{"operation":"document","citation":"0900006480e91a03","title":"U.S. DOT/PHMSA - Special Permit Analysis and Findings","source_type":"rulemaking","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":null,"effective_on":null,"summary":"The attachment describes a special permit request by TCPL-ANR (PHMSA docket PHMSA-2009-0061) to continue operating a roughly 3,368-foot portion of 20-inch Line 515 in Lucas County, Ohio, at its existing MAOP after a change from Class 1 to Class 3. PHMSA reviewed threshold criteria and integrity-related factors: several threshold requirements were met (coating, no wrinkle bends, operating at or below 72% SMYS, prior hydrostatic test to 1.51 x MAOP, prior ILI in 2005 with no actionable anomalies), and PHMSA published public notice with no comments received. However, PHMSA identifies missing pipe mechanical and chemical properties reports (mill test reports) for the pipe in the segment, which PHMSA states are required to confirm pipe strength for MAOP determination and anomaly repair calculations. Based on the application, technical and safety analysis, and the operating and compliance file","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a03.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a03.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a03","source_url":"https://downloads.regulations.gov/PHMSA-2009-0061-0011/attachment_1.pdf","body":"<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSpecial Permit Analysis and Findings\nSpecial Permit Information:\nDocket Number:\nPipeline Operator:\nDate Requested:\nCode Section(s):\nPHMSA -2009-0061\nTransCanada Pipelines Limited, operator of American Natural Resources\nPipeline (TCPL-ANR)\nFebruary 6, 2009\n49 CFR § 192.611\nPurpose:\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA) provides this\ninformation to describe the facts of the subject special permit application submitted by\nTransCanada Pipelines Limited-American Natural Resourcesl (TCPL-ANR), to discuss any\nrelevant public comments received with respect to the application, to present the engineering and\nsafety analysis of the special permit application, and to make findings regarding whether the\nrequested special permit should be granted and, if so, under what conditions.\nPipeline System Affected:\nThis special permit request involves one (1) special permit segment on the TCPL-ANR 20-inch\nLine 515, a natural gas transmission pipeline, where changes have occurred from an original\nClass 1 location to a Class 32 location in Lucas County, Ohio. If granted, a special permit\nwould allow TCPL-ANR to continue to operate the 20-inch Line 515 at its current maximum\nallowable operating pressure (MAOP) of 858 pounds per square inch gauge (psig).\n1 American Natural Resources is owned and operated by TransCanada Pipelines Limited.\n2 This Class 3 location special permit segment was originally a Class 1 location that was upgraded to Class 2\nlocation in accordance with § 192.611 (a) hydrostatic test.\n\n<<<PAGE 2>>>\n\nTCPL-ANR's special permit request applies to the special permit segment defined using the\nTCPL-ANR Survey Station Number (including Mile Post) references as follows:\n• Special permit segment - 20\" Line 515 - approximately 3,368 feet in length located in\nLucas County, Ohio, downstream of Valve 1 from Survey Station Number 430+69 to Survey\nStation Number 464+37 (Milepost 23.83 to 24.47).\nSpecial Permit Request\nOn February 6, 2009, TCPL-ANR submitted an application to PHMSA, for a special permit\nseeking relief from the Federal pipeline safety regulations in 49 CFR § 192.611(a) for the above\nlisted segment. The Federal pipeline safety regulations in 49 CFR § 192.611 require natural gas\npipeline operators to confirm or revise the MAOP of a pipeline segment after a change in class\nlocation. A special permit would allow TCPL-ANR to continue to operate the special permit\nsegment at its existing MAOP despite a change in class location. If the special permit\napplication is denied, TCPL-ANR would have to reduce pipeline pressure or replace the subject\npIpe.\nPublic Notice:\nOn April 28, 2009, PHMSA posted a notice of this special permit request in the Federal Register\n(74 FR 19264). PHMSA did not receive any comments for or against this special permit request\nas a result of this notice. The request letter, Federal Register notice, and all other pertinent\ndocuments are available for review in Docket No. PHMSA-2009-0061 in the Federal Docket\nManagement System (FDMS) located on the internet at www.Regulations.gov.\nAnalysis:\nBackground: On June 29, 2004, PHMSA published in the Federal Register (69 FR 38948) the\ncriteria it uses for the consideration of class location change waivers, now being granted through\na special permit. First, certain threshold requirements must be met for a pipeline segment to be\nfurther evaluated for a class location change special permit. Second, the age and manufacturing\nprocess of the pipe; system design and construction; environmental, operating and maintenance\nhistories; and integrity management program elements are evaluated as significant criteria.\nThese significant criteria are presented in matrix form and can be reviewed in the FDMS, Docket\n\n<<<PAGE 3>>>\n\nNumber PHMSA-RSPA-2004-17401. Third, such special permits will only then be granted\nwhen pipe conditions and active integrity management provides a level of safety greater than or\nequal to a pipe replacement or pressure reduction.\nThreshold Requirements: Each of the threshold requirements published by PHMSA in the\nJune 29,2004, FR notice is discussed below in regards to the TCPL-ANR special permit request.\n1) No pipeline segments in a class location changing to Class 4 location will be considered.\nThis special permit request is for one (l) segment of TCPL-ANR pipeline where a class\nlocation change has occurred from a Class 1 to Class 3 location. TCPL-ANR meets this\nrequirement.\n2) No bare pipe will be considered. This TCPL-ANR special permit segment is coated with\nfusion bonded epoxy (FBE) coating. TCPL-ANR has met this requirement.\n3) No pipe containing wrinkle bends will be considered. There are no wrinkle bends in the\nspecial permit segment. TCPL-ANR has met this requirement.\n4) No pipe segments operating above 72% of the specified minimum yield strength (SMYS)\nwill be considered for a Class 3 special permit. The special permit segment operates at or\nbelow 72% SMYS. TCPL-ANR has met this requirement.\n5) Records must be produced that show a hydrostatic test to at least 1.25 x maximum allowable\noperating pressure (MAOP) and 90% of the specified minimum yield strength (SMYS).\nTCPL-ANR records submitted show that the sections of the Line 515 containing the special\npermit segment have been hydrostatically tested to 1293 psig, which is 1.51 x MAOP and\n99% of SMYS. TCPL-ANR has met this requirement.\n6) In-line inspection (ILl) must have been performed with no significant anomalies identified\nthat indicate systemic problems. The proposed special permit segment was last inspected by\nILl in 2005, with no immediately actionable anomalies found. TCPL-ANR would be\nrequired to run future ILl tools, if this special permit is granted.\n7) Criteria for consideration of class location change waiver, now being granted through special\npermit, published by PHMSA in the Federal Register (69 FR 38948), define a waiver\ninspection area (special permit inspection area) as up to 25 miles of pipe either side of the\nwaiver segment (special permit segment). The special permit inspection area must be\ninspected according to TCPL-ANR's integrity management program and periodically\n\n<<<PAGE 4>>>\n\ninspected with an in-line inspection technique. If granted, a special permit would be\ncontingent upon TCPL-ANR's incorporation of the special permit segment in its written\nintegrity management program as a \"covered segment\" in a \"high consequence area\"\n(HCA) in accordance with 49 CFR § 192.903.\nCriteria Matrix and Operational Integrity Compliance:\nAs part of its review of TCPL-ANR's application, PHMSA evaluated the relevant regulatory\ncompliance and enforcement history to determine the overall fitness of TCPL-ANR to receive a\nspecial permit. The special permit segment meets most of the threshold requirements; however a\nreview of pipe material shows the following integrity issues:\n• The 20-inch Line 515 pipeline consists of American Petroleum Institute Specification\n5LX, Specification for Line Pipe (API 5LX), electric resistance welded (ERW), X-52\nsteel pipe manufactured by American Steel. TCPL-ANR has not provided mechanical\nand chemical properties reports (mill test reports) for the pipe in the special permit\nsegment to document pipe strength for the pipeline operating pressure.\nPrior to granting a special permit for a class location change, PHMSA requires operators to\nsubmit pipe strength documentation for Class 1 to Class 3 location upgrades. This\ndocumentation is necessary to confirm the pipe strength for usage in operating pressure\ndetermination and anomaly repair safe pressure calculations. This pipeline segment was\nconstructed in 1991 and TCPL-ANR must maintain this critical pipe strength documentation to\ndetermine maximum allowable operating pressure (MAOP) in accordance with 49 CFR\n§§ 192.1 05 and 192.611.\nCompliance History - 2000 through 2009:\nA review ofPHMSA enforcement actions for the TCPL-ANR pipeline system from 2000\nthrough 2009, shows the following enforcement actions against TCPL-ANR, which are in the\n\"possible acceptance justification category\".\n• Letters - ofConcem or Warning - 8 matters\n• Notices - of Amendment or of Probable Violation - 4 matters\n\n<<<PAGE 5>>>\n\n. .\n• Collected Civil Penalties - $51,000 collected, additional penalties have been proposed\nTransCanada Pipelines Limited has operated the ANR pipeline system since February 22, 2007.\nThe 10-year enforcement history of the ANR system reveals only a few compliance issues.\nGiven TCPL-ANR's lack of pipe mechanical and chemical properties reports to confirm the\nstrength of the pipe in the special permit segment, issuance of a special permit would not be\nconsistent with pipeline safety nor would it be in the public interest.\nFindings:\nFor the reasons discussed above and having reviewed TCPL-ANR's application, analyzed the\ntechnical and safety issues involved, and the relevant operating and compliance history, PHMSA\nrecommends that the special permit requested by TCPL-ANR for one segment of Line 515 in\nLucas County, Ohio, be denied.\nSEP 1 7 2010\nCompleted in Washington DC on: ____________ _\nPrepared by: Engineering and Emergency Response","truncated":false,"body_characters":9234}