive than minus 1.2 volts direct current (DC).\nc) Inadequate Cathodic Protection Level Determination:\ni) In instances where inadequate potentials are a result of an electrical short to an\nadjacent foreign structure, a rectifier malfunction, an interruption of power source, or\nan interruption of CP current due to other non-systemic or location-specific causes,\nGSPC must document and repair these instances. A close interval survey (CIS) will\nnot be required.\nii) All other instances must be assessed as detailed in Condition 4 – Close Interval\nSurveys.\nd) Remedial Action Plans:\ni) Within six months of identifying a deficiency, GSPC must develop a remedial action\nplan to restore CP to meet 49 CFR § 192.463. Within two months of the finding,\nGSPC must apply for any necessary environmental permits (Federal or State).\nii) GSPC must complete the remediation and confirm restoration of adequate CP over\nthe entire area where inadequate CP levels were detected within 12 months of the\ndeficiency finding or as soon as practicable after obtaining the necessary permits.\n4) Condition 4 – Close Interval Surveys\na) Survey Methodology and Boundaries:\ni) GSPC must perform an “on and off” current CIS at a maximum five-foot spacing\nalong the entire length of each special permit segment.\nii) GSPC must evaluate each special permit segment in accordance with 49 CFR §\n192.463.\niii) For inadequate CP level determination described in Condition 3(c)(ii), GSPC must\nconduct a CIS in both directions from the test station with an inadequate CP reading\nwith the CIS ending at the adjacent test stations.\nb) Survey Intervals: GSPC must perform the CIS within the following timeframes:\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 5 of 33\n\n<<<PAGE 6>>>\n\ni) Initial assessment must be completed for each newly incorporated and extensions of\nspecial permit segments within 12 months after the grant of the special permit. For a\nspecial permit segment renewal, the CIS may be conducted at the next reassessment\ninterval.9\nii) Reassessments must be conducted every five years not to exceed 66 months. CIS\nassessments within the reassessment interval are not required to be performed in the\nsame year as ILI reassessments.\nc) Survey Remediation and Remedial Action Plans:\ni) If a special permit segment requires the use of 100 millivolt shift criteria10 or the\ninstallation of linear anodes along the special permit segment to meet the CP\nrequirements of 49 CFR § 192.463, it is not eligible to operate with a Class 1 pipe in a\nClass 3 location. GSPC must either: (1) replace the pipe in the special permit\nsegment with Class 3 location standard (design factor) pipe (see 49 CFR §\n192.111(a)); (2) recoat the pipe with non-shielding external coating within 12 months\nof the finding; or (3) lower the MAOP to meet 49 CFR § 192.611.\nii) Within four months of identifying a deficiency, GSPC must develop a remedial action\nplan to restore CP to meet 49 CFR § 192.463. Within two months of the remedial\naction plan being developed, GSPC must apply for any necessary environmental\npermits (Federal or State).\niii) GSPC must complete remediation of each special permit segment and confirm\nrestoration of adequate CP over the entire area where inadequate CP levels were\ndetected within 12 months of the survey or as soon as practicable after obtaining the\nnecessary permits.11\n5) Condition 5 – In-Line Inspection\na) Threat Identification: GSPC must implement data integration and identify integrity\nthreats in the special permit inspection area at least once each calendar year, with\nintervals not to exceed 15 months, in accordance with 49 CFR § 192.917 and Condition\n13(c) – Data Integration. The stress corrosion cracking (SCC) threat assessment for the\nspecial permit segments must be conducted using the current incorporated by reference\n(IBR) edition of the American Society of Mechanical Engineers (ASME) Standard\nB31.8S, “Managing System Integrity of Gas Pipelines” (ASME B31.8S) Appendix A3\n9 A CIS survey conducted in 2020 for a special permit segment that is permit condition compliant would not need to be resurveyed in 2021 but\ncould wait until the next CIS survey reassessment time.\n10 A.W. Peabody, “Peabody’s Control of Pipeline Corrosion,” second edition, “Criteria for Cathodic Protection.” “The 100mV polarization\ncriterion should not be used in areas subject to stray current because 100 mV of polarization may not be sufficient to mitigate corrosion in these\nareas. This criterion also should not be used in areas where the intergranular form of external SCC, also referred to as high-pH or classical SCC,\nis suspected. The potential range for cracking lies between the native potential and -850 mV (CSE) such that application of the 100mV\npolarization criterion may place the potential of the structure in the range for cracking.”\n11 If remediation based upon the findings of the CIS is not practicable within 12 months of the CIS survey, GSPC must submit a schedule and\njustify the delay 60 days prior to the 12-month completion requirement to the Director, PHMSA Central Region. GSPC must receive a “no\nobjection” letter from the Director, PHMSA Central Region, prior to a pipe coating remediation schedule extension.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 6 of 33\n\n<<<PAGE 7>>>\n\nand National Association of Corrosion Engineers (NACE) Standard Practice 0204-2008,\n“Stress Corrosion Cracking Direct Assessment Methodology,” Sections 1.2.1.1 and 1.2.2.\nb) Inline Inspection Methodology: GSPC must conduct instrumented ILI integrity\nassessments in accordance with 49 CFR § 192.493, for the special permit inspection area\nfor all threats identified in accordance with 49 CFR §§ 192.919 and 192.921.\ni) At a minimum, GSPC must conduct ILI assessments for corrosion and denting with\nhigh-resolution (HR) magnetic flux leakage (HR-MFL) and HR deformation tools\nwith deformation-extended sensor arms not limited by pig cups.\nii) For near-neutral or high-pH SCC (cracking threat), GSPC must use an ILI tool12 that\nwill identify tight cracks.13\niii) In the special permit inspection area that has experienced pipe or girth weld leaks or\nruptures due to soil movement, or the threat has been identified, GSPC must run\ninertial measurement unit (IMU) and HR-deformation ILI tools for detection and\nremediation of strains and denting of the pipe body and girth welds from soil or pipe\nmovements that impair pipeline integrity. Remediation must be conducted as\ndetermined by Condition 13(j) – Pipe and Soil Movement.\nc) Inline Inspection Assessment Intervals: GSPC must conduct initial assessments and\nreassessments for the special permit inspection area in accordance with the following:\ni) Initial ILI assessments must be conducted as follows:\n(1) If cracking has been identified as a threat for the extended special permit segment,\nit must be assessed within 18 months of the special permit grant date.\n14\n(2) All identified threats must be assessed within two years of the special permit grant\ndate.\n(3) For newly identified threats, assessments must be completed within two years of\nidentification.\n(4) Previous ILI assessments may be applied if Condition 8 – Anomaly Evaluation\nand Remediation is completed, and the Condition 5(c)(ii) reassessment interval\nis maintained.\nii) Reassessments must be completed in accordance with the shortest interval of the\nfollowing:\n12 The crack ILI tool must be comparable to an electro-magnetic acoustic transducer (EMAT) ILI tool.\n13 GSPC may propose an alternative assessment method for SCC (such as spike hydrostatic testing in accordance with 49 CFR § 192.506) to the\nDirector, PHMSA Central Region, with a copy of the proposal to the Director, PHMSA Engineering and Research Division. GSPC must receive\na “no objection” letter from the Director, PHMSA Central Region, prior to implementing any alternative assessment methods for SCC.\n14 GSPC identified special permit segments 1 and 2 as having FBE coating. Special permit segments 1 and 2 will only require a cracking\nassessment to be completed within 18 months of special permit issuance, should cracking be identified as a threat.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 7 of 33\n\n<<<PAGE 8>>>\n\n(1) 49 CFR § 192.939(a);\n(2) Intervals of five calendar years not to exceed 66 months, if the special permit\nsegment contains any of the following:\n(a) hard spots\n(b) shorted carrier pipe to the casing\n(c) susceptible to SCC\n(d) pipe or soil movement\nAfter conducting two assessments of a threat, one of which must be after the grant\nof this special permit, GSPC may request reassessment intervals up to seven years\nfor that threat assessment. GSPC must submit for and receive a “no objection”\nletter from the Director, PHMSA Central Region, prior to implementing this\nchange.\n(3) The engineering critical assessment (ECA) determined interval, if applicable.\niii) If factors beyond GSPC’s control prevent the completion of an assessment within the\nrequired timeframe or reassessment interval, GSPC must perform the assessment as\nsoon as practicable, and GSPC must submit a letter justifying the delay and provide\nthe anticipated date of completion to the Director, PHMSA Central Region, no later\nthan two months prior to the end the timeframe or interval. GSPC must receive a “no\nobjection” letter from the Director, PHMSA Central Region, for the delay or must\nlower the MAOP of the special permit segment in accordance with 49 CFR §\n192.611.\nd) Remediation: Anomaly assessments must be evaluated and remediated in accordance\nwith Condition 8 – Anomaly Evaluation and Remediation.\n6) Condition 6 – Girth Welds\nConstruction Girth Weld Non-Destructive Test Records: GSPC provided records to\nPHMSA that demonstrate the girth welds in the special permit inspection area were non-\ndestructively tested at the time of construction in accordance with Federal pipeline safety\nregulations at the time the pipelines were constructed in 2013 and 2014. Records review\ndemonstrated that girth welds defects were properly repaired.\n7) Condition 7 – Stress Corrosion Cracking Threat\nGSPC must evaluate the entire length of each special permit inspection area15 for SCC as\nfollows:\n15 GSPC has documented no occurrences of SCC or cracking in the special permit inspection area.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 8 of 33\n\n<<<PAGE 9>>>\n\na) Threat Assessments: GSPC must complete the SCC threat assessment as detailed in\nCondition 5(a) – Threat Identification.\nb) SCC Integrity Assessment: If the threat assessment required under Condition 7(a)\nindicates an extended special permit segment is susceptible to either near-neutral or high-\npH SCC, GSPC must perform an SCC assessment on the extended special permit\nsegment in accordance with Condition 5 – In-Line Inspection.\n16\nc) Examination of Pipe: If the threat of SCC exists in an extended special permit segment\nas determined in Condition 7(a), GSPC must examine the pipe directly for SCC when\nthe coating has been identified as poor during the pipeline examination. The examination\nmust be conducted using an accepted crack detection practice in accordance with 49 CFR\n§ 192.710(c)(4) and (d) when the extended special permit segment is uncovered for any\nreason to comply with the special permit and integrity management activities, not\nincluding One Call activities (49 CFR § 192.614).\nd) Discovery of SCC: If GSPC discovers SCC17 activity by any means within an extended\nspecial permit segment in similar pipe vintage (manufacturer, manufacturing time or age,\ndiameter, wall thickness, grade, and seam type) and pipe coating vintage (in accordance\nwith 49 CFR § 192.917(e)), or an extended special permit segment has had an in-service\nor hydrostatic test SCC failure or leak,18 the special permit segment must be further\nassessed and mitigated, within 18 months of finding SCC and reassessed every five\ncalendar years or less19 based upon the evaluated growth of the SCC, using one of the\nfollowing methods:\ni) Spike Hydrostatic Test Program:20\n(1) GSPC must perform its SCC spike hydrostatic test program in the extended\nspecial permit segment in accordance with 49 CFR § 192.506 and include an\nECA of the results that includes a determination of the reassessment interval; and\n(2) If a joint of pipe in an extended special permit segment leaks or ruptures during a\nhydrostatic test due to SCC, GSPC must replace the pipe joint that does not meet\n49 CFR § 192.611 in the extended special permit segment with new pipe. GSPC\n16 GSPC may propose an alternative assessment method for SCC (such as spike hydrostatic testing in accordance with 49 CFR § 192.506) to the\nDirector, PHMSA Central Region, with a copy of the proposal to the Director, PHMSA Engineering and Research Division. GSPC must receive\na “no objection” letter from the Director, PHMSA Central Region, prior to implementing any alternative assessment methods for SCC.\n17 “SCC” activity shall be defined as greater than 20 percent wall thickness depth and two inches in length.\n18 For all in-service and pressure test failures, GSPC must perform a root cause analysis, including the metallurgical examination of the failed\npipe, to determine if the failure is caused by a systemic or non-systemic issue. GSPC must provide the written results of this root cause analysis to\nthe Director, PHMSA Central Region, within 90 days of the failure and must submit a copy of the root cause analysis to the Director, PHMSA\nEngineering and Research Division.\n19 GSPC has the option to submit a written request to the Director, PHMSA Central Region, with a copy to the Director, PHMSA Engineering\nand Research Division, for extension of the crack assessment interval to seven years, as defined in 49 CFR § 192.939(a), if the ECA shows that\nfive-calendar-year assessments are not required. GSPC must receive a “no objection” letter from the Director, PHMSA Central Region, prior to\nextending the assessment interval to seven calendar years.\n20 GSPC may propose an alternative assessment method for SCC (such as spike hydrostatic testing in accordance with 49 CFR § 192.506) to the\nDirector, PHMSA Central Region, with a copy of the proposal to the Director, PHMSA Engineering and Research Division. GSPC must receive\na “no objection” letter from the Director, PHMSA Central Region, prior to implementing any alternative assessment methods for SCC.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 9 of 33\n\n<<<PAGE 10>>>\n\nmust complete a successful SCC hydrostatic test prior to returning the extended\nspecial permit segment to operational service.\nii) Crack Detection Tool Assessment: GSPC must run an electro-magnetic acoustic\ntransducer (EMAT) ILI tool or other equivalent crack detection ILI tool in the\nextended special permit segment;\niii) MAOP Lowered: GSPC must lower the MAOP of the special permit segment to 60\npercent specified minimum yield strength (SMYS);\niv) Pipe Replacement: GSPC must replace all pipe and comply with 49 CFR § 192.611\nand § 192.619 in the special permit segment; or\nv) Operating Pressure Lowered: GSPC must lower the operating pressure of the\nspecial permit segment to 20 percent below the maximum pressure during the\npreceding 90-day operating interval until GSPC conducts an ECA and remediates the\nspecial permit segment.\ne) SCC Remediation Plan: If GSPC discovers any SCC activity in the extended special\npermit segment, GSPC must submit an SCC remediation plan to the Director, PHMSA\nCentral Region, and send a copy to the Director, PHMSA Engineering and Research\nDivision, no later than 90 days after the finding of SCC.21 The plan must:\ni) Meet Condition 7(d) and include an SCC remediation/repair plan with SCC\ncharacterization and timing; or\nii) Include a technical justification that shows that GSPC is addressing the threat for\nSCC in the special permit segment.\n8) Condition 8 – Anomaly Evaluation and Remediation\na) General: GSPC must use the procedures specified in the special permit conditions, 49\nCFR § 192.712 and 192.933, and Table 3 – Dent Criteria when evaluating\nanomalies. GSPC must account for ILI tool tolerance and corrosion growth rates in\ndetermining scheduled response times and repairs and must document and justify the\nvalues used.\ni) ILI Tool Accuracy: GSPC must demonstrate ILI tool tolerance accuracy for each ILI\ntool run by using calibration excavations and unity plots that demonstrate ILI tool\naccuracy to meet the tool accuracy specification provided by the vendor (typical for\ndepth within +10 percent accuracy for 80 percent of the time). GSPC must\nincorporate ILI tool accuracy by ensuring that each ILI tool service provider\ndetermines the tolerance of each tool and includes that tolerance in determining the\nsize of each anomaly feature reported to GSPC. GSPC must compare previous\nindications to current indications that are significantly different. If a trend is identified\n21 For GSPC to go forward with the technical justification for addressing the SCC threat, GSPC must receive a “no objection” letter from the\nDirector, PHMSA Central Region.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 10 of 33\n\n<<<PAGE 11>>>\n\nwhere the tool has been consistently overcalling or undercalling, the remaining ILI\nfeatures must be re-graded accordingly. ILI tools used must be calibrated as follows:\n(1) General ILI Tool Calibration: ILI tool calibrations must use ILI tool run results\nand anomaly calibrations from the special permit inspection area. ILI calibration\nexcavations may include previously excavated anomalies or recent anomaly\nexcavations with known dimensions that were field measured for length, depth,\nand width, externally re-coated, CP maintained, and documented for ILI\ncalibrations prior to the ILI tool run. A minimum of four calibration excavations\nmust be used for unity plots.22\n(2) EMAT ILI Tool Calibration:\n(a) ILI calibration for EMAT ILI tools must be based upon excavation results of a\nminimum of the two most severe anomalies from a combined review of crack\ndepth and length. If the EMAT tool identifies only one anomaly, the anomaly\nmust be excavated and assessed. GSPC can propose alternative EMAT ILI\ntool evaluation procedures to the Director, PHMSA Central Region, but must\nreceive a “no objection” letter prior to usage of these procedures.\n(b) If the EMAT ILI tool does not identify any cracking anomalies above the\nminimum length and depth criteria for 90 percent probability of detection,\nGSPC must provide the following to the Director, PHMSA Central Region:\n(1) EMAT ILI service provider report with any GSPC provided reporting\nthresholds for cracking;\n(2) Calibration data showing the ILI tool meets API Standard 1163 IBR –\nSection 6 – Qualification of Performance Specifications, Section 7 –\nSystem Operational Verification, and Section 8 – System Results\nValidation, as applicable; and\n(3) Previous in-ditch non-destructive examination records showing no SCC\nfindings.\nOnce the above information has been submitted, GSPC must receive a “no\nobjection” letter from the Director, PHMSA Central Region, that no\nexcavation is required for the EMAT ILI tool calibration.\nii) Unity Plots: The unity plots must show actual anomaly depth versus predicted depth.\n22 Other known and documented pipeline features that are appropriate for the type of ILI tool used may be used as calibration excavations for ILI\ntool calibration with technical documentation of their validity. To use other known and documented pipeline features as calibration excavations\nfor ILI tool calibration, GSPC must complete the following: (1) submit a plan for using known and documented pipeline features such as\ncalibration excavation data, to the Director, PHMSA Central Region, with a copy to the Director, PHMSA Engineering and Research Division.\nThe plan must include at least the following information: a) reason that known and documented pipeline features will be used in place of\nanomalies on the pipelines; b) the pipeline features that will be used for the ILI tool calibration; and c) the technical justification for using the\npipeline features for ILI tool calibration; (2) receive a “no objection” letter from the Director, PHMSA Central Region, prior to performing the\nILI tool calibration using pipeline features; (3) submit a report to the Director, PHMSA Central Region, with a copy to the Director, PHMSA\nEngineering and Research Division, and with the results of the use of pipeline features for the ILI tool calibration that includes technical\ndocumentation establishing the validity of using the pipeline features for the ILI tool calibration.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 11 of 33\n\n<<<PAGE 12>>>\n\niii) ILI Tool Evaluations: ILI tool evaluations for metal loss must use “6t x 6t”23\ninteraction criteria for determining anomaly failure pressures and response timing.\niv) Discovery Date: The discovery date24 must be within 180 days of any ILI tool run\nfor each type of ILI tool (e.g., HR-geometry, HR-deformation, HR-MFL, EMAT,\nIMU, or other equivalent ILI tools).\nb) Remediation schedule for special permit inspection area: GSPC must remediate\nconditions in the special permit inspection area as required by the criteria in 49 CFR §\n192.933(d), and additionally GSPC must schedule the following conditions for\nremediation as described:\ni) GSPC must immediately repair metal loss preferentially affecting a detected pipe\nweld seam, and the predicted failure pressure determined in accordance with 49 CFR\n§ 192.712(d) is less than 1.25 times the MAOP or the metal loss is greater than\n50 percent of pipe wall thickness.25\nii) GSPC must remediate any crack or crack-like anomaly that has a crack depth greater\nthan 40 percent of the pipe wall thickness within two years of discovery that are in\nthe special permit inspection area and area outside of the special permit segments.\niii) GSPC must monitor any crack with depth less than 40 percent of the pipe wall\nthickness during subsequent risk assessments and integrity assessments for any\nchange that may require remediation.\nAppendix A – Table 3 – Dent Criteria summarizes when ECA may be used to evaluate a\ncritical dent. When required to conduct ECA performed in accordance with 49 CFR\n§ 192.712(c):\n1) The ECA process must be repeated following each assessment to ensure\nconformance to the original ECA conclusions.\n2) ECA use for dents with a depth greater than six percent up to 10 percent of the\noutside diameter (OD) requires a “no objection” letter from the Director, PHMSA\nCentral Region.\n3) GSPC must remediate dents and mechanical damage that do not pass the criteria\ndefined in Table 3 – Dent Criteria.\n4) GSPC must submit the dent ECA procedure to the Director, PHMSA Central Region,\nfor a “no objection” letter prior to conducting the anomaly evaluation.26 The\nDirector, PHMSA Central Region, must respond to GSPC’s submittal letter within\n23 6t” means pipe wall thickness times six.\n24 Discovery date is the day, month, and year that GSPC receives the ILI tool run results from the ILI tool service provider.\n25 ASME/ANSI B31G and R-STRENG are not acceptable evaluation methodologies for corrosion in pipe weld seams. Pipe weld seams must be\nevaluated using ECA methodology for cracking anomalies in accordance with 49 CFR § 192.712(d).\n26 A copy of the dent ECA procedure must be sent to the Director, PHMSA Engineering and Research Division.\nPHMSA-2023-0126 – Gulf South Pipeline Company, LLC Special Permit – Class 1 to Class 3 Location – Grayson County, Texas\nPage 12 of 33\n\n<<<PAGE 13>>>\n\n90 days. The Director, PHMSA Central Region, may provide a decision, request for\nadditional information, or notify GSPC of PHMSA’s need for additional time to\nprovide a decision.\nc) Remediation schedule for special permit segments: In addition to the requirements in\nparagraphs (a) and (b) of Condition 8 for the special permit inspection area, GSPC must\nremediate conditions in special permit segments as follows:27\ni) One-year conditions for special permit segments: GSPC must repair the following\nconditions within one year of discovery in special permi","truncated":true,"body_characters":123262}