{"operation":"document","citation":"0900006480eb58c3","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":"Document conclusions, scope and key conditions summarized from the application and PHMSA analysis: - Conclusion: \"PHMSA finds that granting this special permit to TCPL is inconsistent with pipeline safety.\" (passage id: regulations-gov-attachment-0900006480eb58c3-node-9) - Purpose and request: PHMSA prepared this analysis to \"describe the facts of the subject special permit application... to discuss any relevant public comments... to present the engineering/safety analysis... and to make findings regarding whether the requested special permit should be granted and if so under what conditions.\" The applicant (TransCanada Pipelines Limited, operator of ANR Pipeline Company) requested relief from 49 CFR § 192.611(a) to \"allow TCPL to continue to operate the one (1) pipeline segment at its current maximum allowable operating pressure (MAOP) of 1050 pounds per square inch gauge (psi g)\" after","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480eb58c3.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480eb58c3.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006480eb58c3","source_url":"https://downloads.regulations.gov/PHMSA-2010-0192-0007/attachment_1.pdf","body":"<<<PAGE 1>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (PHMSA)\nSpecial Permit Analysis and Findings\nSpecial Permit Information:\nDocket Number: PHMSA-20 1 0-0 192\nPipeline Operator: TransCanada Pipelines Limited, operator of ANR Pipeline Companyl\nDate Requested: June 24,2010\nCode Section(s): 49 CFR § 192.611(a)\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 (TCPL), operator of the ANR Pipeline Company (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 request involves one (1) special permit segment along the 30-inch ANR\nLateral Loop 2-716 pipeline natural gas transmission pipeline in St. Martin Parish, Louisiana.\nThe special permit segment class location along the pipeline has changed from an original Class\n1 location to a Class 32 location.\nThis special permit, if granted, will allow TCPL to continue to operate the one (1) pipeline\nsegment at its current maximum allowable operating pressure (MAOP) of 1050 pounds per\nsquare inch gauge (psi g) for the 30-inch ANR Lateral Loop 2-716 pipeline.\nI ANR Pipeline Company is owned and operated by TransCanada Pipelines Limited.\n2 The Class 3 location special permit segment was originally a Class 1 location that was upgraded to Class 2 location\nin accordance with 49 CFR § 192.611 (a) hydrostatic test.\n1\n\n<<<PAGE 2>>>\n\nThis special permit application applies to the special permit segment defined as follows using the\nANR Lateral Loop 2-716 pipeline mile post and valve section survey station references:\n• Special permit segment is defined as the 30-inch ANR Lateral Loop 2-716 pipeline\nbeginning at Mile Post 54.02 (V4 584+66 feet) between Valve Site 3 and Valve Site 4.\nThe special permit segment extends for 3,149 feet along 30-inch ANR Lateral Loop 2-\n176 and concludes at Mile Post 54.61 (V4 616+15), also between Valve Site 3 and Valve\nSite 4. The special permit segment is located in St. Martin Parish, Louisiana. (Note: The\nabove ground Mile Posts do not correlate exactly with the below ground pipe lengths.)\nThis special permit application applies to the special permit inspection area defined as the area\nthat extends 220 yards on each side ofthe centerline along the entire length of the 30-inch ANR\nLateral Loop 1-716 and 2-716 pipelines as follows:\n• Special permit inspection area is defined as the pipeline that begins at Mile Post 29.02 at\nValve Site 2 (V3 427+75 feet) on Loop 1-716 in Iberia Parish, Louisiana. The special\npermit inspection area extends through Valve Site 3 to Mile Post 43.03 where the ANR\npipeline lateral naming convention changes from Loop 1-716 to Loop 2-716 in st. Martin\nParish, Louisiana. The special permit inspection area continues along Loop 2-176 to\nValve Site 4 at Mile Post 55.52 where the ANR pipeline lateral naming convention\nreverts back to Loop 1-176, also in St. Martin Parish, Louisiana. The special permit\ninspection area continues along Loop 1-176 and concludes at Valve Site 5 at Mile Post\n70.78 (V5 00+00 feet) in St. Landry Parish, Louisiana.\nThe total length of the proposed special permit inspection area is approximately 41.76 miles and\nincludes the special permit segment.\nSpecial Permit Request\nTCPL submitted an application to PHMSA on June 24,2010, for a special permit seeking relief\nfrom the Federal pipeline safety regulations in 49 CFR 192.611(a) for one (1) segment of\nTCPL's 30-inch ANR Lateral Loop 2-716 natural gas transmission pipeline, where a change has\noccurred from a original Class 1 location to a Class 3 location in St. Martin Parish, Louisiana.\n2\n\n<<<PAGE 3>>>\n\nAs requested, this proposed special permit would allow TCPL to continue to operate the pipeline\nsegment at its current maximum allowable operating pressure (MAOP) of 1050 pounds per\nsquare inch gauge (psig). The Federal pipeline safety regulations in 49 CFR 192.611 (a) require\nnatural gas pipeline operators to confIrm or revise the MAOP of a pipeline segment after a\nchange in class location. A special permit, if granted, will allow TCPL to continue to operate the\nspecial permit segment at its existing MAOP's despite a change in class location.\nIn its application, TCPL suggested that the special permit segment be included in a special\npermit inspection area (see TCPL's application for the specifIc details). The special permit\ninspection area on the 30-inch ANR Lateral Loops 1-716 and 2-716 pipeline will begin\napproximately 25 miles upstream of the beginning of the special permit segment and\napproximately 16.17 miles downstream of the special permit segment. The special permit\ninspection area would be approximately 41.76 miles in length and will include the special permit\nsegment.\nPublic Notice:\nOn March 3,2011, PHMSA posted a notice of this special permit request in the Federal Register\n(76 FR 11853). The request letter, Federal Register notice, and all other pertinent documents are\navailable for review in Docket No. PHMSA-2010-0192 in the Federal Docket Management\nSystem (FDMS) located on the internet at www.Regulations.gov.\nPHMSA received no public comments on this application for a class location special permit.\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 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 elements are evaluated as signifIcant criteria.\nThese signifIcant criteria are presented in matrix form and can be reviewed in the FDMS, Docket\n3\n\n<<<PAGE 4>>>\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 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 one (1) segment of ANR's 30-inch Lateral Loop 2-716\n2) pipeline where a class location change has occurred from Class 1 to Class 3 location.\nNo bare pipe will be considered. This TCPL special permit segment is coated with coal tar\nenamel coating. TCPL has met this requirement.\n3) No pipe containing wrinkle bends will be considered. There are no wrinkle bends in the\nspecial permit segment. TCPL 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 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 records submitted show that the\nsection of the ANR's 30-inch Lateral Loop 2-716 pipeline containing the special permit\nsegment has been hydrostatically tested to 1450 psig, which is 1.38 xMAOP and 99% of\nSMYS. TCPL 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 2009, with no immediately actionable anomalies found. TCPL has met this\nrequirement.\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's integrity management program and periodically inspected\nwith an in-line inspection technique. The special permit inspection area is approximately\n4\n\n<<<PAGE 5>>>\n\n41.76 miles long, which is the entire length of the 30-inch ANR Lateral Loops 1-716 and 2-\n716 pipeline. This special permit is contingent upon TCPL's incorporation of the special\npermit segment in its written integrity management program as a \"covered segment\" in a\n\"high consequence area\" (HCA) per 49 CFR § 192.903.\nThe special permit segment meets the threshold requirements.\nCriteria Matrix: The original and supplemental data submitted by TCPL for the special permit\nsegment have been compared to the class location change special permit criteria matrix. The\nspecial permit segment falls in the probable acceptance column of the criteria matrix for all\ncriteria except for:\n• Possible acceptance - pipe manufacture, pipe coating, and depth of cover.\n• Requires substantial justification - none.\nThe data findings above fall within the \"possible acceptance\" columns of the criteria matrix and\nwould require some remediation measures as described below:\n1) Pipe manufacture: ANR's 30-inch Lateral Loop 2-716 pipeline was installed in 1972, and\n2) 3) consists of American Petroleum Institute Specification 5LX, Specification/or Line Pipe (API\n5LX), doubled submerged arc welded (DSA W), X-52 steel pipe manufactured by US Steel\nCorporation. This pipe is of sufficient toughness - 53 foot-pounds. The ANR Lateral Loop\n1-716 and 2-716 pipeline in the special permit inspection area has had no leaks or ruptures.\nThis pipe meets requirements for a special permit with no conditions for manufacture.\nPipe coating: The pipe is coated with coal tar enamel- Koppers 70-B primer and hi-melt\nenamel. If the special permit is granted, TCPL will be required to perform ILl assessments,\nanomaly repairs, close interval surveys, and stress corrosion cracking direct assessment\n(SCCDA) along the entire length of the ANR Lateral Loops 1-716 and 2-716 pipeline\nspecial permit inspection area and special permit segment according to the requirements of\n49 CFR § 192.929 within one (1) year after the grant of this special permit\nDepth of cover: TCPL has not conducted a pipeline depth of cover survey, and would be\nrequired to conduct a depth of cover survey in the special permit segment and implement\nremediation measures where depth of cover is reduced.\n5\n\n<<<PAGE 6>>>\n\nPHMSA has determined that imposing the special pennit conditions, if granted, would address\nthese concerns and provide equivalent safety for these areas.\nOperational Integrity Compliance:\nPHMSA reviewed this special permit request to ensure that integrity threats to the pipeline in the\nspecial permit segment and special permit area are in the operator's operations and management\nplan (O&M Plan) to provide a systematic program to review and remediate the pipeline for\nsafety concerns. Additional operational integrity review and remediation requirements will be\nrequired for this special permit segment class location change, if a special permit is granted. The\npipeline operational integrity requirements are to ensure that the operator has an ongoing\nprogram to locate and remediate safety threats. These threats to integrity and safety include pipe\ncoating quality, cathodic protection effectiveness, operations damage prevention program for\nthird party damage, weld seam and girth weld integrity, anomalies in the pipe steel, and material\nand structures either along or near the pipeline that could cause the cathodic protection system to\nbe ineffective. PHMSA carefully designs a comprehensive set of conditions that an operator\nwould be required to meet in order for the special permit to be granted. Among other things, the\nproposed conditions would include:\n• A close interval survey to determine the effectiveness of the cathodic protection system\nmust be performed within the special permit inspection area and all areas with\ninadequate 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 required to be remediated.\n• Stress corrosion cracking (SCC) surveys on the pipeline will be required to ensure that\nthe pipe steel does not contain cracks due to the effects of high and near neutral pH SCC.\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 area.\n• Interference currents from electric transmission lines and other interfering structures in\nthe special permit inspection area must be identified, controlled and mitigated by\nconducting surveys and installing grounding systems where required.\n6\n\n<<<PAGE 7>>>\n\n• An analysis of pipeline field coated girth welds that could have shielding coatings that\ncould cause corrosion of the pipe steel must be undertaken in the special permit segment\nand in-line inspection logs that indicate 30% corrosion indications on shielding or\nunknown coatings must be exposed and evaluated.\n• Anomalies and dents in the pipeline must be repaired, based upon the special permit\nrepair criteria.\n• Girth welds in the special permit segments must have been inspected to a non destructive\ntest plan during construction, or a quality review and remediation program must be\nimplemented by the pipeline operator.\n• All shorted casing at road crossings and railroad crossings in the special permit segments\n(either metallic or electrolytic) must be cleared to prevent corrosion.\n• Pipeline longitudinal seams within the special permit inspection area must have an\nengineering analysis to determine if there are any threats and remediated, if integrity\nthreats 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 segment at\nthe applicable reassessment intervals.\n• In-line tool (ILl) inspections must be conducted through the special permit segments and\nthe special permit inspection area, and anomaly findings remediated any in accordance\nwith the 49 CFR Part 192, Subpart 0, § 192.485, and the conditions of the special permit.\n• A depth of cover survey of the special permit segments must be conducted. Any pipe in\nthe special permit segment that does not meet 49 CFR § 192.327(a) must have additional\nsafety measures implemented in areas with reduced depth of cover.\nCompliance History - 2007 through 2011:\nA review ofPHMSA enforcement actions of ANR from February 22,2007, through May 24,\n2011, shows the following closed enforcement actions against TCPL. During this time interval,\nTCPL has owned and operated ANR (OPID 405).\n• Letters - of Concern or Warning - 4 matters closed\n• Notices - of Amendment or of Probable Violation - 1 matters closed\n• Collected Civil Penalties - $41,000 collected\n7\n\n<<<PAGE 8>>>\n\nThis enforcement history reveals a few compliance issues, including pipeline maintenance\nIssues. PHMSA would require TCPL to comply with Special Permit conditions to address these\nIssues.\nPHMSA reviewed the existing special permits issued to TGPL to ensure that TCPL is in\ncompliance with the conditions of any existing special permits issued to them. PHMSA found\nthat TGPL was not following all of the special permit conditions on the PNGTS3 24-inch\nmainline pipeline (PHMSA-RSPA-2003-15733) through-out the life of the special permit as\nfollows:\nSpecial Permit Condition 5: Findings, remediation, and documentation - Perform\nweekly aerial patrols and quarterly ground patrols over the entire 143.8 miles of the 24-\ninch pipeline. The ground patrols must include leak surveys on all Class 3 portions of the\npipeline using appropriate instrumented leak detection equipment.\nPHMSA review of compliance documents:\nTCPLIPNGTS did not meet the special permit conditions for performing weekly\naerial patrols and quarterly ground patrols.\n• TCPLIPNGTS stopped conducting weekly aerial patrols in July, 2006,\nthrough early 2010. Bi-weekly aerial patrols were performed from 2008\nthrough early 2010 .. PHMSA was not notified of this special permit\nmodification.\n• TCPLIPNGTS performed quarterly ground patrols until the 4th-quarter of\n2004, and annual ground patrols were conducted in 2005,2006, and 2007.\nQuarterly ground patrols were resumed in 2008. PHMSA was not notified\nof this special permit modification.\nPHMSA fmds that TCPLIPNGTS's lack of diligence in following all of the conditions of the\nexisting special permit to be inconsistent with pipeline safety.\n3 TGPL is operator of the PNGTS Pipeline Company and was issued special permit (PHMSA-RSPA-2003-15733)\non March 4, 2004.\n8\n\n<<<PAGE 9>>>\n\nFindings:\nTCP requested a special permit to operate the ANR 30-inch Lateral Loop 2-716, a natural gas\ntransmission pipeline, at the current MAOP where a change in class location has occurred from\nan original Class 1 location to a Class 3 location. Based on the information submitted by TCPL\nand PHMSA's analysis of the technical, operational, and existing special permit non-compliance\nissues on other TOPL operated pipelines, PHMSA finds that granting this special permit to\nTCPL is inconsistent with pipeline safety.\nCompleted in Washington DC on: ----., ... u ... JN ..... ' ...... 7~2f+01HI---\nPrepared by: Engineering and Research Division\n9","truncated":false,"body_characters":17858}