{"operation":"document","citation":"0900006480e91c2f","title":"U.S. DOT/PHMSA - Special Permit Analysis & Findings","source_type":"rulemaking","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":null,"effective_on":null,"summary":"PHMSA describes the special permit application (PHMSA-2008-0330) submitted November 13, 2008, for two segments on Columbia Gulf’s 30-inch Mainline 200 and 36-inch Mainline 300 in Wilson County, TN, where class locations changed to Class 3, and explains the special permit scope, required conditions, evaluative criteria, enforcement history considerations, and PHMSA’s conclusion that granting the special permit under specified conditions is consistent with pipeline safety. Scope includes the two 1,600-foot special permit segments and ~50.30 mile special permit inspection areas on each pipeline. Limitations and conditions noted include threshold requirements, additional inspections and surveys (ILI, DCVG/ACVG, CIS, SCCDA), girth weld records or leakage surveys, coating/cathodic protection remediation, periodic reassessments, training of senior management and technical staff, and PHMSA’s use","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91c2f.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91c2f.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e91c2f","source_url":"https://downloads.regulations.gov/PHMSA-2008-0330-0003/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:\nPHMSA-2008-0330\nRequested By:\nColumbia Gulf Transmission Company'\nDate Requested:\nNovember 13, 2008\nCode Sections:\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 Columbia\nGulf Transmission Company (Columbia Gulf), to discuss any relevant public comments received\nwith respect to the application, to present the engineering/safety analysis of the special permit\napplication, and to make findings regarding whether the requested special permit should be\ngranted and if so under what conditions.\nPipeline System Affected:\nThis special permit applies to two natural gas pipeline segments on the 30-inch Mainline 200 and\n36-inch Mainline 300 pipelines operated by Columbia Gulf in Wilson County, TN, where\nchanges have occurred from original Class 1 locations to Class 3 locations or a Class 2ª location\nto Class 3 location. This special permit allows Columbia Gulf to continue to operate the two\npipeline segments at their current maximum allowable operating pressure (MAOP) of 1008\npounds per square inch gauge (psig) for the 30-inch Mainline 200 and 1008 psig for the 36-inch\nMainline 300.\nColumbia Gulf Transmission Company is owned and operated by NiSource Gas Transmission and Storage\n(NGT&S).\nlocation in accordance with a § 192.611(a) hydrostatic test.\n\" The Class 3 location special permit segments were originally a Class 1 location area that was upgraded to a Class 2\n\n<<<PAGE 2>>>\n\n2\nThis special permit applies to the special permit segments defined as follows using the Columbia\nGulf pipeline survey stationing (Sta.):\n• Special Permit Segment I: 30-inch Mainline 200 - 1600 feet, Sta. 3030+43 to Sta. 3046+43\n• Special Permit Segment 2: 36-inch Mainline 300 - 1600 feet, Sta. 3025+55 to Sta. 3041+55\nThis special permit applies to the special permit inspection area(s) defined as follows using the\n30-inch Mainline 200 and the 36-inch Mainline 300 pipeline stationing as a reference:\nSpecial permit inspection areas - means the area that extends 220 yards on each side of the\ncenterline of each pipeline along the entire length of the Columbia Gulf 30-inch Mainline 200\nand the 36-inch Mainline 300 pipelines defined as follows:\n• Special Permit Inspection Area 1: 30-inch Mainline 200 - Sta. 1710+43 to Sta. 4366+43,\n(50.30 miles)\n• Special Permit Inspection Area 2: 36-inch Mainline 300 - Sta. 1705+55 to Sta. 4361+55,\n(50.30 miles)\nNote: The special permit inspection area extends approximately 50.30 miles along each pipeline\n(Mainlines 200 and 300) with overlapping areas and includes the special permit segment.\nThe special permit inspection area is located in Williamson, Davidson, Wilson, Sumner, and\nTrousdale Counties, TN. The special permit inspection area extends from approximately 25\nmiles upstream of the special permit segments to approximately 25 miles downstream of the\nspecial permit segments, a total of approximately 50.30 miles on each pipeline.\nSpecial Permit Request:\nColumbia Gulf submitted an application to PHMSA on November 13, 2008, for a special permit\nseeking relief from the Federal pipeline safety regulations in 49 CFR § 192.611 for two segments\non the 30-inch Mainline 200 and the 36-inch Mainline 300 natural gas transmission pipelines,\nwhere a change has occurred from a original Class 1 location per 192.611, to a Class 3 location\nin Wilson County, Tennessee. This special permit allows Columbia Gulf to continue to operate\nthe pipeline segments at their current maximum allowable operating pressure (MAOP) of 1008\npounds per square inch gauge (psig) on the Mainlines 200 and 300 pipelines. The Federal\n\n<<<PAGE 3>>>\n\n3\npipeline safety regulations in 49 CFR § 192.611, require natural gas pipeline operators to\nconfirm or revise the MAOP of a pipeline segment after a change in class location. A special\npermit would allow Columbia Gulf to continue to operate each of the two special permit\nsegments on the 30-inch Mainline 200 and the 36-inch Mainline 300 at its existing MAOP\ndespite a change in class location. Columbia Gulf did not include the Mainline 100 pipeline in\nthe special permit request.\nIn its application, Columbia Gulf suggested that the two special permit segments be included in\nseparate special permit inspection areas. The special permit inspection areas on the Mainline\n200 and the Mainline 300 pipelines, would begin approximately 25 miles upstream of the Special\nPermit Segment and end approximately 25 miles downstream of Special Permit Segment for a\ntotal of 50.30 miles.\nPublic Notice:\nOn January 23, 2009, PHMSA posted a notice of this special permit request in the Federal\nRegister (74 FR 4298). PHMSA did not receive any comments for or against this special permit\nrequest as a result of this notice. The request letter, Federal Register notice and all other\npertinent documents are available for review in Docket No. PHMSA-2008-0330 in the Federal\nDocket Management 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\nspecial permits. First, certain threshold requirements must be met for a pipeline section 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 (IMP) elements are evaluated as significant criteria.\nThese significant criteria are presented in matrix form and can be reviewed in the FDMS, Docket\nNumber PHMSA-RSPA-2004-17401. Third, such special permits will only then be granted\nwhen pipe conditions and the operator's active integrity management program provides a level of\nsafety greater than or equal to a pipe replacement or pressure reduction. As described later in\nthis document, in addition to technical review, PHMSA focused heavily on enforcement history\nin reviewing this application.\n\n<<<PAGE 4>>>\n\n4\nThreshold Requirements: Each of the threshold requirements published by PHMSA in the\nJune 29, 2004, FR notice is discussed below in regards to the Columbia Gulf special permit\npetition.\n1) No pipeline segments in a class location changing to Class 4 location will be considered.\nThis special permit request is for two segments of the Columbia Gulf pipeline system where\na class location change has occurred from Class 1 or 2 to Class 3. Columbia Gulf has met\nthis requirement in details submitted in application.\n2) No bare pipe will be considered. These Columbia Gulf special permit segments are coated\nwith coal tar. Columbia Gulf has met this requirement in details submitted in application.\n3) No pipe containing wrinkle bends will be considered. There are no wrinkle bends in the\nspecial permit segments. Columbia Gulf has met this requirement in details submitted in\napplication.\n4) No pipe segments operating above 72% of the specified minimum yield strength (SMYS)\nwill be considered for a Class 3 special permit. These special permit segments operate at or\nbelow 72% SMYS. Columbia Gulf has met this requirement in details submitted in\napplication.\n5) Records must be produced that show a hydrostatic test to at least 1.25 x MAOP and 90% of\nSMYS. Columbia Gulf has met this requirement in details submitted in application.\n6) In-line inspection (ILI) must have been performed with no significant anomalies identified\nthat indicate systemic problems. Columbia Gulf has met this requirement in details\nsubmitted in application.\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 areas must be\ninspected according to Columbia Gulf's integrity management program and periodically\ninspected with an in-line inspection technique. The special permit inspection areas are\napproximately 50.3 miles long on both the Mainline 200 and Mainline 300 pipelines. This\nspecial permit will be issued contingent upon Columbia Gulf's incorporation of the two\nspecial permit segments in its written integrity management program as \"covered segments\"\nin a \"high consequence area\" (HCA) per 49 CFR § 192.903.\n\n<<<PAGE 5>>>\n\n5\nThe two special permit segments meet the seven threshold requirements. Additional ILI tool\nruns will be required in the special permit conditions.\nCriteria Matrix: The original and supplemental data submitted by Columbia Gulf for the two\nspecial permit segments have been compared to the class location change special permit criteria\nmatrix. The two special permit segments falls in the probable acceptance column of the criteria\nmatrix for all criteria except for:\nPossible Acceptance: Pipe material (low or unknown toughness), pipe coating\n(coal tar), and pipe manufacture (1963 and 1968, DSAW).\nb. Requires substantial justification: Columbia Gulf has no records of performing\nnon-destructive testing of girth welds, direct assessment (ECDA and SCCDA),\nand has outstanding inspection findings from a CAO on its pipelines. Moreover,\nthe enforcement history for Columbia Gulf indicates outstanding inspection\nfindings from Corrective Action Orders (CAO) on its pipelines.\nThe data findings below fall within the \"probable acceptance\" or the \"requires substantial\njustification\" columns of the criteria matrix:\n1) Pipe design and construction, including pipe manufacture, material and design stress:\nMainline 200 and Mainline 300 pipelines were installed in 1963 & 1968 and consists of\nAmerican Petroleum Institute Specification 5L, Specification for Line Pipe (API 5L),\nsubmerged arc welded (SAW), X-60 steel pipe manufactured by National Tube and double\nsubmerged arc welded (DSAW), X-65 steel pipe manufactured by U.S. Steel. These pipes\nare of unknown toughness but Columbia Gulf has addressed this risk in their integrity\nmanagement plan. Moreover, none of these pipelines have any known systemic\nmanufacturing issues. This places the two special permit segments in the \"possible\nacceptance\" column of the criteria matrix\n2) Girth welds: Columbia Gulf does not know if the girth welds were nondestructively tested\nduring initial construction and has been unable to locate any supporting documentation thus\nfar. This places both special permit segments in the \"requires substantial justification\"\ncolumn of the criteria matrix. While there have been no reported problems with girth welds\n\n<<<PAGE 6>>>\n\non these pipelines in the special permit inspection area, to address the girth weld issue this\nspecial permit will include a condition requiring Columbia Gulf to provide girth weld\ninspection records, or to certify that there have been no in-service leaks or breaks in the girth\nwelds on Mainline 200 and Mainline 300 pipelines in the special permit inspection area. In\nthe absence of records, Columbia Gulf will also be required to perform leakage surveys using\nleak detection equipment along the entire length of each special permit segment within 60\ndays atter the grant of this special permit. Columbia Gulf must prepare and follow a girth\nweld remediation plan for both special permit segments.\n3) ILl Time Frame: Mainline 200 was last inspected with a high-resolution MFL and a\ngeometry tool in July 2004, and in October 2005. Mainline 300 was last inspected with a\nhigh-resolution MFL and a geometry tool in July and August 2004. This places both special\npermit segments in the \"possible acceptance\" column of the criteria matrix. To address ILI\nissues, this special permit will be conditioned upon Columbia Gulf treating both special\npermit segments as a \"covered segment\" in a \"high consequence area\" per 49 CFR\n$ 192.903. The special permit conditions specify the time intervals between ILI runs.\n4) Direct Assessment (ECDA & SCCDA): Columbia Gulf has not completed an external direct\nassessment (ECDA) or a stress corrosion cracking assessment (SCCDA) of the special permit\nsegments. This places both special permit segments in the \"requires substantial justification\"\ncolumn of the criteria matrix. To address these issues, this special permit will be conditioned\nupon Columbia Gulf completing a Direct Current Voltage Gradient (DCVG) survey or an\nAlternating Current Voltage Gradient (ACVG) survey; a close interval survey (CIS); and a\nSCCA along Mainline 200 and Mainline 300 pipelines not later than one year after the\ngrant of this special permit.\nPHMSA has determined that imposing the special permit conditions will address these concerns\nand provide equivalent safety for these areas.\nOperational Integrity Compliance: PHMSA has reviewed this special permit request to ensure\nthat integrity threats to the pipeline in the special permit segments and special permit inspection\nareas are addressed in the operator's operations and management plan (O&M Plan). Columbia\nGulf must have a systematic program to review and remediate the pipeline for safety concerns.\n\n<<<PAGE 7>>>\n\n7\nAdditional operational integrity review and remediation requirements will be required by this\nspecial permit for this special permit segment class location change. The pipeline operational\nintegrity requirements are to ensure that the operator has an ongoing program to locate and\nremediate safety threats. Some of these threats to integrity and safety are the pipe coating\nquality, cathodic protection effectiveness, operations damage prevention program for third party\ndamage, weld seam and girth weld integrity, anomalies in the pipe steel, and material and\nstructures either along, or near the pipeline that could cause the cathodic protection system to be\nineffective. PHMSA carefully designed a comprehensive set of conditions that Columbia Gulf\nwould be required to meet in order for the special permit to be granted. Among other things, the\nconditions include:\n• A close interval survey to determine the effectiveness of the cathodic protection system\nmust be performed within the special permit segments and special permit inspection area\nand all areas with inadequate cathodic protection must be remediated.\n• A coating survey to determine the quality of the pipe coating must be conducted and in-\neffective coating areas must be remediated within the special permit segments.\n• Stress corrosion cracking surveys on the pipeline will be required to ensure that the pipe\nsteel is not cracking due to the effects of high and near neutral pH SCC, within the\nspecial permit segments and special permit inspection area.\n• The latest methods of damage prevention must be incorporated by the operator, such as\nthe best practices of the Common Ground Alliance (CGA), within the special permit\ninspection areas.\n• Interference currents from electric transmission lines and other interfering structures in\nthe special permit segments and special permit inspection area must be identified,\ncontrolled and mitigated by conducting surveys and installing grounding systems where\nrequired.\n• An analysis of pipeline field coated girth weld coatings that could have shielding coatings\nthat could cause corrosion of the pipe steel must be undertaken in the special permit\nsegments and special permit inspection area, and indications from in-line inspection logs\nshowing 30% or greater wall loss corrosion on shielding or unknown coatings must be\nexposed and evaluated.\n\n<<<PAGE 8>>>\n\n8\n• Anomalies and dents on the pipeline must be repaired based upon the special permit\nrepair criteria.\n• Girth welds in the special permit segments must have had a non-destructive test plan\nduring construction, or a quality review and remediation program must be implemented\nby the pipeline operator.\n• All shorted casing (either metallic or electrolytic) at road crossings and railroad crossings\nin the special permit segments and special permit inspection areas must be cleared to\nprevent corrosion.\n• Pipeline longitudinal seams within the special permit segments and special permit\ninspection area must have an engineering analysis to determine if there are any threats\nand remediated if integrity threats are determined.\n• Periodic close interval surveys and in-line inspection surveys (pipeline internal surveys to\ndetermine corrosion in the pipeline) must be performed on the special permit segments\nand special permit inspection area at the applicable reassessment intervals.\n• Training of Senior Executive Management (Executive Vice President and Group CEO,\nVice President of Operations and Vice President of Engineering), Engineering and\nOperations Managers and Supervisors, and Technical Personnel (Engineers and\nOperations Technicians) in natural gas pipeline integrity management, corrosion control,\nand anomaly evaluation, validation and repairs to meet Part 192 and these special permit\nconditions.\n• Columbia Gulf must maintain an open and transparent relationship with PHMSA to\nensure effective implementation of special permit conditions, and must make records and\napplicable information available to PHMSA upon request. Columbia Gulf must fully\nexecute the special permit conditions and proactively respond to findings encountered\nthroughout implementation.\nThe special permit will contain numerous conditions to ensure Columbia Gulf meets or exceeds\nthe threshold requirements with equivalent safety, and to ensure that granting the special permit\nwill not be inconsistent with safety.\n\n<<<PAGE 9>>>\n\n9\nPast Enforcement History - 2000 through 2009\nThe enforcement history is an important reflection of how Columbia Gas has been observed to\nfollow pipeline safety regulations, and was a major area of focus for the review of this\napplication. A review of PHMSA enforcement actions against Columbia Gulf and Columbia\nGas from 2000 through 2009, shows the following enforcement actions against the companies.\nThe existence of these actions requires substantial justification pursuant to the Class Location\nSpecial Permit Criteria, as confidence is necessary that conditions contained in the special permit\nwould be closely followed. Columbia Gulf and Columbia Gas are owned and operated by\nNiSource Gas Transmission and Storage (NGT&S).\nBelow is a listing of PHMSA closed enforcement matters of all types in all PHMSA Regions for\nColumbia Gulf and Columbia Gas from 2000 through 2009:\n• Letters - of Concern or Warning - 30 matters\n• Notices - of Amendment or of Probable Violation - 20 matters\n• Fines - $1,221,000 collected, additional penalties have been proposed\nThe preceding enforcement history summary reveals a number of compliance issues, including\npipeline maintenance issues.\nPHMSA initially was inclined to deny this special permit application based on the enforcement\nhistory. PHMSA notified Columbia Gulf senior management of the agency's enforcement\nhistory concerns prior to taking final action to deny the special permit application. Columbia\nGulf acknowledged performance issues and requested a meeting with PHMSA, to explain\nimprovements the company had made to its pipeline safety programs that were designed to\nimprove compliance with the regulations. In a meeting with PHMSA on July 28, 2009,\nColumbia Gulf's senior management gave a presentation entitled \"Integrity Management\nImprovements,\" which described changes made by Columbia Gulf to improve compliance with\npipeline safety regulations. In an August 27, 2009, meeting with PHMSA, Columbia Gulf\npresented its \"Special Permit Management Plan,\" which described an organizational structure\nand plan to manage special permit compliance. The presentations from the meetings listed above\nare posted on the docket.\n\n<<<PAGE 10>>>\n\n10\nIn analyzing whether or not to grant a special permit, PHMSA considered the organizational,\nmanagement and procedural changes described by Columbia Gulf. PHMSA believes that some\nof these changes are positive and necessary for pipeline safety, and will incorporate additional\nconditions into the special permit to capture the company's commitments. These additional\nconditions will require Columbia Gulf (NGT&S) Executive Management, Mid-Level\nManagement and Technical Support Personnel to make improvements in integrity management,\ntraining, and operating procedures. The additional conditions include:\nColumbia Gulf (NGT&S) must complete the training of Senior Executive Management\n(Executive Vice President/Group CEO, Vice President of Operations and Vice President of\nEngineering), Engineering and Operations Managers and Supervisors, and Technical Personnel\n(Engineers and Operations Technicians) in natural gas pipeline integrity management, corrosion\ncontrol, anomaly evaluation, validation and repairs to meet Part 192 and the special permit\nconditions as follows:\n• Columbia Gulf Senior Executive Management Level Commitment to:\na) Execution of Special Permit Requirements for Class Location Changes in\naccordance with letter from Mr. Chris Helms, Executive Vice President and Group\nCEO, of NGT&S (Columbia Gulf) to PHMSA dated September 21, 2009 and\nb) completion of all outstanding Corrective Action Orders (CAO) on the Columbia\nGulf System.\n• Columbia Gulf (NGT&S) must maintain a transparent relationship with PHMSA to\nensure implementation of all conditions.\n• Columbia Gulf 's Executive Vice President/Group CEO, will require letters of\ncommitment from responsible employees throughout Columbia Gulf (NGT&S),\nrequiring that these individuals commit in writing to specific special permit\nconditions, to reinforce and demonstrate the full commitment to compliance with the\nspecial permit throughout the organization.\nPHMSA has determined that imposing the special permit conditions summarized in this\ndocument will ensure that granting the special permit will not be inconsistent with safety.\n\n<<<PAGE 11>>>\n\n11\nFindings:\nBased on the information submitted by Columbia Gulf and PHMSA's analysis of the technical,\noperational, and safety issues, and given the conditions that will be imposed in the special\npermit, PHMSA finds that granting this special permit to Columbia Gulf to operate special.\npermit segments of the Mainline 200 and 300 natural gas transmission pipelines at the current\nMAOP, where a change in class location has occurred from an original Class 1 location to a\nClass 3 location is consistent with pipeline safety.\nCompleted in Washington DC on:\nAPR 1 3 2010\nPrepared By: PHMSA - Engineering and Emergency Support","truncated":false,"body_characters":22797}