{"operation":"document","citation":"PHMSA-2025-0011","title":"Natural Gas Pipeline Co. of America — Pipeline Special Permit","source_type":"permit","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-07-28","effective_on":"2025-07-28","summary":"PHMSA-2025-0011, issued 2025-07-28 for Natural Gas Pipeline Co. of America's gas transmission system.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2025-0011.json","markdown":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2025-0011.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2025-0011","source_url":"https://www.regulations.gov/docket/PHMSA-2025-0011","body":"PHMSA pipeline special permit PHMSA-2025-0011. Operator: Natural Gas Pipeline Co. of America. System: Gas Transmission. Issue date: 2025-07-28. Renewal: Extension.\n\n<<<PAGE 1>>>\n\nÿ ÿ ÿ ÿ\nÿ ÿ ÿ\nÿ ÿ ÿ\nÿ ÿ ÿ ÿ\nÿ ÿ ÿ\nÿ\nÿ\nÿÿ ÿ\nÿ\nÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ\nÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ\nÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ\nÿ\nÿ ÿ ÿ ÿ\nÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ\nÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\n\n<<<PAGE 2>>>\n\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ ÿ\nÿ\nÿ ÿ\nÿ ÿ ÿ ÿ ÿ ÿÿ ÿ ÿ ÿ ÿ ÿ ÿ\n\n<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSpecial Permit Analysis and Findings\nClass 1 to Class 3 Location Change\nSpecial Permit Information:\nDocket Number: PHMSA-2025-0011\nRequested By: Natural Gas Pipeline Company of America, LLC\nOperator ID#: 13120\nOriginal Date Requested: August 29, 2024\nOriginal Issuance Date: July 28, 2025\nCode Section(s): 49 CFR §§ 192.611(a) and 192.619(a)\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS),\n1 prepared this document to provide information related to the special permit application\nsubmitted by Natural Gas Pipeline Company of America, LLC (NGPL) in the above-captioned\nproceeding.2 The document discusses the relevant public comments received with respect to the\napplication, presents the engineering and safety analysis of the special permit application, and makes\nfindings regarding whether the requested special permit should be granted and, if so, under what\nconditions.\nPipeline System Affected and Need for Special Permit:\nOn August 29, 2024, NGPL applied for a special permit waiving the requirements in 49 Code of\nFederal Regulations (CFR) §§ 192.611(a) and 192.619(a) for approximately 10.37 miles of the 30-inch\ndiameter Louisiana Line #2 natural gas transmission pipeline located in Liberty, Harris, and\nMontgomery counties, Texas.\nNGPL’s special permit application specifically requested a waiver of 49 CFR § 192.611(a) as\napplicable to 10.37 miles of pipe, comprising 16 pipeline special permit segments (SPSs), where the\nclass location changed from Class 1 to Class 3. Without a special permit, 49 CFR § 192.611(a)\nrequires NGPL to replace the SPSs experiencing a Class 1 to Class 3 location change with higher yield\nstrength or thicker walled pipe or continue to operate at a reduced pipeline maximum allowable\n1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of Transportation’s Pipeline and Hazardous\nMaterials Safety Administration Office of Pipeline Safety.\n2 Natural Gas Pipeline Company of America, LLC is owned by Kinder Morgan, Inc.\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permit Analysis and Findings – TX\nPage 1 of 14\n\n<<<PAGE 2>>>\n\noperating pressure (MAOP).3 As part of its request for a special permit, NGPL sought to restore an\nearlier MAOP and implement enhanced integrity management (IM) practices for the pipeline.\nA description and definition of the SPSs and the pipeline specifications are detailed in Attachment A –\nNGPL Special Permit Segments in Docket No. PHMSA-2025-0011 in the Federal Docket\nManagement System (FDMS) located at Regulations.gov. The special permit inspection area (SPIA)\nextends over the entire segment length between the upstream launcher and downstream receiver of the\nin-line inspection (ILI) tool, contains all the SPSs, and extends 220 yards on each side of the centerline\nof the Louisiana Line #2 pipeline subject to this document.\nPublic Notice:\nOn April 21, 2025, PHMSA posted a notice of this special permit request in the Federal Register with a\nclosing date of May 21, 2025.4 The NGPL special permit application letter, Federal Register notice,\nFinal Environmental Assessment (FEA), Finding of No Significant Impact, and all other pertinent\ndocuments are available for review in Docket No. PHMSA-2025-0011 in the Federal Docket\nManagement System (FDMS) located at www.regulations.gov.\nPHMSA reviewed all public comments received for Docket Number PHMSA-2025-0011 through May\n21, 2025. PHMSA received 17 public comments concerning this special permit request. Specific\ncitations from the Federal pipeline safety regulations, 49 CFR Parts 190 and 192, are referenced\nthroughout PHMSA’s responses to the public comments and are accessible online at eCFR: 49 CFR\nChapter I Subchapter D – Pipeline Safety.\nAnonymous commenters submitted 15 public comment responses, many of which contain dozens of\nquestions and comments. Anonymous commenters frequently asked the same or similar questions.\nThe Pipeline Safety Trust (PST) and the operator, NGPL, also submitted comments.\nSummary of Public Comments and PHMSA Response\nComments fell into the following general topic areas: whether NGPL provided adequate justification\nfor the waiver; public awareness; applying IM principles in lieu of class location design factor\nrequirements; adequacy of the safety analysis and proficiency of staff conducting the analysis; valve\nautomation, emergency response and leak detection methodology; corrosion control; material\ntoughness and hydrostatic pressure testing; public transparency and environmental assessment; incident\nand enforcement history; regulatory coordination and related approvals; and repair methods and\nadequacy of documentation. NGPL’s submission addressed many of the questions and concerns raised\nby commenters and reiterated NGPL’s IM approach to safely operating the pipeline.\nBased on PHMSA’s expertise, consideration of the public comments, and technical information\nprovided by NGPL including in response to the public comments, PHMSA is granting the permit.\n3 Under 49 CFR § 192.611(a), when a pipeline operator determines that a class location increase has occurred, it is required to replace those segments of\npipe with higher strength or thick walled pipe, reduce the operating pressure using the design factors for new pipe under 49 CFR § 192.111 commensurate\nwith the new class location, or use a previous pressure test or conduct a new pressure test to revise the MAOP using the criteria in 49 CFR §192.611(a)\nwhich allows design factors higher than 49 CFR § 192.111 to be used when revising MAOP due to a class location increase. NGPL used the pressure test\noption when it derated the MAOP from 1,100 psig to 936 psig and is unable to use the pressure test option to restore the MAOP to 1,100 psig because it\nexceeds the limiting criteria for determining MAOP under 49 CFR § 192.611(a) and 49 CFR § 192.111.\n4 See “Pipeline Safety: Request for Special Permit; Natural Gas Pipeline Company of America (NGPL),” 90 FR 16766 (Apr. 21, 2025).\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permit Analysis and Findings – TX\nPage 2 of 14\n\n<<<PAGE 3>>>\n\nEach of the general topic areas from the public comments is described further below.\nWaiver Justification PST and several anonymous commenters questioned whether the applicant met\nthe requirement of 49 CFR § 190.341(c)(4) to explain unique circumstances that justify a waiver of the\nspecified regulation.\nPHMSA Response: PHMSA may grant a waiver from compliance with class location change\nrequirements to applicants who demonstrate that their request is not inconsistent with pipeline safety.\n5\nPHMSA issued a policy statement identifying the threshold criteria it considers when granting class\nlocation special permits.\n6 PHMSA has reviewed the documentation submitted by NGPL and\ndetermined the facility meets the threshold criteria for a class location special permit.\nPublic Awareness. Many anonymous commenters and PST asserted that the special permit process\ndoes not provide adequate transparency and asked why the proposed special permit did not require\nNGPL to notify affected members of the public of this special permit request. In its comments, NGPL\nnoted that its routine public awareness activities include mailing brochures to the affected public within\n1,000 feet of the pipeline and to excavators in Liberty and Montgomery Counties in Texas.\nSeveral public commenters also asserted that raising the MAOP increases the risk associated with an\nincident by increasing the potential impact radius (PIR) for the pipeline and incorporating additional\ndwellings. NGPL’s comments clarified that restoring the MAOP from the current 936 psig to 1,100\npsig results in an increase of the PIR from 633 feet to 687 feet, with 79 dwellings being newly\nincorporated into the PIR due the MAOP restoration. In total there will be 889 homes, four businesses,\nand one church located within the 687-foot PIR calculated using the restored MAOP of 1,100 psig.\nPHMSA Response: To ensure public transparency this Federal Register Notice notified the public of\nthe proposed special permit by publishing the application, Draft Environmental Assessment (DEA), and\ndraft special permit conditions in the Federal Register.\n7\nPIR calculates “the radius of a circle within which a potential pipeline failure could have significant\nimpact on people or property.”8 NGPL calculated a PIR of 687 feet using the formula provided in 49\nCFR § 192.903, using an MAOP of 1,100 psig and the pipeline diameter of 30 inches. The increase in\nMAOP will extend the PIR an additional 54 feet and incorporate an additional 79 dwellings. Adhering\nto the IM requirements in 49 CFR Part 192, Subpart O ensures that the dwellings within the PIR are\nadequately protected from the risks associated with the operation of the pipeline.\n49 CFR § 192.616 requires NGPL to administer a Public Awareness program, and to follow American\nPetroleum Institute (API) Recommended Practice (RP) 1162. Operators must notify the public that a\ngas transmission pipeline is operated in the vicinity, educate the public on: the use of a one-call\nnotification system for damage prevention; possible hazards associated with unintended releases from a\ngas pipeline facility; physical indications that such a release may have occurred; steps that should be\n5 See 49 U.S.C. § 60118(c)(1).\n6 See “Pipeline Safety: Development of Class Location Change Waiver Criteria,” 69 FR 38948 (June 29, 2004).\n7 See generally FEDERAL REGISTER 101, OFFICE OF THE FEDERAL REGISTER (2010), https://uploads.federalregister.gov/uploads/2011/01/fr_101.pdf\n(“Publishing a document in the Federal Register provides the public official notice of a document’s existence, specifies the legal authority of the agency to\nissue the document, and gives the document evidentiary status.”).\n8 49 CFR § 192.903.\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permit Analysis and Findings – TX\nPage 3 of 14\n\n<<<PAGE 4>>>\n\ntaken for public safety in the event of a gas pipeline release; and procedures for reporting such an\nevent.9\nNGPL previously operated the pipeline at an MAOP of 1,100 psig, and portions of the pipeline outside\nthe SPIA operate at an MAOP of 1,100 psig. The operator therefore has valuable experience operating\nthe pipeline at that pressure and complying with the applicable regulatory requirements of such a\npressure.\nIntegrity Management Principles in Lieu of Class Location Design Factor Requirements. PST stated\nthe draft special permit appears to only require that NGPL incorporate the SPSs into its Integrity\nManagement Plan (IMP) as Class 1 pipe without incorporating the tougher repair standards necessary\nfor Class 3 locations. PST and several public commenters questioned whether IM adequately\ncompensates for the waiver of critical design factors established for Class 3 locations and allows\noperation at MAOP based on Class 1 design factor. They sought assurances that IM evaluation and\nrepair criteria appropriately reflect the higher risk and consequence of failure in populated areas and\nstated that allowing for increased pressure on outdated infrastructure introduces higher likelihood of\nfailure, gas leaks, explosions, and long-term environmental contamination. Some also questioned if the\nrepair criteria in Subpart O are appropriate for understrength pipe in Class 3 locations.\nIn its comments, NGPL conveyed the applicability of 49 CFR Part 192, Subpart O to the entire 44.9-\nmile SPIA will result in a higher level of safety due to regulatory requirements for identification of\nthreats, assessment of all applicable threats, minimum reassessment intervals, remediation criteria, and\nmanagement of manufacturing and construction threats. NGPL also provided additional information\nabout integrity threats and assessments on the pipeline subject to the special permit. Threats identified\nby NGPL within the SPIA include external corrosion and internal corrosion. The internal and external\ncorrosion threats were comprehensively assessed in 2023 and 2024. In 2023, NGPL completed in-line\ninspection (ILI) of the entire SPIA using high-resolution caliper, inertial measurement unit, and\nmagnetic flux leakage-axial (MFL-A) tools. In 2024, the entire SPIA underwent a hydrostatic pressure\ntest at or above 1.39 times the MAOP. The next integrity assessment is planned for no later than the\nend of 2030.\nPHMSA Response: The requirement in 49 CFR § 192.611 to confirm or revise the MAOP of a\npipeline that experiences a change in class location has been in effect since 1970.\n10 Historically, Part\n192 has required operators to reduce the MAOP of the pipeline when population density increases,\napplying a design factor that varies based on the class location in 49 CFR §§ 192.111 or 192.611(a).\nThese design factors provide a safety margin in more populated areas, but are greater than the design\nfactors applied to new pipe and may be used if an adequate pressure test has been conducted.\nAlternatively, operators may replace the pipe with a higher yield strength or thicker walled pipe to\nensure the hoop stress corresponding to the desired MAOP is commensurate with the new class\nlocation.\nPHMSA’s intent in creating the IM program requirements in Subpart O was to realize a greater safety\nmargin than what was historically provided by 49 CFR § 192.611. Section 192.611 requires the use of\nsafety factors that vary based on population density, but which predate the advent of ILI technology\n9 See 49 CFR § 192.616(d).\n10 See “Transportation of Natural and Other Gas by Pipeline; Minimum Safety Standards,” 35 FR 13248 (Aug. 19, 1970).\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permit Analysis and Findings – TX\nPage 4 of 14\n\n<<<PAGE 5>>>\n\nand requirements to use other assessment methods periodically in high and moderate consequence\nareas. The IM requirements in Part 192 require gas transmission line operators to conduct periodic\nintegrity assessments and stringent evaluation, investigation, and repair based on assessment findings.\nAs described in the documentation, NGPL uses high-resolution caliper, inertial measurement unit, and\nMFL-A tools when conducting ILI, already conducted a hydrostatic pressure test at or above 1.39 times\nMAOP, and will conduct other activities to comprehensively assesses threats like internal and external\ncorrosion.\nTo ensure the pipeline is operated at an equivalent level of safety, special permit Condition 1(b)\nrequires the entire SPIA to be considered a covered segment subject to IM practices. This will increase\nthe pipeline mileage subject to IM requirements from 8.5 miles to 44.9 miles. The pipeline was\nmanufactured and constructed pursuant to the Federal pipeline safety regulations. All records and\ndocumentation provided with the application indicate that the pipeline was manufactured and\nconstructed soundly. PHMSA has determined that the more rigorous practices required by the special\npermit conditions ensure an equivalent level of safety which addresses the elevated risk associated with\noperating the pipeline at a higher pressure in a more populous area.\nProficiency of Safety Analysis. Several public commenters asked about the competency and training\nof PHMSA personnel who process special permits and conduct analyses to ensure public safety\nstandards are maintained by the conditions in this proposed special permit. Public commenters asked\nsimilar questions about whether the competency of NGPL personnel overseeing IM practices and the\noperator’s incident history were considered in PHMSA’s decision. Commenters also asked why\nPHMSA did not require special permit conditions like previously issued special permits, why the\nspecial permit conditions did not require the pipeline to have the same requirements as new pipelines,\nand why special permit conditions did not require NGPL to complete their proposed measures to\nundertake as an alternative to compliance in Attachment B. Commenters further questioned what factor\nof safety was required by Subpart O and whether the proposed special permit alters allowable pipeline\nrepair methods.\nIn its comments, NGPL stated that ILI technology and robust IM practices render pipe replacement\nsolely due to population growth near a pipeline unnecessary and inefficient. NGPL further stated that\nits IMP is specifically designed to proactively identify and mitigate potential threats to pipeline\nintegrity. NGPL explained that the proposed special permit results in an additional 34.5 miles of\npipeline treated as a high consequence area (HCA) in accordance with 49 CFR Part 192, Subpart O,\nwhich provides a higher level of safety across a greater length of pipeline as compared to the alternative\nof pipeline replacement.\nPHMSA Response: PHMSA engineers review and verify the special permit application packages to\nensure the documentation meets the requirements of 49 CFR § 190.341. The engineers engage with\nregion personnel who have additional experience with the operator and the segments under\nconsideration, and who ultimately inspect and enforce special permit conditions. PHMSA engineers\nalso provide their analysis and recommendations, including any recommended special permit\nconditions, to the Associate Administrator for Pipeline Safety, who is authorized to grant or deny the\nspecial permit application. The records reviewed by PHMSA in processing a special permit application\nsubstantiate the material characteristics and integrity of the facility subject to the special permit\napplication.\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permit Analysis and Findings – TX\nPage 5 of 14\n\n<<<PAGE 6>>>\n\nThe shorter and more simplified format of the special permit document is attributable to PHMSA’s\nefforts to increase the comprehensibility and legibility of regulatory documents by eliminating\nredundant requirements and referencing code citations rather than restating already existing regulatory\nrequirements. Some previously issued special permits listed conditions that were already required by\nthe regulations. To meet the requirements of 49 CFR § 190.341(c)(5), NGPL provided descriptions of\nproposed measures to undertake as an alternative to compliance in Attachment B.11\nPHMSA evaluates proposed measures, but ultimately determines which conditions will ensure an\nequivalent level of safety. PHMSA considered whether inclusion of additional conditions may be\nwarranted based on the information provided, but determined only those conditions included are\nnecessary to ensure that the special permit achieves the level of safety required by law. The absence of\nadditive requirements in this special permit compared to previously issued class location special\npermits is also consistent with PHMSA’s efforts to reduce regulatory burdens on the use of domestic\nenergy resources, as directed by Executive Order 14154,\n12 and PHMSA’s commitment13 to modernize\nhow pipeline risk is addressed through use of IM principles and technologically advanced tools to\nassess pipeline integrity and maintain pipeline safety standards.\nThe Federal pipeline safety regulations require operators to maintain detailed compliance records,\nincluding identification of the employees responsible for conducting the test or assessment, training and\nqualifications of employees and contractors who conduct, not only assessments, but all activities\nperformed on a pipeline facility that affect the operation or integrity of the pipeline. See 49 CFR\n192.807. PHMSA believes it is paramount to pipeline safety to ensure properly qualified and\nexperienced individuals with appropriate knowledge of pipeline facilities are entrusted to complete\ninspections, assessments, and evaluations of integrity to ensure pipelines are operated safely. Stringent\nrecordkeeping requirements ensure PHMSA is able to perform detailed inspections and investigations\nas detailed in 49 CFR § 190.203.\nValve Automation, Emergency Response, and Leak Detection. Commenters requested mandatory\nremotely controlled valves (RCV) with 30-minute or less shut-in times, enhanced rupture detection\nstandards, continuous leak detection with additional measures to ensure public transparency, and\ncommunity evacuation drills within the PIR. PST advocated for explicit permit conditions ensuring\nthat RCVs shut in pipeline segments within 30 minutes, referencing prior special permits and National\nTransportation Safety Board recommendations that resulted from incident investigations. They stressed\nthat such requirements reduce risk significantly in populated areas.\nPHMSA Response: Although requirements for rupture-mitigation valve (RMV) installation and\nreduced valve spacing required by PHMSA’s recently issued Final Rule14 are primarily applicable to\npipelines constructed after the rule’s effective date, NGPL indicated to PHMSA that all the mainline\nand lateral isolation valves on the system meet the valve automation methodology15 required by the\nFinal Rule and which PHMSA has historically required as a condition in similar special permits. In\naddition, the Final Rule incorporated more stringent requirements that are applicable to all regulated\n11 See NGPL, “Attachment B,” Docket ID PHMSA-2025-0011-0001 (Apr. 21, 2025).\n12 See “Unleashing American Energy,” 90 FR 8353 (Jan. 29, 2025).\n13 See “Pipeline Safety: Pipeline Integrity Management in High Consequence Areas (Gas Transmission Pipelines),” 68 FR 69778 (Dec. 15, 2003); “Pipeline\nSafety: Development of Class Location Change Waiver Criteria,” 69 FR 38948 (June 29, 2004).\n14 See “Pipeline Safety: Requirement of Valve Installation and Minimum Rupture Detection Standards,” 87 FR 20940 (Apr. 8, 2022)\n15 See PHMSA, “Draft Special Permit—Appendix A,” Docket ID PHMSA-2025-0011-0004 at tbl. A3 (Apr. 21, 2025).\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permit Analysis and Findings – TX\nPage 6 of 14\n\n<<<PAGE 7>>>\n\ngas transmission facilities. 49 CFR §§ 192.615 and 192.635 require enhanced emergency response\nplans to ensure quicker responses to indications of emergency and more rapid identification and\nnotification of potential ruptures.\n16 The requirements from that rule within 49 CFR §§ 192.615,\n192.617, and 192.635 are applicable to all natural gas transmission pipelines, and the requirements\nfrom 49 CFR §§ 192.745 and 192.935 are applicable to all RMVs. PHMSA appreciates the assertion\nthat leak detection reduces risk. The Federal pipeline safety regulations include many provisions for\nleak detection including through IM requirements of Subpart O. NGPL is required to comply with leak\ndetection requirements for the entirety of its pipeline system—including the SPSs.\nCorrosion Control. Public comments questioned the effectiveness of fusion bonded epoxy (FBE)\nexternal coating dating from the early phases of its use in the 1970s and the adequacy of cathodic\nprotection (CP) test stations given the age and vintage coating practices on large-diameter pipe.\nCommenters raised concerns about coating disbondment, chloride contamination, and their potential\nconnection to pipe failures. Suggestions were made to require additional CP test sites, enhanced\ncorrosion inspection, and defined remediation timeframes. PST challenged the claim that affected\npipeline segments have FBE coatings, noting limited commercial adoption of FBE in the 1970s and\npotential degradation over 50 years. PST recommended mandatory inspection and remediation of\ncoating defects to ensure external corrosion control is consistent with current safety standards. NGPL\nreported routine inspections including close interval surveys (CIS) that demonstrate the pipeline’s\ncoating system effectiveness, with corrosion control practices that do not rely solely on linear anodes or\nthe 100 mV polarization criterion. They highlighted recent pipeline examination reports confirming\nbond integrity and coating condition.\nPHMSA Response: PHMSA reviewed pipeline examination reports and CIS data confirming that the\npipeline generally possesses solidly bonded FBE coatings supplemented by coal tar coatings on girth\nwelds, consistent with then-current industry practices. Proper coating installation practices are\nparamount to ensure pipeline coating will be effective in protecting pipelines from corrosion. Section\n192.461, which requires sufficient coating installation practices, including adequate surface preparation\nand protection from coating damage during construction or maintenance activities, was codified at the\ntime of the subject pipeline’s construction between 1974 and 1978.\nNGPL’s corrosion control program complies with Part 192 Subpart I requirements mandating adequate\ncathodic protection (CP) levels, frequent testing, and prompt remediation of deficiencies. NGPL has\nalso performed CISs on the pipeline subject to this special permit. These measures, in addition to\nexternal corrosion data collected from ILI, contribute to the operator’s knowledge about the condition\nof the coating on the pipeline. The operator’s established practices provide ongoing surveillance of\ncoating integrity and corrosion threats at an enhanced scope and frequency. PHMSA found existing CP\ntest site locations and monitoring frequency satisfactory to support integrity assurance for this pipeline\nsegment.\nAdditional conditions were not included in the special permit because Part 192 Subpart I already\nrequires operators to verify through frequent inspection and testing that CP is adequate. For example,\nCP power sources and protective bonds are required to be inspected every 2½ months. Section 192.469\nrequires pipelines to have sufficient test stations to determine the adequacy of cathodic protection.\nAnnual testing is required to ensure CP meets specified criteria. When an annual CP survey indicates\ninadequate systemic CP, the operator must conduct an interrupted current CIS as required by 49 CFR\n16 See Valve Rule Fact Sheet, PHMSA (Aug. 12, 2024), https://www.phmsa.dot.gov/rulemaking-implementation/valve-rule/valve-rule-fact-sheet.\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permit Analysis and Findings – TX\nPage 7 of 14\n\n<<<PAGE 8>>>\n\n§ 192.465(f) and complete remedial action within 15 months of discovery. The implementation of IM\nfor the entire SPIA will incorporate additional robust requirements to maintain integrity and pipeline\nsafety.\nMaterial Toughness, and Hydrostatic Pressure Testing. PST and anonymous public commenters\nexpressed concerns with the absence of Charpy impact toughness data from construction records, given\npipe manufacture occurred between 1974 and 1978. Several commenters requested details about\npressure test failures linked to seam weld toe cracks and how those defects and pipe toughness are\naddressed. Commenters asked why the final pressure test was 1.39 times MAOP rather than the 1.5\ntimes MAOP generally required for Class 3 pipelines, and whether the special permit requires periodic\nreassessment using crack-detection ILIs. PST urged PHMSA to require verification of toughness and\ncomprehensive evaluations of crack related defects on non-failed areas, and questioned NGPL’s\nmanufacturing defect rejection rates and ILI assessment for cracking threats.\nIn its comments, NGPL clarified that the two 2024 pressure test failures occurred near 100-percent of\nspecified minimum yield strength (SMYS), leading to removal and replacement of defective pipe\nseams. Metallurgical analysis confirmed these were longstanding manufacturing imperfections that had\nremained stable for approximately 50 years, and that the successful 2024 pressure test reached 1.39\ntimes MAOP, or around 1,539 psig. NGPL stated the test pressure exceeding 1.25 times MAOP\nstabilizes any latent manufacturing imperfections in accordance with § 192.917(e)(3). NGPL cited an\nadjacent vintage and manufacturer pipeline operating safely at 1,100 psig as evidence of defect\nstabilization.\nPHMSA Response: NGPL submitted records documenting material characteristics for pipe from the\noriginal pipeline construction. Those records did not include test results documenting Charpy impact\ntoughness properties or repair and rejection rates from the manufacturer. In the absence of known pipe\nmaterial toughness, the Federal pipeline safety regulations require operators to use conservative\nminimum values or obtain the data during pipeline cutouts or using nondestructive testing, to ensure\naccurate or conservative toughness values are used when calculating predicted failure pressure and\ncritical strain level.\nThe pipeline subject to this special permit was manufactured using the double submerged arc welding\n(DSAW) process to form its longitudinal seams. PHMSA reviewed metallurgical analysis reports from\nthe 2024 pressure test failures which ascertained the toughness of the pipe body, heat affected zone, and\nlongitudinal seam weld and determined that the subject pipe does not have a similar risk profile to\nvintage pipe. Those test results demonstrated the pipe has adequate Charpy toughness values by\nmodern standards in all but one case, which still demonstrated toughness that far exceeds the\nconservative minimum values provided in the Federal pipeline safety regulations. Those values, along\nwith other known pipe characteristics, material testing records, positive material identification reports,\nconsideration of the operating and maintenance history, and results of both the pressure test and ILI\nassessments indicated the pipeline’s integrity and safety in operating at the restored MAOP of 1,100\npsig. The operator submitted documentation that demonstrated traceable, verifiable, and complete\nmaterial records for all SPSs subject to the special permit, including material test reports for all the pipe\nwhich confirms the pipe attributes, the chemical properties, and strength test results.\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permit Analysis and Findings – TX\nPage 8 of 14\n\n<<<PAGE 9>>>\n\nPressure tests are a reliable integrity assessment method for manufacturing defect threats, including\ndefective pipe seams.\n17 Testing a pipeline above the operating pressure eliminates any defect that\nthreatens a pipeline’s integrity, through failure, and when successful, demonstrates the absence of\ndefects which might cause it to fail in service. The adequacy of pressure tests to ensure safe pipeline\noperations is demonstrated by decades of empirical evidence as well as a multitude of studies. PHMSA\nFAQs18 detail the reliability of Subpart J pressure tests as an assessment method for manufacturing\ndefects, including seam and construction defects, caused by mechanical damage. Section 192.917(e)(3)\nallows an operator to consider manufacturing defects stable if the pipeline has been subjected to a\npressure test at least 1.25 times MAOP. The successful pressure test up to 1.39 times MAOP on this\npipeline in 2024 following repairs at failure locations, among several other factors, demonstrated the\npipe’s integrity and ability to operate safely at its restored MAOP.\nCondition 1(b) of the special permit requires the operator to apply IM to the entire pipeline subject to\nthe SPSs—this includes a requirement to identify and evaluate all potential threats, including cracking\nthreats, as 49 CFR § 192.917(e)(6) requires the operator to address cracks or crack-like defects.\nSubpart O requires pipeline operators to evaluate all threats on a pipeline, including threats considered\nstable. Moreover, 49 CFR § 192.712(d)(3) requires operators that do not have ILI data to assess cracks\nby analyzing potential crack defects that could have survived a pressure test.\nPublic Transparency and Environmental Assessment. PST and anonymous public commenters\ncriticized the absence of pipeline location maps and detailed demographic information in the\nEnvironmental Assessment (EA), asserting these omissions limit stakeholders’ ability to evaluate risks\nadequately. PST also questioned the EA’s portrayal of the affected area as largely undeveloped forest,\nminimizing the extent of nearby population and development. Some anonymous commenters thought\nindependent third-party verification of pipeline safety analyses and public release of inspection data in\nsearchable databases would improve public transparency.\nPHMSA Response: In addition to posting notices of proposed special permits in the Federal Register\nfor public review and comment, PHMSA also lists information about noticed proposed special permits\non its website.\n19 Section 190.341(c)(2)(i) requires special permit applications to include a detailed\ndescription of the pipeline facilities, including the beginning and ending points of the pipeline mileage\nto be covered and the counties and States in which it is located. Section 191.29 requires each operator\nof a gas transmission pipeline to provide geospatial data to PHMSA annually to be displayed on a\npublic website, the National Pipeline Mapping System (NPMS).\n20 The online map resource and\ncoordinates21 were also provided to ensure the public could access pipeline maps in their preferred level\nof detail.\nPHMSA’s former practice of attaching maps required significant effort to ensure adequate scaling,\nproofreading, redrafting, document consolidation, and transfer of large file sizes. While PHMSA\n17 Section 192.937(c)(2) states that pressure testing is an appropriate assessment method for the following threats: Internal corrosion; external corrosion\nand other environmentally assisted corrosion mechanisms; manufacturing and related defects threats, including defective pipe and pipe seams; stress\ncorrosion cracking; selective seam weld corrosion; dents; and other forms of mechanical damage.\n18 See PHMSA, “Gas Transmission Integrity Management FAQs,\n” FAQ-219 and FAQ-220 (Jan. 15, 2021), https://www.phmsa.dot.gov/pipeline/gas-\ntransmission-integrity-management/gas-transmission-integrity-management-faqs.\n19 See Pipeline Special Permits and State Waivers Overview, PHMSA (June 30, 2025), https://www.phmsa.dot.gov/pipeline/special-permits-state-\nwaivers/special-permits-and-state-waivers-overview.\n20 See NAT’L PIPELINE MAPPING SYS., https://www.npms.phmsa.dot.gov (last visited July 25, 2025).\n21 See NGPL, “Attachment A,” Docket ID PHMSA-2025-0011-0002 (Apr. 21, 2025).\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permit Analysis and Findings – TX\nPage 9 of 14\n\n<<<PAGE 10>>>\n\nbelieves substantial effort is worthwhile to provide transparency to the public regarding pipeline safety\ntopics, PHMSA also believes the public is best served when the Agency allocates its finite resources to\nthe review and analysis tasks associated with special permit applications. NPMS is an informative and\nuseful tool that can provide a more detailed understanding of the subject facility, as well as the national\npipeline network.\nThe NPMS has many helpful resources to aid the public in learning to use the NPMS. The Public Map\nViewer22 contains an instructional video located under the Help menu which demonstrates the viewer’s\nfunctionality and should answer most user questions about how to use the viewer. The instructional\nvideo is also accessible on YouTube.23 Contact information for pipeline operators may be found via\nthe Find Who’s Operating in Your Area tool. This tool displays the contact information for all pipeline\noperators in the NPMS data for the user’s selected State, county, or zip code. Dwelling count per each\nSPS is provided in Attachment A – NGPL Special Permit Segments, and acknowledgement of the\nincreased population density within class 3 areas and discussion of the pipeline safety impacts on the\npopulation were discussed and carefully considered. In addition to consideration of public safety, the\nEA acknowledged the terrain to ensure adequate assessment of potential environmental impacts.\nIncident and Enforcement History. Several commenters requested insight into NGPL’s incident\nhistory over the past five years and any enforcement actions taken by PHMSA. They questioned\nwhether enforcement and past incidents informed the permit approval and requested disclosure of\nNGPL’s recent significant incident history and PHMSA enforcement actions to assess pipeline safety\nand reliability. Public commenters also asked several questions about how PHMSA can ensure\naccountability of pipeline operators through enforcement of Federal pipeline safety regulations and\nspecial permit conditions.\nPHMSA Response: The operator’s incident and enforcement histories were reviewed by PHMSA and\nconsidered in evaluation of this special permit application. In the special permit process, consideration\nof whether an operator’s procedures are adequate is made through a review of the operator’s\nenforcement history. Previous findings of inadequate procedures are indicated by formerly issued\nNotices of Amendment and enforcement history is considered by PHMSA in making a determination\non issuance of special permits. An overview of reported incidents and enforcement actions are\ndiscussed within the Analysis section of this special permit and includes references to online viewing of\nPHMSA’s incident and enforcement history for NGPL. Additionally, PHMSA’s website24 is a\ncomprehensive resource for members of the public to learn more about enforcement activity. Any\nmember of the public may request additional information from PHMSA under the Freedom of\nInformation Act.\n25\nPipeline operators are responsible for compliance with the pipeline safety regulations and the orders\nissued by PHMSA, including special permits. The enforcement actions that PHMSA can take if an\noperator is found to be in violation of the Federal pipeline safety regulations or the conditions of this\n22 See Learn About the Public Map Viewer, NAT’L PIPELINE MAPPING SYS., https://www.npms.phmsa.dot.gov/AboutPublicViewer.aspx.\n23 See PHMSA, How to Locate Pipelines in Your Area with the National Pipeline Mapping System (NPMS), YOUTUBE (Jan. 5, 2017),\nhttps://youtu.be/OnZFGVwae4I\n24 See Enforcement Data, PHMSA, https://primis.phmsa.dot.gov/enforcement-data/ (last visited July 25, 2025).\n25 See FOIA Overview, PHMSA (Oct. 6, 2023), https://www.phmsa.dot.gov/foia.\n2025-0011 – Natural Gas Pipeline Company of America, LLC Special Permi","truncated":true,"body_characters":55131}