{"operation":"document","citation":"0900006480e91a41","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":"u.s. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION Special Permit Analysis and Findings Special Permit Information: Docket Number: Pipeline Operator: Date Requested: Code Section(s): PHMSA-2009-0056 TransCanada Pipelines Limited, operator of American Natural Resources Pipeline (TCPL-ANR) February 6, 2009 49 CFR § 192.611 Purpose: The... requirement for wall loss, but would need to run in line inspection tools both high resolution MFL and geometry tools to detect corrosion and to detect dents. 7) TCPL-ANR has met this requirement for wall loss, but would need to run an ILl tool to detect dents and re-run ILl for anomalies and corrosion. 8) Criteria for...","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a41.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a41.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a41","source_url":"https://downloads.regulations.gov/PHMSA-2009-0056-0009/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-2009-0056\nTransCanada Pipelines Limited, operator of American Natural\nResources Pipeline (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 ofthe subject special permit application submitted by\nTransCanada Pipelines Limited, operator of American Natural Resourcesl (TCPL-ANR), to\ndiscuss any relevant public comments received with respect to the application, to present the\nengineering/safety analysis of the special permit application, and to make findings regarding\nwhether the requested special permit should be granted and if so under what conditions.\nPipeline System Affected:\nThis special permit application applies to one (1) special permit segment along the TCPL-ANR\nsystem of natural gas pipelines. This special permit segment is on the 30-inch Line 1-501\npipeline located in Tate County, Mississippi. The class location along the pipeline special permit\nsegment has changed from an original Class 1 Location to a Class 32 Location.\nThis special permit application applies to the special permit segment and special permit\ninspection area defined using the TCPL-ANR valve stationing references as follows:\n1 American Natural Resources is owned and operated by TransCanada Pipelines Limited~\n2 This Class 3 special permit segment was originally a Class 1 location that was upgraded to Class 2 location in\naccordance with § 192.611 (a) hydrostatic test.\n\n<<<PAGE 2>>>\n\n• Special permit segment - Line 1-501,872 feet, from Valve 27 Station 927 +05 to Valve 27\nStation 935+77.\n• Special permit inspection area means the area that extends 220 yards perpendicular on each\nside of the centerline of the Line 1-501, 30-inch, pipeline from the discharge of the Sardis\nCompressor Station at Valve 27 Station 0+00 (approximately 17.6 miles upstream of the\nspecial permit segment) to the Brownsville Compressor Station at Valve 29 Station 297+05\n(approximately 25 miles downstream of the special permit segment). The special permit\ninspection area is approximately 42.77 miles long and 440 yards wide and includes the\nspecial permit segment.\nSpecial Permit Request\nTCPL-ANR submitted an application to PHMSA on February 6, 2009, for a special permit\nseeking relief from the Federal pipeline safety regulations in 49 CFR § 192.611(a) for one (1)\nsegment of TCPL-ANR natural gas transmission 30-inch Line 1-501 pipeline where a change has\noccurred from an original Class 1 location to a Class 3 location in Tate County, Mississippi.\nThis special permit request is to allow TCPL-ANR to continue to operate the pipeline special\npermit segment at its current maximum allowable operating pressure (MAOP) of 858 pounds per\nsquare inch gauge (psig). The Federal pipeline safety regulations in 49 CFR § 192.611 (a)\nrequire natural gas pipeline operators to confirm or revise the MAOP of a pipeline segment after\na change in class location.\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-2009-0056 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 referred to as a special\n\n<<<PAGE 3>>>\n\npermit. Certain threshold requirements must be met for a pipeline section to be further evaluated\nfor a class location change special permit. The age and manufacturing process of the pipe;\nsystem design and construction; environmental, operating and maintenance histories; and\nintegrity management program elements are evaluated as significant criteria. These significant\ncriteria are presented in matrix form and can be reviewed in the FDMS, Docket Number\nPHMSA-RSPA-2004-17401. Special permits will only then be granted when pipe conditions\nand active integrity management provides a level of safety greater than or equal to a pipe\nreplacement 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 petition.\n1) No pipeline segments in a class location changing to Class 4 Location will be considered.\nThis special permit request is for the PHMSA 2009-0056 segment of TCPL-ANR pipeline\nwhere a class location change has occurred from a Class 1 location to a Class 3 location.\n2) No bare pipe will be considered. These TCPL-ANR special permit segment is coated with\nAllied cold tar enamel, primer, and felt wrap. TCPL-ANR has met this requirement.\n3) No pipe containing wrinkle bends will be considered. There are no wrinkle bends in the\nspecial permit segments. 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 SMYS. TCPL-ANR records submitted show that\nthe sections ofthe 30-inch Line 1-501 pipeline has been hydrostatically tested to 1,150 psig\nwhich is 1.34 x MAOP and 96.5% of SMYS. TCPL-ANR has met this requirement. TCPL-\nANR has mechanical and chemical properties test reports for the pipe to verify the pipe\nspecifications, but these reports indicate the pipe has low toughness properties.\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\nIII in 2003, with no immediately actionable anomalies found. TCPL-ANR has met this\n\n<<<PAGE 4>>>\n\nrequirement for wall loss, but would need to run in line inspection tools both high resolution\nMFL and geometry tools to detect corrosion and to detect dents.\n7) TCPL-ANR has met this requirement for wall loss, but would need to run an ILl tool to\ndetect dents and re-run ILl for anomalies and corrosion.\n8) Criteria for consideration of class location change waiver, now referred to as a special permit,\npublished by PHMSA in the Federal Register (69 FR 38948), define a waiver inspection\narea (special permit inspection area) as up to 25 miles of pipe either side of the waiver\nsegment (special permit segment). The special permit inspection area must be inspected\naccording to operator's integrity management program and periodically inspected with an in-\nline inspection technique. The special permit inspection area is approximately 42.77 miles\nin contiguous length. This special permit, if issued, would be contingent upon the operator's\nincorporation of each of the special permit segments in its written integrity management\nprogram as a \"covered segment\" in a \"high consequence area\" (HCA) per 49\nCFR § 192.903.\nCriteria Matrix: The original and supplemental data submitted by TCPL-ANR for the special\npermit segments have been compared to the class location change special permit criteria matrix.\nThe data fall within the probable acceptance column of the criteria matrix except for:\na. Possible acceptable justification - pipe coating, depth of cover, hydrostatic test\nrupture, ILl, and cathodic protection.\nb. Requires substantial justification - pipe manufacture and girth weld inspections\nThe data findings below fall within the \"possible acceptance\" or the \"requires substantial\njustification\" column of the criteria matrix:\n1) Possible Acceptable Justification - Pipe coating, leaks & failures, depth of cover and ILl\ninspections: The 30-inch pipe is coated with coal tar enamel coating. TCPL-ANR would be\nrequired to remediate this coating in the special permit segment by Direct Current Voltage\nGradient (DCVG) surveyor an Alternating Current Voltage Gradient (ACVG) survey and\nclose interval surveys (CIS) and remediate poor quality coating. The pipeline did have a\nhydrostatic test failure in 1966, but has no leaks or failures since that time. Depth of cover\nwas not confirmed by TCPL-ANR, so a survey and remediation of shallow areas would need\n\n<<<PAGE 5>>>\n\nto be required if a special permit was issued. To confirm cathodic protection a CIS survey\nwould be required in the special permit inspection area.\n2) Requires substantial justification - pipe manufacture and girth weld inspections: TCPL-ANR\nindicates 30-inch Line 1-501 pipeline was installed in 1966 and consists of American\nPetroleum Institute Specification 5LX, Specification/or Line Pipe (API 5LX), double\nsubmerges arc welded (DSAW), X-60 steel pipe manufactured by Kaiser Steel. TCPL-ANR\nstates it has mill test reports to verify the strength and chemistry of the pipe, but the pipe steel\ntoughness is low for fracture arrest. TCPL-ANR has tested this pipeline to 96.5% SMYS test\nlevels, 1150 psig, and 134% ofMAOP. TCPL-ANR reports no in service leaks or failure on\nthis 30-inch pipeline in the special permit inspection area. This would place all special\npermit segments in the \"requires substantial justification\" column of the criteria matrix.\nTCPL-ANR would be required by the special permit conditions to hydrostatically test the 30-\ninch pipe in the special permit segment to 100% SMYS and to cut pipe samples to verify the\npipe strength properties. TCPL-ANR does not have records to show that pipeline girth welds\nwere non-destructively tested during construction. TCPL-ANR would be required to conduct\ntests to verify girth weld quality in the special permit conditions, if a special permit was\nissued.\nTo further address the pipe manufacture and girth weld quality, an operator of pipe such as\nthe pipe involved in this application would have to treat all special permit segments as\n\"covered segments\" in an HCA per 49 CFR § 192.903. ILl assessments, anomaly repairs,\nCIS, and stress corrosion cracking direct assessment (SCCDA) of 30-inch Line 1-501\npipeline would be required to be performed along the entire length of the special permit\ninspection area and special permit segments according to the requirements of 49 CFR\n§ 192.929 within one year after the grant of a special permit and on a 7 year reassessment\ninterval. A special permit would need to include a condition that each special permit\nsegment be operated at or below its existing MAOP. TCPL-ANR would be required by a\nspecial permit to evaluate girth weld quality and pipe strength.\n\n<<<PAGE 6>>>\n\nPHMSA has determined that issuing a special permit with conditions would not provide\nequivalent safety for this area where an original Class 1 location is being upgraded to a Class 3\nlocation. TCPL-ANR did not furnish documentation that shows the pipe steel toughness\nproperties are high enough to mitigate fracture propagation and arrest cracks in the steel pipeline.\nLow toughness pipe can potentially increase the consequences of a pipeline failure in a Class 3\nlocation. Class location upgrades that are considered by PHMSA for special permits in\npopulated areas must meet pipe toughness standards, so that integrity evaluations for special\npermit conditions are technically sound.\nFindings:\nPHMSA has determined that a special permit, even with conditions, that would allow TCPL-\nANR to leave the existing subject pipeline segment in service at its current MAOP will not\nensure equivalent safety in this populated Class 3 location and would not be consistent with\npipeline safety. Accordingly, we recommend that the special permit request be denied.\ntJUL 1 62010\nCompleted in Washington DC on: ____________ _\nPrepared By: PHMSA - Engineering and Emergency Support","truncated":false,"body_characters":12160}