{"operation":"document","citation":"0900006480e92734","title":"U.S. DOT/PHMSA - Response to Request for Special Permit","source_type":"rulemaking","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":null,"effective_on":null,"summary":"PHMSA’s letter (Sept. 1, 2009 Attachment A) sets interim inspection, excavation, testing, removal, remediation, and monitoring requirements that MEP must meet before operating Class 1 pipe above 72% SMYS up to 80% SMYS. Key elements include high-resolution deformation tool runs, removal of pipe joints expanded over specified thresholds (notably >1.50% with elastic loading), mechanical property testing of excavated or removed pipe, calibration digs, limits on class-change ‘one class bump’ at locations with >1.0% expansion until a fitness-for-service plan is accepted, prescribed in-line inspection and survey intervals after operation at the alternative MAOP, enhanced anomaly response/repair criteria tied to failure pressure ratios and percent wall loss, and incorporation of these interim guidelines into MEP’s Operations and Maintenance procedures. The authorization to operate up to 80% SMY","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e92734.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e92734.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480e92734","source_url":"https://downloads.regulations.gov/PHMSA-2007-27842-0012/attachment_1.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\n1200 New Jersey Ave, S.E.\nSafety Administration\nPipeline and Hazardous Materials\nWashington, D.C. 20590\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nMr. M. Dwayne Burton\nVice President, Operations and Engineering\nMidcontinent Express Pipeline, LLC\nOne Allen Center\n500 Dallas St\nSuite 1000\nHouston, TX 77002\nRE: Midcontinent Express Pipeline, LLC (MEP); Special Permit: PHMSA-2007-27842\nDear Mr. Burton:\nOn August 25, 2009, you wrote to the Pipeline and Hazardous Materials Safety Administration\n(PHIMSA) requesting to increase the operating pressure of the Midcontinent Express Pipeline,\nLLC (MEP) to a pressure corresponding to a maximum hoop stress of 80% of the specified\nminimum yield strength (SMYS) in accordance with the alternative maximum allowable\noperating pressure (MAOP) Special Permit, Docket No. PHMSA-2007-27842. MEP currently\noperates at a pressure corresponding to 72% SMYS. Further, under separate cover, MEP\nsubmitted documents supporting the request.\nAfter a thorough review of the documents and consideration of MEP assertions in your August\n25, 2009 letter, this letter responds to your request, providing guidance to attain operating\npressures above 12% SMYS up to 80% SMYS. The requirements contained herein in\n\"Attachment A\"- Integrity Verification of Pipe Properties - September 1, 2009 apply to the\npipeline segments experiencing expansion above 0.60% for 42-inch pipe and 0.75% for pipe\nequal to or less than 36-inch diameter.\nOn May 21, 2009, PHMSA issued an advisory bulletin (PHMSA-2009-0148), for the Potential\nfor Low and Variable Yield and Tensile Strength and Chemical Compositions in High Strength\nLine Pipe (ADB), recommending operators to investigate if certain pipelines contain pipe joints\nnot meeting minimum specification requirements (74 FR 23930). The observance of pipe\nexpansions on recently constructed natural gas projects including Kinder Morgan projects led to\nPHMSA's issuance of the ADB. PHMSA remains concerned about expansion deformations\nexceeding 1.5% and is particularly concerned with any situation where expansion is present in\ncombination with pipe not meeting mechanical requirements under API 5L. In fact, the basis for\nthe design formula contained in 49 CFR section 192.111 contains specific material property\nrequirements which provides the basis for establishing MAOP under 49 CFR section 192.619.\n\n<<<PAGE 2>>>\n\n2\nTherefore, an operator cannot afford to only consider the amount of expansion when reviewing\npipeline in-line inspection deformation tool results since expansion may also be evidence of low\nyield or tensile strength line pipe. Until further studies are complete, PHMSA believes that a\nconservative approach is necessary that requires the operator to remove excessive pipe expansion\nanomalies along with performing mechanical testing to confirm if yield strength is a concern. To\nthis end, PHMSA requests MEP to confirm if the following interim guidelines in \"Attachment A\n- Integrity Verification of Pipe Properties\" dated September 1, 2009 were met for the MEP\npipeline.\nMEP must implement all special permit conditions in PHMSA-2007-27842, for the special\npermit pipeline segments. All DCVG/ACVG surveys must be conducted in accordance with the\nspecial permit conditions. The DCVG/ACVG surveys and the pipe coating remediation must be\ncompleted within 6 months after operating at the alternative MAOP (above 72% SMYS up to\n80% SMYS operating pressure).\nContingent upon your certification and documentation of compliance with the attached interim\nguidelines, PHMSA will grant authorization to increase the operating pressure of the designated\nMEP pipeline to a pressure corresponding to 80% SMYS. Please be advised that the interim\nSincerely,\nAlan K. Mayberr\nDirector, Engineering and Emergency Support\nOffice of Pipeline Safety\nCc:\nJeffrey Wiese\nJohn Gale\nLinda Daugherty\nSteve Nanney\nRod Seeley\n\n<<<PAGE 3>>>\n\n3\n\"ATTACHMENT A\"- Integrity Verification of Pipe Properties - September 1, 2009\nMEP must remove all pipe joints expanded in excess of 1.50% in diameter, with elastic loading\nincluded (i.e., taking into account the pressure on the pipe at the time of measuring the\ndeformation), or the commensurate adjusted expansion without elastic loading on the pipe when\nexpansion is verified in the field without pressure on the pipe.\nMEP must also comply with the following requirements prior to operation of Class 1 pipe above\n72% specified minimum yield strength (SMYS):\n1) Unless already completed, MEP must run a deformation tool through all pipeline\nsegments on the MEP Pipeline. MEP must use a high resolution deformation tool in lieu\nof a geometry tool to address the threat of low strength, expanded pipe.\nThe deformation tool must include multi-finger sensors that contact the pipe\ninternal diameter and have an accuracy of +/- 1% or less to identify expanded\npipe and dents.\nThe results of all deformation tool run results for\nexpanded pipe and dents should be analyzed and submitted to the appropriate\nPHMSA Regional Director. All pipe exhibiting an indicated diameter greater\nthan 0.60% or 0.75% (based upon pipe diameter 42\" or ≥ 36\" per API SL\nabove the nominal pipe diameter should be noted on the report of potential\ndeformations.\nExpanded pipe is defined as pipe exhibiting an indicated\ndiameter greater than 0.60 % or 0.75% (based upon pipe diameter 42\" or ≥\n36\" per API 5L) above the nominal or actual rolled pipe diameter.\nMEP must ensure that all deformation tool results are not masked by the\napproach used to calculate and compare expanded versus non-expanded pipe\nand the percentage of expansion. MEP must employ procedures to review and\ncompare deformation tool results with other pipe joint diameters to ensure an\nentire pipe joint is not expanded\nMEP must review with the appropriate PHMSA Regional Director, the\ndeformation tool reports. This analysis must consider pipe properties and\nproperty distributions, hydrostatic test pressures and reported test behavior,\nand pipe end to center variations. Based on local pressure and expecter\n›ehavior, any expansion exceeding the diameter by more than 1.5% witl\nelastic loading (or the commensurate adjusted expansion with elastic loading\non the pipe, when expansion is verified in the field without pressure on the\npipe) must be investigated by excavation to determine actual expansion, wall\nthinning and, if necessary, to verify pipeline special permit segments: tensile\nstrength, yield\nstrength, elongation, chemical composition, carbon\nequivalent/Pcm, hardness, Charpy - shear area and absorbed energy with full\nCharpy curves, and drop weight tear test (DWTT) properties (\"properties\n\n<<<PAGE 4>>>\n\n4\n2. Pipe joints with expansions ≥ 1.5% with elastic loading must be removed and\nconfirmed for strength serviceability as follows:\na. Perform \"properties test\" in the transverse direction. MEP must take 2 sets at\n3 locations along the pipe section of \"properties test\" for each removed pipe\njoint. The expanded pipe joint should be mapped to identify expanded pipe\nminimum and maximum wall thicknesses with at least 10 thickness readings\nmapped showing location on the pipe.,\nb. If expanded pipe properties tests in (a.) do not meet special permit\nrequirements, MEP must:\ni. Perform \"properties test\" of at least two (2) expanded pipe joints over\n1% with elastic loading and two (2) non-expanded pipe samples from\nthe steel/pipe supplier of expanded pipe (same OD, wall thickness,\nGrade, weld seam, steel supplier, pipe manufacturer and rolling\ncampaign) to confirm pipe properties. The non-expanded pipe joints\nmay be from in service or spare pipe inventory.\nii. Submit remediation plans or a technical justification (fitness for\nservice plan) to PHMSA on how reduced strength pipe meets 49 CFR\nPart 192.105.\nc. If the deformation tool run in Condition 1 shows no expanded pipe above\n1.5% expansion or the pipe \"properties test\" in Condition 2. b above shows no\nreduced pipe properties, MEP must excavate two (2) expanded pipe joints\nwith expansion above 1% with elastic loading to determine if there is wall loss\nor thinning that is detrimental to safe operations, prior to operating at the\nalternative MAOP. Any wall loss that would reduce the pipe segment\noperating pressure in accordance with §§ 192.103, 192.105 192.111, 192.112\nand 192.619 must be remediated. If these excavations show wall loss below\nnominal wall thickness, MEP must continue to excavate and remediate\nexpanded pipe joints above 1% with elastic loading until there are no\ndetrimental wall loss pipe joints in service.\nAll deformation tool results, for an initial run on a \"pipeline segment\", must be\nconfirmed with at least two calibration digs to validate anomaly sizes and tool\nevaluations and remediation.\naccuracy. Tool inaccuracies after validation must be considered into expanded pipe\n4.\nMEP must not use the \"one class bump\" for class change locations where expansions\nexceeded 1.0% with elastic loading until completion of a \"fitness for service\" plan\nand acceptance by PHMSA.\nThe interim guidelines contained herein must be reviewed with PHMSA, Director of\nEngineering and Emergency Support and PHMSA, Southern and Southwestern\nRegional Directors at the completion of the investigation, pipe properties testing, and\n\"fitness for service\" plan for technical soundness (including a determination of the\nproper pipe grade to meet § § 192.103, 192.105, 192.111, 192.112 and 192.619 in\ndetermining the alternative MAOP or MAOP of the pipeline segment)\n\n<<<PAGE 5>>>\n\n5\nMEP must perform the following actions where deformation tool runs indicate expansion\ngreater than 1.5% or in pipeline segments with low strength pipe.\n6. Conduct a re-inspection and remediation of the pipelines with deformation and high\nresolution magnetic flux leakage (MFL) tools to evaluate for metal loss and\nexpansion anomalies:\na. Within 36 months of operating above 72% SMYS up to 80% SMYS on any\ngiven pipeline segment with expanded or remediated pipe.\nb. Schedule subsequent in-line inspection with MFL tools (ILI) and close\ninterval survey re-inspections for the pipelines based on failure pressure ratios\nintervals.\n(FPKs) calculated after the first re-inspection, but not to exceed 5 year\nC.\nManage plain dents (in accordance with ANSI B31.8 and § 192.933) not to\nexceed 6% total strain in pipe body and 2% strain contiguous with weld for\nfuture ILl deformation and geometry tool runs\n7. Pipeline operations: Pipeline may be operated up to the alternative MAOP (80%\nSMYS), after successful completion of the following interim guidelines:\n\"Properties tests,\" and a technical review including review of pipe test\npressures to confirm that pipe property results meet API SL\nspecifications and 49 CFR Part 192 requirements for the alternative\nMAOP or MAOP. The \"properties tests\" must show conformance\nwith API 5L and alternate MAOP or MAUP criteria.\ni. Finise foser bic treplan to operate lining alter ate Mily thor A tre\nbased upon pipe \"properties test\" and any effects of elevated test\npressure due to pipe elevation differences may have had on pipe\nexpansion.\nili. The technical documentation of all \"properties test\" findings or\n\"fitness for service\" plans must be submitted by MEP to PHMSA,\nb. For pipeline operations, MEP must run:\ni. ILI initially within 3 years of operating at the alternative MAOP and\non a maximum 5 year interval thereafter. Anomalies must be evaluated\nand remediated based upon alternative MAOP or MAOP conditions,\nii. Conduct close interval surveys (CIS) and remediate pipe in each\npipeline segment in accordance with 49 CFR Part 192 on a periodic\nbasis, not to exceed 3 months of running ILI tools\nili. MEP must operate in accordance with the \"interim guidelines of this\ndocument\" until PHMSA has developed \"go-forward\" guidance on\nexpanded pipe removals based upon technical input from research and\nindustry. If the PHMSA technical and safety evaluation of pipe\nexpansion issues results in \"go-forward\" guidance that differs from\nthe requirements above, MEP must implement the PHMSA \"go-\n\n<<<PAGE 6>>>\n\n6\nforward\" guidance for the alternative MAOP or MAOP pipeline\nsegments.\n8. For expanded pipe only not meeting 49 CFR Part 192.105 and special permit\nrequirements, implement enhanced corrosion anomaly response and repair criteria:\na. Anomaly Response Time: Repair Immediately\n• Any anomaly within a pipeline segment operating up to 80% SMYS with\neither: (1) a failure pressure ratio (FPR) equal to or less than 1.15; (2) an\nanomaly depth equal to or greater than 50% wall thickness loss.\n• Any anomaly within a pipeline segment operating up to 72% SMYS with\neither: (1) a failure pressure ratio (FPR) equal to or less than 1.25; (2) an\nanomaly depth equal to or greater than 50% wall thickness loss.\n• Any anomaly within a pipeline segment operating up to 60% SMYS with\neither: (1) an FPR equal to or less than 1.40; (2) an anomaly depth equal to\nor greater than 50% wall thickness loss.\n• Any anomaly within a pipeline segment operating up to 50% SMYS with\neither: (1) an FPR equal to or less than 1.5; (2) an anomaly depth equal to\nor greater than 50% wall thickness loss.\nb. Anomaly Response Time: Repair Within One Year\n• Any anomaly within a pipeline segment operating at up to 80% SMYS\nwith either: (1) an FPR equal to or less than 1.25; (2) an anomaly depth\nequal to or greater than 40% wall thickness loss.\n• Any anomaly within a pipeline segment operating at up to 72% SMYS\nwith either: (1) an FPR equal to or less than 1.39; (2) an anomaly depth\nequal to or greater than 40% wall thickness loss.\n• Any anomaly within a pipeline segment operating at up to 60% SMYS\nwith either: (1) an FPR equal to or less than 1.67; (2) an anomaly depth\nequal to or greater than 40% wall thickness loss.\n• Any anomaly within a pipeline segment operating at up 50% SMYS with\neither: (1) an FPR equal to or less than 2.0; (2) an anomaly depth equal to\nor greater than 40% wall thickness loss.\nc. Anomaly Assessment Methods:\n• MEP must use the most conservative anomaly repair method and take into\ncount a lowest pipe proponyes basell pon in a algoro ton,\nsteel source, pipe manufacturer, wall thickness, and grade.\n9. MEP must review and document all areas along the pipeline to ensure pipe loadings\nat all crossings meet combined stress limits for all equipment, farm machinery, roads,\nhighways, and railroads to maintain Special Permit design factors based upon the\nlowest pipe strengths for that pipe grade, wall thickness, design factor, maximum\nloadings, and depth of cover. MEP must add a provision in its Operations and\nMaintenance Manual for annual reviews to account for combined stresses.\n10. MEP's Operations and Maintenance Procedures must include the interim guidelines\nof this document within three months of operating at the alternative MAOP. Submit\nand must be certified by an officer of MEP to the PHMSA, Director of Engineering\nDirectors.\nand Emergency Support and the PHMSA Southern and Southwestern Regional","truncated":false,"body_characters":15016}