{"operation":"document","citation":"0900006480e91a56","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":"1 U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (PHMSA) Special Permit Analysis and Findings Special Permit Information: Docket Number: Pipeline Operator: Date Requested: Code Section(s): PHMSA-2009-0055 TransCanada Pipelines Limited - American Natural Resource (TCPL-ANR) February 6, 2009 49 CFR § 192.611 Purpose: The Pipeline and... 5 b. Requires substantial justification - pipe manufacture, pipe girth weld, and ILl inspections The data findings below fall within the \"probable acceptance\" or the \"requires substantial justification\" column of the criteria matrix: 1) Pipe coating, leaks & failures, and depth of cover: The 20-inch pipe is coated with...","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a56.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a56.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91a56","source_url":"https://downloads.regulations.gov/PHMSA-2009-0055-0013/attachment_1.pdf","body":"<<<PAGE 1>>>\n\n1\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (PHMSA)\nSpecial Permit Analysis and Findings\nSpecial Permit Information:\nDocket Number:\nPipeline Operator:\nDate Requested:\nCode Section(s):\nPHMSA-2009-0055\nTransCanada Pipelines Limited - American Natural\nResource (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 four (4) special permit segments along the TCPL-ANR\nsystem of natural gas pipelines. These four (4) special permit segments are on the 20-inch Line\n716 pipeline located in St. Martin Parish, Louisiana. The class locations along the pipeline\nspecial permit segments have changed from an original Class 1 Location to a Class 32 Location.\nThis special permit application applies to the special permit segments and special permit\ninspection area defined using the TCPL-ANR Survey Station Numbers (including Mile Post)\nreferences as follows:\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\n2\nSt. Martin Parish, Louisiana\n• Special permit segment 1 - approximately 553 feet of20-inch Line 716 located downstream\nof Valve 6 (end ofline) from Survey Station Number 628+29 feet to Survey Station Number\n633+82 feet in St. Martin Parish, Louisiana, Mileposts 58.90 to 58.80.\n• Special permit segment 2 - approximately 1,042 feet of 20-inch Line 716 located from\nSurvey Station Number 634+62 feet to Survey Station Number 644+86 feet in St. Martin\nParish, Louisiana, Mile Posts 58.78 to 58.59.\n• Special permit segment 3 - approximately 63 feet of 20-inch Line 716 located from Survey\nStation Number 656+30 feet to Survey Station Number 656+93 feet in St. Martin Parish,\nLouisiana, Mile Posts 58.37 to 58.36.\n• Special permit segment 4 - approximately 817 feet of20-inch Line 716 located from Survey\nStation Number 703+51 feet to Survey Station Number 711 +68 feet in St. Martin Parish,\nLouisiana, Mile Posts 57.48 to 57.32.\nSt. Martin, St. Landry and Iberia Parishes, Louisiana\nSpecial permit inspection area is the area that extends 220 yards on each side of the pipe\ncenterline along the entire length ofthe 20-inch Line 716 pipeline from Station 0+000 of Valve\n6 (end ofline) in St. Landry Parish, Louisiana to 29,914 ft downstream of Valve 4 in Iberia\nParish, Louisiana. The special permit inspection area is located in St. Landry, St. Martin, and\nIberia Parishes, Louisiana. The special permit inspection area extends approximately 11.90\nmiles upstream of the special permit segment I to approximately 25 miles downstream of the\nspecial permit segment 4; (Milepost 70.80 to 32.31). The total length of the special permit\ninspection area including the four special permit segments is approximately 38.48 miles.\nNote: The special permit inspection area includes the four (4) special permit segments.\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 four\nsegments of the TCPL-ANR natural gas transmission 20-inch Line 716 pipeline where a change\nhas occurred from a original Class 1 location to a Class 3 location in St. Martin, St. Landry and\n\n<<<PAGE 3>>>\n\n3\nIberia Parishes, Louisiana. The special permit would have allowed TCPL-ANR to continue to\noperate the pipeline segments at their current maximum allowable operating pressure (MAOP) of\n1,050 pounds per square inch gauge (psig), respectively. The Federal pipeline safety regulations\nin 49 CFR § 192.611(a) require natural gas pipeline operators to confirm or revise the MAOP of\na pipeline segment after a 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.\nThe request letter, Federal Register notice, and all other pertinent documents are available for\nreview in Docket No. PHMSA-2009-0055 in the Federal Docket Management System (FDMS)\nlocated 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\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 No. PHMSA-\nRSPA-2004-17401. Such special permits will only then be granted when pipe conditions and\nactive 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 PHMSA 2009-0055 segments of TCPL-ANR pipeline\nwhere a class location change has occurred from Class 1 to Class 3.\n\n<<<PAGE 4>>>\n\n5\nb. Requires substantial justification - pipe manufacture, pipe girth weld, and ILl\ninspections\nThe data findings below fall within the \"probable acceptance\" or the \"requires substantial\njustification\" column of the criteria matrix:\n1) Pipe coating, leaks & failures, and depth of cover: The 20-inch pipe is coated with Koppers\nXXH enamel and primer and felt wrap. TCPL-ANR would be required to remediate this\ncoating in the special permit segment by conducting Direct Current Voltage Gradient\n(DCVG) surveyor an Alternating Current Voltage Gradient (ACVG) survey, and close\ninterval surveys (CIS) and remediate poor quality coating. The pipeline did have a leak in\n1983 due to internal corrosion caused by chlorines (salt) and water in the gas stream. Since\n1995 TCPL-ANR has cleaned with scraper pigs this section of pipeline over 97 times to\nremove deleterious gas stream constituents from the special permit inspection area. Depth of\ncover was not confirmed by TCPL-ANR, so if a special permit was issued the conditions\nwould require a survey and remediation of shallow areas.\n2) Pipe manufacture, pipe girth weld, and ILl inspections: 20-inch Line 716 pipeline was\ninstalled in 1964 and consists of American Petroleum Institute Specification 5LX,\nSpecificationfor Line Pipe (API 5LX), electric flash welded (EFW), X-52 steel pipe\nmanufactured by A.O Smith. Pipe with EFW seams normally have systemic manufacturing\nissues. TCPL-ANR has tested this pipeline to 99.2% SMYS test levels, 1449 psig. TCPL-\nANR reports no hydrostatic test and no in service leaks or failures on this 20-inch pipeline in\nthe special permit inspection area due to selective seam corrosion. However, this type of\nweld seam pipe has been known for systemic manufacturing issues resulting in weld seam\nfailure. This will place the special permit segments in the \"requires substantial justification\"\ncolumn of the criteria matrix would place all special permit segments in the \"requires\nsubstantial justification\" column of the criteria matrix.\nTo further address these pipe manufacture, girth weld and internal corrosion issues, an\noperator of pipe such as the pipe involved in this application would have to meet conditions\nrequiring TCPL-ANR to treat all special permit segments as \"covered segments\" in an HCA\nper 49 CFR § 192.903. TCPL-ANR did not have records to substantiate girth weld quality.\n\n<<<PAGE 5>>>\n\n6\nTo address lack oflLI Tool inspections, a special permit inspection area would need to\nrequire be the 20-inch Line 716 pipeline to be inspected according to TCPL-ANR's integrity\nmanagement program and periodically inspected with an in-line inspection technique. Any\nspecial permit issued would need to be contingent upon TCPL-ANR incorporation of each of\nthe special permit segments in its written integrity management program as a \"covered\nsegment\" in a \"high consequence area\" (HCA) in accordance with 49 CFR § 192.903.\nThe proposed special permit segments on the 20-inch Line 716 pipeline have had internal\ncorrosion issues due to poor gas quality, poor pigging practices, and have EFW weld seams.\nThese proposed special permit segments are located in densely populated areas, which are new\nClass 3 location population areas defined by § 192.5(a)(1), (a)(2) and (b )(3) - Class Locations as\nfollows;\n(a) This section classifies pipeline locations for purposes of this part. The following\ncriteria apply to classifications under this section.\n(1) A \"class location unit\" is an onshore area that extends 220 yards (200\nmeters) on either side of the centerline of any continuous I-mile (1.6\nkilometers) length of pipeline.\n(2) Each separate dwelling unit in a multiple dwelling unit building is counted\nas a separate building intended for human occupancy.\n(b) (3) A Class 3 location is:\n(i) Any class location unit that has 46 or more buildings intended for\nhuman occupancy; or\n(ii) An area where the pipeline lies within 100 yards (91 meters) ofeither\na building or a small, well-defined outside area (such as a playground,\nrecreation area, outdoor theater, or other place of public assembly) that is\noccupied by 20 or more persons on at least 5 days a week for 10 weeks in\nany 12-month period (The days and weeks need not be consecutive.)\nTo further address these pipe design and construction issues, an operator of pipe such as the pipe\ninvolved in this application would have to meet conditions requiring TCPL-ANR to treat all\nspecial permit segments as \"covered segments\" in an HCA per 49 CFR § 192.903. A stress\ncorrosion cracking direct assessment (SCCDA) of the 20-inch Line 716 pipeline would also be\nrequired along the entire length of the special permit inspection area according to the\nrequirements of 49 CFR § 192.929.\n\n<<<PAGE 6>>>\n\n7\nPHMSA has determined that a special permit, even with conditions, that would allow TCPL-\nANR to leave the existing 20-inch Line 716 pipeline in service will not ensure equivalent safety\nbased upon the 49 CFR § 192.611 regulations for Class 3 location areas due to Line 716 pipeline\ngas quality issues from gas supplies, the 1983 internal leak due to internal corrosion and the\npresence ofpre-1970 EFW pipe in the Class 3 location special permit segments.\nFindings:\nBased on the information submitted by TCPL-ANR and PHMSA's analysis of the technical,\noperational, and safety issues, and given the additional measures required and conditions that\nwould be imposed, PHMSA finds that granting this special permit to TCPL-ANR to operate four\n(4) special permit segments of the 20-inch Line 716 pipeline, a natural gas transmission pipeline,\nat the current MAOP of 1080 psig where a change in class location has occurred from an original\nClass 1 location to a Class 3 location would be inconsistent with pipeline safety.\nThe failure risks of vintage seam pipe longitudinal welds (EFW and LF-ERW pipe) are\ndocumented in the \"Integrity of Vintage Pipelines\" prepared by the Interstate Natural Gas\nAssociation of America (INGAA) dated October, 2004 (Vintage Pipe Report). The Vintage Pipe\nReport documents several integrity and performance history reasons to be concerned with LF-\nERW and/or EFW pipe due to:\n• Lack of fusion and oxides along the weld seam bond line, due to poor process controls,\n• Stitched seam welds, which are alternating from complete and incompletely fused or\npartially fused areas, due to uneven heating,\n• Hook cracks near the weld seam bond line caused by inclusions in the steel,\n• Excessive trim or grooving (wall thickness reduction), and\n• Arc burns resulting from poor or intermittent welding electrode contact.\nPHMSA is advancing Research & Development to review the service history of LF -ER W\n(including EFW) longitudinal seam pipe and will also review integrity management/inspection\ntools to detect integrity issues with these pipe seams. This is a follow-up to a National\nTransportation Safety Board (NTSB) recommendation on the subject. Following NTSB's\ninvestigation of the Dixie Pipeline failure in 2007, NTSB developed safety recommendations to\n\n<<<PAGE 7>>>\n\n......\n8\nPHMSA focused on preventing failures in LF- ERW pipe. Until PHMSA is satisfied that the\ninherent integrity risks associated with this type pipe seam can be reliably managed, PHMSA\nwill not issue special permits to allow operation ofLF-ERW, EFW, or other pipe with a history\nof pipe seam integrity issues for original Class 1 location pipe installed in a sparsely populated\narea to be upgraded through a special permit process to operate in a densely populated Class 3\nlocation.\nThe risks posed by these pipe seam characteristics and the lack of documentation are not\nacceptable in a populated Class 3 location. The applicant has not described a plan or the use of\ntechnology to remediate these pipelines that would mitigate the safety risks in a Class 3 location\nconsistent with replacing the pipe with modern steel pipe, external coatings, field welding, girth\nweld non-destructive testing, and in-place hydrostatic testing methods.\nBased on the information submitted by TCPL-ANR and PHMSA's analysis of the technical,\noperational, and safety issues, PHMSA finds that granting this special permit to TCPL-ANR to\noperate segments of its natural gas transmission pipelines now in Class 3 locations, at the current\nMAOP, would be inconsistent with pipeline safety.\n'JUL 16 20lD\nCompleted in Washington DC on: ____________ _\nPrepared By: PHMSA - Engineering and Emergency Support","truncated":false,"body_characters":14590}