# Sable Offshore Corp — Pipeline Special Permit - **operation:** document - **citation:** PHMSA-2026-0464 - **title:** Sable Offshore Corp — Pipeline Special Permit - **source type:** permit - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** current - **official:** true - **published on:** 2026-06-25 - **effective on:** 2026-06-25 - **summary:** PHMSA-2026-0464, issued 2026-06-25 for Sable Offshore Corp's hazardous liquid system. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2026-0464.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2026-0464.md - **app url:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2026-0464 - **source url:** https://www.regulations.gov/docket/PHMSA-2026-0464 **body:** PHMSA pipeline special permit PHMSA-2026-0464. Operator: Sable Offshore Corp. System: Hazardous Liquid. Issue date: 2026-06-25. <<>> U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION SPECIAL PERMIT Special Permit Information: Docket Number: PHMSA-2026-0464 Requested By: Sable Offshore Corp. Operator ID #: 40881 Original Date Requested: January 22, 2026 Original Issuance Date: June 25, 2026 Effective Dates: June 25, 2026, to June 25, 2036 Code Section(s): 49 CFR § 195.452(h)(4)(iii)(H) Grant of Special Permit: By this order, subject to the terms and conditions set forth below, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS)1 grants this special permit to Sable Offshore Corp. (Sable). This special permit applies to two segments of the Santa Ynez Pipeline System (SYPS), an interstate hazardous liquid pipeline facility that transports crude oil produced on the Outer Continental Shelf (OCS) through an onshore processing facility located in Santa Barbara County, California, to a terminal located in Kern County, California. The two segments that are subject to the special permit are known as Lines CA-324 and CA-325 (CA-325A and CA-325B). The regulation waived is 49 Code of Federal Regulations (CFR) § 195.452(h)(4)(iii)(H), which requires hazardous liquid pipeline operators to remediate certain longitudinal seam weld corrosion within 180 days of discovery. I. Purpose and Need: Lines CA-324 and CA-325 were originally installed with polyurethane foam and an overlying polyethylene wrap tape to provide thermal insulation. The use of these materials is known to cause shielding, a condition that interferes with the proper functioning of cathodic protection and increases the risk of corrosion in pipeline systems. Sable requested a special permit authorizing an alternative approach for managing the increased corrosion risk on Lines CA-324 and CA-325 1 Throughout this special permit, the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety. <<>> to implement the terms of a Consent Decree entered in Civil Action No. 2:20-CV-02415 by the U.S. District Court for the Central District of California. The Consent Decree includes provisions to address a rupture that occurred on the SYPS in Santa Barbara County, California, in May 2015. As relevant here, the Consent Decree required the prior operator of the SYPS to obtain a waiver before restarting Lines CA-324 and CA-325 to ensure that effective measures were in place to mitigate the risk of corrosion. The Consent Decree also incorporated the outstanding requirements from a corrective action order that PHMSA issued following the rupture (CPF No. 5-2015-5011H). The CAO required the restart plan for Lines CA-324 and CA-325 to include a long-term plan for managing corrosion under insulation (CUI). The Consent Decree provided multiple options for satisfying this requirement. One of the options was obtaining a special permit that requires: 1) accelerated reassessments; 2) use of appropriate, complementary assessment tools for all threats, including stress corrosion cracking; 3) coordination of data from the appropriate alternating in-line inspection (ILI) technologies; 4) more stringent repair criteria targeted at CUI; and 5) advanced data analysis techniques to account for the potential growth of CUI, including interaction criteria for anomaly assessment.2 The conditions in this special permit address the requirements in the Consent Decree. Specifically, the conditions require substantially more frequent integrity assessments as compared to the pipeline safety regulations at 49 CFR Part 195. Each integrity assessment must use threat-appropriate tools (including for wall loss anomalies from external and internal-based corrosion and for detecting crack anomalies from conditions such as stress corrosion cracking), The conditions also establish more stringent anomaly repair criteria as compared to Part 195; require enhanced data integration from integrity assessments to continuously gauge assessment performance through comparison with in-the-field and other comparative benchmarks; and require the performance of a corrosion growth rate analysis to better inform the analysis of integrity assessment data. PHMSA notes that it previously issued an emergency special permit to Sable for Lines CA-324 and CA-325 imposing substantially similar conditions on December 23, 2025 (Docket no. PHMSA-2025-1502),3 and that the California Office of State Fire Marshal (OSFM) issued waivers to Sable containing essentially the same conditions on December 17, 2024.4 PHMSA further notes that the jurisdictional status of Lines CA-324 and CA-325 has changed since the District Court entered the Consent Decree. At that time, CA-324 and CA-325 were 2 See also PHMSA ADB-2016-04, 81 Fed. Reg. 40398, 40400 (June 21, 2016). 3 The emergency special permit included several conditions which Sable indicated it had completed prior to the effective date of the emergency special permit but that it had not provided to PHMSA for review. Sable provided additional records to PHMSA following the issuance of the emergency special permit, rendering those conditions no longer necessary for inclusion in this special permit. In addition, on February 13, 2026, Sable requested that its application be considered in accordance with the Notice of Limited Enforcement Discretion and Statement of Policy issued by PHMSA on January 12, 2026. As part of that request, Sable agreed to follow the terms and conditions in the emergency special permit until PHMSA issued its decision on this application. 4 OSFM submitted a comment on the docket for this special permit request stating that the proposed special permit conditions removed the state waiver requirement that Sable account for tool tolerance in its evaluation of corrosion anomalies needing remediation prior to restart of the SYPS. As discussed in the SPAF, that requirement was not clearly stated in the state waiver itself, and PHMSA determined that the margin of error afforded by that tool tolerance allowance was not necessary for the conditions to be consistent with pipeline safety. <<>> considered part of an intrastate hazardous liquid pipeline facility subject to regulation by OSFM.5 However, as discussed more fully in the Jurisdictional Determination, PHMSA has since determined that Lines CA-324 and CA-325 are part of an interstate hazardous liquid pipeline facility. Accordingly, PHMSA has the sole and exclusive authority to issue the special permit for Lines CA-324 and CA-325 that Sable has requested in this proceeding.6 II. Special Permit Segments This permit pertains to the specified special permit segments defined in this section. Special Permit Segments: Special Permit Segment Name Location Mileage California County or Counties CA-324 Las Flores Canyon Processing Facility to Gaviota Pump Station 10.86 Santa Barbara CA-325A Gaviota Pump Station to Sisquoc Pump Station 38.72 Santa Barbara CA-325B Sisquoc Pump Station to Pentland Station 74.84 Santa Barbara; San Luis Obispo; Kern III. Conditions PHMSA grants this special permit subject to Sable implementing each of the following conditions. These conditions must be implemented and complied with in addition to all applicable requirements of 49 CFR Part 195 except for compliance with requirements in 49 CFR § 195.452(h)(4)(iii)(H). General Conditions: 1) 2) 3) The special permit segments may only be used to transport crude oil. Prior to transporting crude oil in the special permit segments, Sable must develop and implement procedures for the conditions and requirements described in the special permit. Sable shall not exceed maximum operating pressure (MOP) limits for the special permit segments, as follows: a) The MOP of Line CA-324 cannot exceed 1,003 pounds per square inch gauge (psig). b) The MOP of Line CA-325A (the segment of Line CA-325 between Gaviota and Sisquoc stations) cannot exceed 1,000 psig. 5 See 49 U.S.C. §§ 60101(a)(10) (defining “intrastate hazardous liquid pipeline facility”); 60105 (establishing requirements for State pipeline safety program certifications). 6 49 U.S.C. §§ 60104(c), 60118(c). <<>> 4) 5) 6) 7) 8) c) The MOP of Line CA-325B cannot exceed 1,292 psig between Sisquoc and Check Valve 37, and 1,170 psig between Check Valve 37 and Pentland Station. Sable shall not exceed maximum operating temperature limits for crude oil transported in the special permit segments, as follows: a) The maximum operating temperature of the crude oil transported in Line CA-324 must not exceed 140 degrees Fahrenheit for more than 12 consecutive hours. b) The maximum operating temperature of the crude oil transported in Line CA-325A (the segment of Line CA-325 between Gaviota and Sisquoc stations) must not exceed 125 for more than 12 consecutive hours. Temperature transmitters must be installed on Line CA-325 at Gaviota station to monitor the temperature of Line CA-325A. c) The maximum operating temperature of the crude oil transported in Line CA-325B (the segment of Line CA-325 between Sisquoc and Pentland stations) must not exceed 110 for more than 12 consecutive hours. Temperature transmitters must be installed on Line CA-325 at Sisquoc station to monitor the temperature of Line CA-325B. This special permit does not relieve Sable from complying with applicable requirements under 49 CFR Part 195, other than those waived in this special permit. This special permit does not relieve Sable from any applicable requirements contained in the Consent Decree (United States District Court Central District of California Civil Action No. 2:20-cv-02415). ILIs performed pursuant to this special permit must include a) Use of a tool that is at least capable of reliably detecting and identifying cluster corrosion and general corrosion, defined as follows: i. Cluster means two or more adjacent metal loss features in the wall of the pipe or weld that may interact based on interaction criteria. ii. General corrosion means uniform or gradually varying loss of wall thickness over an area. b) Use of a tool that is at least capable of reliably detecting and sizing corrosion at a 90 percent probability of detection (POD) and probability of identification (POI). c) Use of a tool that is at least capable of reliably detecting and sizing crack or crack-like anomalies at a 90 percent POD and POI. Prior to placing CA-324 in operation, Sable must perform fracture toughness tests on the existing 24-inch pipe from CA-324 in accordance with ASTM E1820-23B Standard Test Method for Measurement of Fracture Toughness. All test specimens must be from the predominant existing 24-inch pipe, specifically API 5L X65 HF-ERW pipe with a nominal thickness of 0.344 inches that was manufactured by Nippon Steel Corp. in the 1980s. At least three separate tests must be performed to obtain the fracture toughness values of the pipe body, heat affected zone (HAZ),7 and the HF-ERW long seam weld on the pipe to represent the fracture toughness of CA-324 (i.e., three samples for pipe body, 7 The HAZ, as used in this special permit, is defined as a 1-inch-wide area on either side of the longitudinal weld seam. <<>> 9) 10) 11) 12) three samples for HAZ, and three samples for the HF-ERW long seam weld). The lowest fracture toughness value must be applied to conditions 11, 16, 17, and 21. Sable may use pipe samples taken opportunistically during ongoing maintenance and repair efforts on Line CA-324.8 Prior to placing Line CA-325 (including CA-325A and CA-325B) in operation, Sable must perform fracture toughness tests on the existing 30-inch pipe from CA-325A/B in accordance with ASTM E1820-23B Standard Test Method for Measurement of Fracture Toughness. All test specimens must be from both of the two following predominant existing 30-inch pipe specifications: a) API 5L X70 pipe with a nominal thickness of 0.281 inches that was manufactured by the various pipe mills in the 1980s. b) API 5L X65 pipe with a nominal thickness of 0.344 inches that was manufactured by the various pipe mills in the 1980s. At least three separate tests must be performed from each pipe mill, for both of the two pipe specifications listed above, to obtain the fracture toughness values of the pipe body, HAZ, and the double submerged arc weld (DSAW) long seam weld on the pipe to represent the fracture toughness of CA-325A/B (i.e., three samples for pipe body, three samples for HAZ, and three samples for the DSAW long seam weld). The lowest fracture toughness value must be applied to conditions 11, 16, 17, and 21. Sable may use pipe samples taken opportunistically during ongoing maintenance and repair efforts on Line CA-325A/B.9 All existing immediate and 180-day repair conditions must be evaluated and remediated pursuant to the Consent Decree repair criteria prior to restarting CA-324 and CA- 325A/B.10 Upon restart Sable must utilize ultrasonic thickness wall measurement (UTWM) and ultrasonic shear wave crack detection (USCD) ILI tools within 7 days of achieving initial steady state operation in accordance with an ILI survey schedule approved by PHMSA. Sable must use the UTWM and USCD ILI results to identify, to evaluate, and to remediate any immediate and 180-day repair conditions listed in this special permit. Remaining strength of pipe calculation for all metal loss anomalies must be in accordance with the Modified B31G method as described in ASME B31G Manual for Determining the Remaining Strength of Corroded Pipelines. If ASME B31G 2012 Edition is used, then it must comply with the conditions in accordance with section 1.2 and exclusions in accordance with section 1.3 of ASME B31G 2012 Edition. However, if the metal loss anomaly intersects or is within 1 inch (circumferentially) of the longitudinal seam weld, Sable must also calculate the predicted failure pressure of the anomaly by using the crack-like flaw evaluation method ASME FFS-1/API 579-1. Sable must use cleaning pigs at regular intervals not to exceed a biweekly basis to 8 Sable indicated in its application that it has already completed all of the testing required in this condition. Sable has submitted fracture toughness results to PHMSA, and PHMSA will review the results and confirm the completion of required testing. 9 Sable indicated in its application that it has already completed all of the testing required in this condition. Sable has submitted fracture toughness results to PHMSA, and PHMSA will review the results and confirm the completion of required testing. 10 Sable indicated in its application that it has already completed the repairs required in this sentence. Sable must submit all relevant records to PHMSA. <<>> maintain adequate cleanliness on the internal pipe wall of the special permit segments. 13) Pressure testing:11 a) Prior to placing CA-324 in operation, Sable must conduct a spike hydrostatic pressure test of CA-324 at a minimum pressure that is at least 1.5 times the maximum operating pressure (MOP) or 100 percent specified minimum yield strength for a minimum of 15 minutes after the spike test pressure is stabilized. Sable must field evaluate and remediate the following anomalies before performing the spike hydrostatic test on CA-324: b) c) d) e) i. ii. All metal loss anomalies that have an ILI reported depth of 40 percent and greater wall loss. All anomalies that have a predicted failure pressure less than or equal to 1.6 times MOP. Immediately following the spike hydrostatic pressure test specified in Condition 13(a), Sable must conduct an 8-hour hydrostatic pressure test of CA-324 at a minimum of 1.25 times the MOP. Prior to placing Line 325A (segment of Line 325 between Gaviota and Sisquoc stations) in operation, Sable must conduct a spike hydrostatic pressure test of CA-325A at a minimum pressure that is at least 1.39 times the MOP, for a minimum of 15 minutes after the spike test pressure is stabilized. Sable must ensure that the spike hydrostatic pressure at the highest elevation of each testable segment is at least 1.39 times the MOP. Sable must field evaluate and remediate the following anomalies before performing the spike hydrostatic test on CA-325A: i. All metal loss anomalies that have an ILI reported depth of 40 percent and greater wall loss. ii. All anomalies that have a predicted failure pressure less than or equal to 1.5 times MOP. Immediately following the spike hydrostatic pressure test specified in Condition 13(c), Sable must conduct an 8-hour hydrostatic pressure test of CA-325A at a minimum of 1.25 times the MOP. Prior to placing Line 325B (segment of Line 325 between Sisquoc and Pentland stations) in operation, Sable must conduct a hydrostatic pressure test of CA-325B at a minimum pressure of 1.25 times the MOP, for a minimum of 8 hours. Sable must ensure that the hydrostatic pressure at the highest elevation of each testable segment is at least 1.25 times the MOP. Sable must field evaluate and remediate the following anomalies before performing the hydrostatic test on CA-325B: i. All metal loss anomalies that have an ILI reported depth of 40 percent and greater wall loss. ii. All anomalies that have a predicted failure pressure less than or equal to 1.4 times MOP. 11 Sable completed all of the testing required in this Condition, but the condition is included for completeness. <<>> f) Sable must obtain approval for each hydrostatic pressure test from PHMSA (or OSFM if such testing was performed prior to November 26, 2025) and have the approved independent testing firm forward separately the certified test results to PHMSA or the OSFM, as applicable. g) Each hydrostatic pressure test must be performed in accordance with the applicable requirements of 49 CFR Part 195 subpart E – Pressure Testing and monitored by an independent testing firm listed under PHMSA or OSFM (as applicable) approved hydrostatic testing companies. h) Failures resulting from the spike hydrostatic pressure test or the 8-hour strength test shall be immediately reported to PHMSA.12 i) Section(s) of the special permit segments that failed during the required hydrotesting must be repaired by removing and replacing the failed section. PHMSA reserves the right to revoke this special permit if failure(s) raise the concern that the special permit segments cannot be safely operated. 14) ILI assessment and frequency: a) Prior to performing ILIs of the special permit segment, Sable shall provide PHMSA with a written notification describing its assessment plan with the following information: i. Dates for integrity assessment. ii. ILI tool(s) selected, in accordance with API Standard 1163, section 5, and NACE SP010213 to assess the integrity of the subject pipe segment(s) in which ILIs must be capable to detect and size wall loss, dents, internal corrosion, external corrosion, cracks and crack-like indications. iii. ILI tool vendor(s). iv. Required tool specifications, including operational specifications and tool validation methodology. v. Anomaly feature identification criteria and reporting thresholds – wall loss, dents, internal corrosion, external corrosion, cracks, and crack-like indications. vi. Criteria used to identify locations for excavation and field verification. vii. Non-destructive examination. b) Within 7 days prior to any anticipated ILI tool run, Sable must use extensive brush pigs and solvents (xylene or other chemicals) to ensure that the internal pipe wall does not have any corrosive products, wax, and bacteria buildup that may affect the ILI tool performance. c) Metal loss tool(s): i. Initial ILI tool runs – Each year, during the first 2 years of operating the 12 All submissions to PHMSA required by this special permit shall be submitted through email to the OPS Western Region Director, Dustin Hubbard, email address, Dustin.Hubbard@dot.gov, or his designee. 13 Industry standards referenced in this special permit must utilize the editions that are incorporated by reference in 49 CFR § 195.3 unless another edition is explicitly specified in this special permit. <<>> d) e) f) ii. special permit segments, Sable shall conduct at least two ILIs using a UTWM tool with an inertial measurement unit (IMU). Sable shall compare both runs and evaluate all available information, including these tool runs and corresponding IMU data. Sable shall perform the UTWM tool run every 6 months not to exceed 9 months. If a UTWM tool run is unsuccessful, Sable shall identify the limitations that prevented the UTWM tool run from being successful, consider changes to increase the likelihood of a successful UTWM tool run, and use best efforts to rerun the UTWM tool within 30 days. Subsequent ILI tool runs – After the first 2 years of operating the special permit segments, Sable shall conduct at least one UTWM each calendar year, not to exceed 15 months, or the ILI assessment must be assessed at more frequent intervals if the remaining failure pressure ratio will be less than 1.39 times MOP prior to the next ILI assessment, based upon anomaly growth estimates and pressure cycling. If any UTWM tool run is deemed to be unsuccessful, Sable shall document the reasons why the UTWM tool was unsuccessful, consider changes to increase the likelihood of a successful UTWM tool run, and must reassess the special permit segment within 30 days after it was deemed to be unsuccessful. All metal loss tool runs must also utilize an IMU. Crack detection tools – Sable shall conduct at least one USCD tool each calendar year, not to exceed 15 months,14 or the ILI assessment must be assessed at more frequent intervals if condition 21 determined a shorter assessment interval. i. These crack tool runs must use an IMU and must be able to detect and size axial and circumferential cracks. ii. USCD performance specification requirements: 1. The USCD tools must have a probability of detection that is greater than or equal to 90 percent for axial and circumferential cracks. 2. The minimum crack depth that can be detected must be at least 1 mm for axial and circumferential cracks located in the base material. 3. The minimum crack depth that can be detected must be at least 2 mm for axial and circumferential cracks located in the weld. 4. The depth sizing accuracy for cracks must be ± 0.8 mm for axial cracks and ± 1 mm for circumferential cracks. Dents and Pipe Deformation: Sable shall conduct a high-resolution deformation ILI tool with each UTWM. Where any ILI tool fails to record data for 5 percent or more of the external and/or internal surface area of the inspected segment, reassess with the ILI tool to cover the area that is deemed to be inadequate data of the inspected segment. In addition, if the ILI tool travels at a speed outside the range of the tool velocity listed in the 14 Sable may petition PHMSA to revise the reassessment interval for crack detection tool(s) when sufficient evidence is available to determine if crack growth rates could support a longer reassessment interval. Changes to the reassessment interval are subject to PHMSA approval. <<>> tool specification for 2 percent or more of the length of the inspected segment, Sable must rerun the ILI tool to reassess the special permit segment in which the ILI tool velocity was outside of the specified tool velocity range. g) Sable must require its ILI tool vendor(s) to include in the vendor’s inspection report all metal loss indications of 10 percent or greater, based on raw data, prior to adding in any correction for tool tolerance. h) Sable must incorporate ILI tool accuracy by ensuring that each ILI tool service provider determines the tolerance of each tool, in accordance with API Standard 1163 Second Edition, and includes that tolerance in determining the size of each indication reported to Sable. i) Sable must account for ILI tool tolerance and anomaly growth rates in scheduled response times, repairs, and future reassessment intervals. Sable must document and justify the values used. Sable must demonstrate ILI tool tolerance accuracy for each ILI tool run by using calibration, excavations, and unity plots15 that demonstrate ILI tool accuracy to meet the tool accuracy specification provided by the vendor (typical for depth within +10 percent accuracy for 80 percent of the time). Sable must compare previous indications to current indications that are significantly different. If a trend is identified where the tool has been consistently over-calling or under-calling, the remaining ILI features must be re-graded accordingly. j) Prior to the ILI final report being received, Sable must perform at least four separate validation digs that do not interact with each other. At a minimum, Sable must perform validation digs in accordance with Level 2 of API Standard 1163, “In-line Inspection System Qualification” (Second Edition, April 2013). 15) Discovery of condition: The discovery date must be within 180 days of any ILI tool run for each type of ILI tool. 16) Immediate repair conditions:16 a) A crack or crack-like anomaly that meets any of the following criteria: i. Crack or crack-like anomaly that is equal to or greater than 50 percent of pipe wall thickness. ii. Crack or crack-like anomaly that has a predicted failure pressure of less than 1.39 times the MOP as calculated using crack-like flaw evaluation method ASME FFS-1/API 579-1. b) c) Internal or external metal loss anomalies where the remaining strength of pipe shows a predicted failure pressure less than 1.39 times the MOP. Any external cluster corrosion or external general corrosion located where the remaining strength of pipe shows a predicted failure pressure less than 1.5 times the 15 A minimum of four independent direct examination excavations must be used for unity plots. 16 The criteria specified in this special permit is supplemental to, and does not relieve Sable from complying with, the requirements set forth in 49 CFR § 195.452(h)(4)(i). All immediate repair conditions must be remediated with a permanent repair method. <<>> MOP.17 17) 180-day repair conditions:18 a) A crack or crack-like anomaly that has a predicted failure pressure of less than 1.5 times the MOP. 18) b) Internal or external metal loss anomalies where the remaining strength of pipe shows a predicted failure pressure less than 1.5 times the MOP. c) All internal or external metal loss anomalies that have an ILI reported depth of 40 percent or greater wall loss, including tool sizing tolerance for depth.19 d) For any crack (likely crack or possible crack) or crack-like anomaly, regardless of its dimensions, that interacts with metal loss anomalies and are within 1 inch (circumferentially) of the longitudinal seam weld, Sable must integrate the ILI results from the most recent crack tool run and the most recent metal loss tool run before the discovery date deadline. Corrosion growth rate analysis (CGRA): a) Sable must develop a CGRA procedure to annually calculate corrosion growth rates between successive ILIs (using most recent ILI compared to prior ILI) and perform pipeline remediations needed to assure the integrity of the special permit segments is maintained.20 The timing of remediations under this condition shall be based on the most recent calculation of short-term corrosion rates. b) The CGRA procedure must include ILI data matching methods21 to analyze data from successive ILIs, methodologies for growth rate calculations and errors from comparing ILI data. c) Sable must identify the projected date when remaining metal loss indications will reach a depth of 70 percent or greater wall loss. d) When determining the projected date when remaining metal loss indications will reach a depth of 70 percent or greater wall loss, Sable must account for reported ILI depth, tool tolerance and corrosion growth rates.22 e) All metal loss indications that are projected to reach a depth of 70 percent or greater wall loss prior to the next ILI, will become actionable and must be remediated before the next ILI. 17 Cluster means two or more adjacent metal loss features in the wall of the pipe or weld that may interact based on interaction criteria. General corrosion means uniform or gradually varying loss of wall thickness over an area. 18 The criteria specified in this special permit is supplemental to, and does not relieve Sable from complying with, the requirements set forth in 49 CFR § 195.452(h)(4)(iii), except for those associated with 49 CFR § 195.452(h)(4)(iii)(H). All immediate repair conditions must be remediated with a permanent repair method. 19 For example, if the ILI tool reports a 31 percent metal loss anomaly and the tool sizing tolerance is ±10 for depth, then this anomaly is a 180-day repair condition since it can be considered as an external metal loss anomaly with 41 percent metal loss depth. If Sable is unable to remediate such indications within 180 days of discovery, Sable must notify PHMSA, temporarily reduce the operating pressure, and take further remedial action in accordance with 49 CFR § 195.452 until the indication is remediated or until otherwise authorized by the PHMSA. 20 At a minimum, Sable must include signal matching between ILI data sets. 21 If there are several matching techniques that can be used, Sable must utilize the most accurate method of comparing ILI data sets. 22 Growth projections must use corrosion rates determined in accordance with the CGRA procedure. A default corrosion rate of 32 mpy must be used in determining projections, if corrosion rates determined by CGRA are less than the default value. <<>> 19) 20) Pressure reduction: If Sable is unable to perform field evaluation and remediation of any required conditions within the time limit conditions specified in this special permit, Sable must temporarily implement a minimum 20 percent or greater operating pressure reduction, based on actual operating pressure for 2 months prior to the date of inspection, until the anomaly is repaired. In field direct examination of pipe: a) Direct examinations23 of pipe must include appropriate non-destructive examination methods for cracking, such as magnetic particle inspection, shear wave technology, or phased array ultrasonic testing (PAUT).24 PAUT must be used for sizing any crack or crack-like anomaly lengths and depths. b) Permanent repairs of metal loss anomalies are required for any section of pipe with wall loss equal to or greater than 40 percent in accordance with repair method 1, 4b, or 5 of Table 451.6.2(b)-1 of ASME B31.4 2006 Edition. However, the following additional conditions apply if Sable chooses repair method 5 for metal loss anomalies: c) d) e) f) i. ii. Method 5 must not be used on metal loss anomalies that are in the HAZ, girth weld, or longitudinal seam weld. Sable must increase the metal loss anomaly’s depth by 20 percent when it inputs it into the formula for calculating the number of wraps needed for repair method 5. iii. After the anomaly is repaired via repair method 5, Sable must monitor the anomaly’s wall loss depth in subsequent UTWM tool runs. If the anomaly’s wall loss depth increases by more than 15 percent of the wall thickness in the subsequent UTWM tool runs, Sable must repair this anomaly via repair method 1 or 4b of Table 451.6.2(b)-1 of ASME B31.4 2006 Edition. Permanent repairs are required for all cracks and/or crack-like anomalies discovered during direct examination, regardless of crack depth or crack length in accordance with repair method 1 or 4b of Table 451.6.2(b)-1 of ASME B31.4 2006 Edition. Sable must develop a coating repair procedure for excavated or remediated corrosion anomalies that prevents further external corrosion and seals transition areas from currently insulated pipe to newly coated sections. Any time a shrink sleeve or coating is exposed, remove the shrink sleeve and coating, investigate circumferentially and longitudinally along the pipe for external corrosion and coating deterioration, and recoat with two-part epoxy. Sable must recoat in accordance with its coating repair procedure. All external polyurethane foam and the polyethylene tape wrap on buried pipe exposed during the field evaluation must not be replaced with new insulation or 23 Any time the pipeline is exposed for direct examination of an indication or to perform a repair, Sable must document the condition of the coating and carrier pipe (including anomalies) with photographs. 24 Direct examinations for ILI reported crack or crack-like indications must include a magnetic particle inspection complemented by shear wave technology or inspection by phased array ultrasonic testing. <<>> polyethylene tape wrap. 21) Integrity management: a) A fracture mechanics and pressure cycling evaluation is required for un-remediated cracks and crack-like indications detected by ILI or indirect inspection tools. i. Sable must determine the predicted failure pressure, failure stress pressure and crack growth of un-remediated cracks and crack-like anomalies in accordance with 49 CFR § 192.712(d)(1). ii. Sable must perform a fatigue analysis using an applicable fatigue crack growth law or other technically appropriate engineering methodology in accordance with 49 CFR § 192.712(d)(2). b) Sable must analyze a sample of additional indications of varying amounts of metal loss between 10 percent and 40 percent for validation. The sample size shall be at least ten, unless fewer than ten indications are reported within that range, in which case Sable would examine the number of indications called. 22) c) When sizing metal loss indications, apply interaction/clustering criteria of 6t by 6t for applicable ILI tool(s). d) Sable must send all field measurements to the ILI tool vendor within 90 days of completing direct examinations and require the ILI vendor to validate the accuracy of the tool. Sable must conduct annual meetings with the ILI tool vendor to discuss tool performance and incorporate lessons learned. e) Sable must utilize a third-party expert to review all ILI reports, verification of digs, data integration, ILI tool tolerances, development of unity plots, measured field findings, failure pressure ratios and any other finding that could affect the integrity of the special permit segments. The review must be conducted within 6 months of each ILI assessment. The third-party expert must be approved by PHMSA prior to being selected. f) Within 1 year from date of issuance, Sable must use a NACE-certified expert to conduct an evaluation and determine if alternating current (AC) interference or direct current (DC) interference or shorting that could contribute to external corrosion is occurring. The expert must recommend the frequency of subsequent interference surveys. All evaluations must be approved and signed by the NACE- certified expert.25 Data requirements for predicted failure analysis: a) Unless the defect dimensions have been verified using a direct examination measurements, Sable must explicitly analyze uncertainties in reported assessment results, including—but not limited to—tool tolerance, detection threshold, probability of detection, probability of identification, sizing accuracy, conservative anomaly, interaction criteria, location accuracy, anomaly findings, and unity chart plots or equivalent for determining uncertainties and verifying tool performance, in identifying and characterizing the type and dimensions of anomalies or defects used in the analyses. 25 Sable completed the evaluation required in this condition, but the condition is included for completeness. <<>> b) The analyses performed in accordance with this special permit must utilize pipe and material properties of the pipe body and longitudinal weld seam that are documented in traceable, verifiable, and complete records. 23) Recordkeeping: a) Procedures, records of investigations, data, analyses, and other actions made in accordance with the requirements of this special permit shall be kept for the life of the special permit segments and must be submitted to the PHMSA in the manner requested (electronic, hardcopy, or other format) within 30 days. b) Sable must maintain the following records: i. Technical approach used for the analysis. ii. All data used and analyzed. iii. Pipe and longitudinal weld seam properties. iv. Procedures used to implement special permit conditions. v. Evaluation methodology used. vi. Models used. vii. Direct in situ examination data. viii. All ILI tool assessments information evaluated. ix. Pressure test data and results. x. xi. All in-the-ditch assessments performed on the special permit segments. All measurement tool, assessment, and evaluation accuracy specifications and tolerances used in technical and operations results. xii. All finite element analysis results. xiii. The number of pressure cycles to failure, the equivalent number of annual pressure cycles, and the pressure cycle counting methodology. xiv. The predicted fatigue life and predicted failure pressure from the required fatigue life models and fracture mechanics evaluation methods. xv. Safety factors used for fatigue life and/or predicted failure pressure calculations. xvi. Reassessment time interval and safety factors. xvii. The date of the review. xviii. Confirmation of the results by qualified technical subject matter expert(s). xix. Approval by responsible Sable management personnel. xx. Records of additional preventive and mitigative measures performed. xxi. Reports required by this special permit. 24) Reporting: a) Any release on the special permit segments shall be reported to PHMSA at the earliest practicable moment following discovery but no later than 24 hours from the <<>> b) c) d) time of discovery.26 An email notification shall be made to PHMSA at least 3 days prior to a special permit segment being exposed for non-emergency purposes of field evaluation and repair. The email notification shall include, if applicable: i. Tool type and run date. ii. Unique identifier (e.g., dig number, joint number, flaw ID, condition type). iii. Dig sheets. iv. Field contact information for Sable. v. Time and location of the field evaluation and repair. Sable shall provide a summary of conditions report within 210 days of the last date of an ILI run to PHMSA and include: i. Tool type. ii. Run date. iii. Summary of conditions report.27 iv. Final vendor report and pipe tally. Sable shall provide a report to PHMSA by June 15 of every year for the duration of this special permit. At a minimum, the annual report shall contain the following, if applicable: i. A closure report for the previous calendar year (CY), which contains: 1. Features that were remediated in previous CY, including documentation for in-the-ditch assessments and repairs. 2. Identify features that remain to be assessed. 3. Unity plots for previous ILI runs. ii. Fracture mechanics and pressure cycling analyses in accordance with condition 21(a). iii. The third-party ILI expert reviews in accordance with condition 21(e). iv. v. AC and DC interference surveys that are due in accordance with condition 21(f). A copy of the CGRA for prior year, including: 1. Mean corrosion growth rate for the special permit segments. 2. Distribution graph of the corrosion growth rate for the special permit segments (e.g., occurrences (#) versus corrosion rate (mpy)). 26 This requirement does not relieve Sable from spill reporting requirements that might exist under local, State, or Federal regulations. 27 PHMSA may stipulate specific formatting or other information (e.g., condition type, anomaly details, remaining strength calculation method, failure pressure, CGRA) to be included in the summary of conditions reports, closure report, and annual reports - **truncated:** true - **body characters:** 69034