{"operation":"document","citation":"0900006481c578bc","title":"U.S. DOT/PHMSA - Letter of Decision","source_type":"rulemaking","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":null,"effective_on":null,"summary":"This document is PHMSA's Special Permit Renewal Order PHMSA-2008-0345. It: (1) states PHMSA reviewed CGT operational and maintenance data and finds CGT continues to meet the special permit terms; (2) grants the renewal from April 13, 2015 through December 31, 2016 subject to numerous conditions (including replacement of the three segments by December 31, 2016 or lowering MAOP to meet §§ 192.611 and 192.619); (3) defines the three special permit segments and a 28.31-mile inspection area on 24-inch Line R-701 in Lawrence County, Ohio; (4) specifies detailed integrity, inspection, testing, reporting, training, and certification requirements; and (5) includes limitations on PHMSA authority and renewal procedures. The document limits the permit to the stated period and lists conditions that must be met by specified dates.","machine_formats":{"json":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006481c578bc.json","markdown":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006481c578bc.md"},"app_url":"https://regulus.evalyn.ai/document/regulations-gov-attachment-0900006481c578bc","source_url":"https://downloads.regulations.gov/PHMSA-2008-0345-0018/attachment_1.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nSEP 0 2 2015\nMr. Shawn L. Patterson\nPresident, Operations and Project Delivery\nColumbia Pipeline Group, Inc.\n1700 MacCorkle A venue, SE\nCharleston, WV 25314\nRef: Special Permit Renewal -April13, 2015 to December 31, 2016\nPHMSA-2008-0345\nDear Mr. Patterson:\nBy letter dated July 30, 2014, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), notified Columbia Pipeline Group, Inc. (CPG),\nowner of the Columbia Gas Transmission, LLC (CGT) pipeline system, that special permit\nPHMSA-2008-0345 would expire on April13, 2015, unless renewed. By letter dated August 28,\n2014, CPG applied for a renewal of the CGT special permit. On November 4, 2014, PHMSA\npublished a Federal Register notice concerning this special permit renewal (79 FR 65477). No\npublic comments were received. The special permit renewal request letter and all other pertinent\ndocuments are available for review in Docket No. PHMSA-2008-0345, in the Federal Docket\nManagement System (FDMS) located at www.regulations.gov.\nOn July 14, 2015, CPG notified PHMSA that the three (3) CGT special permit segments located\nin Lawrence County, Ohio, would be replaced in accordance with 49 Code of Federal\nRegulations (CFR) Part 192 for the current class location and a special permit renewal would\nonly be needed through December 31, 2016.\nRenewal of this special permit would continue the waiver of compliance with 49 CFR § 192.611\nfor three (3) natural gas transmission segments of the 24-inch CGT pipeline system, where the\npipeline class location has changed from a Class 1 to a Class 3 location.\nPHMSA has reviewed all operational and maintenance data submitted by CPG for the CGT\nspecial permit renewal and finds that CGT continues to meet the terms of the special permit.\nPHMSA has updated the special permit renewal terms based on changes in the special permit\nsegments and operations. Specifically, this special permit renewal will expire on December 31,\n2016, when the CGT pipeline segments must meet 49 CFR Part 192 for the current class location\nor the maximum allowable operating pressure (MAOP) must be lowered to meet§§ 192.611 and\n192.619 for the current class location. Based on the information provided by CPG, PHMSA has\ndetermined that renewal of the CGT special permit, as modified, would not be inconsistent with\npipeline safety.\n\n<<<PAGE 2>>>\n\nSEP 0 2 2015\nAccordingly, the special permit renewal request for PHMSA-2008-0345, submitted by\nColumbia Gas Transmission, LLC, owned by Columbia Pipeline Group, Inc., is granted\nto operate the specified segments from April13, 2015, through December 31, 2016, for\nthe Columbia Gas Transmission, LLC pipeline system described in the special permit\nwhere Class 1 to Class 3 location changes have occurred. Subject to the terms and\nconditions therein, this special permit renewal Order waives compliance with certain\nFederal regulations in 49 CFR § 192.611 for three (3) segments of the 24-inch Columbia\nGas Transmission, LLC pipeline system located in Lawrence County, Ohio.\nMy staff would be pleased to discuss this special permit or any other regulatory matter with\nyou. Mr. John Gale, Director, Standards and Rulemaking Division, may be contacted at 202-\n366-0434 on regulatory matters. Mr. Kenneth Lee, Director, Engineering and Research\nDivision, may be contacted at 202-366-2694, for technical matters and Mr. Byron Coy,\nDirector, OPS Eastern Region, may be contacted at 609-989-2180, for operational matters\nspecific to the renewal and ongoing operations of this special permit.\nSincerely,\n~~\n/!§\\ Jeffrey D. Wiese\nAssociate Administrator for Pipeline Safety\nEnclosure: Special Permit Renewal Order (PHMSA-2008-0345)\nSpecial Permit: PHMSA-2008-0345 - Columbia Gas Transmission, LLC Page 2 of2\n\n<<<PAGE 3>>>\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nSPECIAL PERMIT- RENEWAL\nSpecial Permit Information:\nDocket Number: PHMSA- 2008-0345\nRequested By:\nColumbia Gas Transmission, LLC1\nOriginal Date Requested:\nOriginal Special Permit:\nRenewal Period:\nCode Section(s):\nDecember 11, 2008\nAprill3, 2010\nApril 13, 2015 through December 31, 2016\n49 CFR § 192.611\nRenewal of Special Permit:\nBy this order, subject to the terms and conditions set forth below the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) grants this special permit renewal (PHMSA-2008-\n0345) from April13, 2015 through December 31,2016, to Columbia Gas Transmission, LLC\n(CGT) waiving compliance from 49 CFR § 192.611(a) for three (3) natural gas transmission\npipeline segments located in Lawrence County, Ohio.\nSpecial permit segments 1, 2 and 3 must be completely replaced with pipe compliant with 49\nCode of Federal Regulations (CFR) Part 192 for the current class location, by December 31,\n20162\nor the maximum allowable operating pressure (MAOP) must be lowered to meet\n§§ 192.611 and 192.619 for the current class location. This special permit renewal eliminates a\nfourth segment, special permit segment 43? as it is no longer needed due to a change in class\n1 Columbia Gas Transmission, LLC (CGT) is owned by Columbia Pipeline Group, Inc. (CPG). When this special\npermit was originally issued on April13, 2010, CGT was previously named Columbia Gas Transmission\nCompany and was owned and operated by NiSource Inc. The CGT pipeline segments described in this special\npermit are operated by CGT.\n2 On July 14,2015, CPG notified PHMSA that special permit segments I, 2, and 3 pipe would be replaced in\naccordance with 49 CFR Part 192 for the current class location and special permit renewal would only be needed\nthrough December 31, 2016.\n3 Special permit segment 4 was from survey station 2430+78 to 2441 +07 on 24-inch Line R-701.\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 1 of25\n\n<<<PAGE 4>>>\n\nlocation from a Class 3 location to a Class 1 location4\n.\nSpecial Permit Segments and Inspection Area:\nLawrence County, Ohio\nPHMSA waives compliance from 49 CFR § 192.611(a) for three (3) natural gas transmission\npipeline segments on the 24-inch Line R-701 pipeline, where a change has occurred from an\noriginal Class 1 location to a Class 3 location or a Class 25 location to Class 3 location in .\nLawrence County, Ohio. The Federal pipeline safety regulations in 49 CFR § 192.611(a) require\nnatural gas pipeline operators to confirm or revise the maximum allowable operating pressure\n(MAOP) of a pipeline segment after a change in class location. This special permit allows CGT\nto continue to operate each special permit segment at its current maximum allowable operating\npressure (MAOP) of900 pounds per square inch gauge (psig) for the 24-inch Line R-701.\nThis special permit applies to the special permit segments defined as follows using the CGT 24-\ninch Line R-701 pipeline survey stationing (Sta.):\n• Special permit segment 1- 24-inch Line R-701- 148 feet, Sta. 28+34 to Sta. 29+82\n• Special permit segment 2- 24-inch Line R-701- 544 feet, Sta. 133+06 to Sta. 138+50\n• Special permit segment 3- 24-inch Line R-701- 2211 feet, Sta. 152+85 to Sta. 174+96\nThis special permit applies to the special permit inspection area defined as follows using the\nCGT 24-inch Line R-701 pipeline stationing as a reference.\nSpecial permit inspection area -means the area that extends 220 yards on each side of the\npipeline centerline along the entire length of the 24-inch Line R-701 pipeline from:\n4 Special permit segment 4 was originally classified by CGT as a Class 3 location due to the identification of a\nsingle structure that was thought to be occupied by 20 or more persons on at least 5 days a week for 10 weeks in\nany 12 month period. After field verification and further analysis, CGT determined that the structure was not\noccupied by 20 or more persons on at least 5 days a week for 10 weeks in any 12 month period. Special permit\nsegment 4 is not a Class 3 location and has been confirmed to be a Class 1 location and is being deleted from this\nspecial permit. CGT sent a letter to PHMSA confirming the class location survey and results on September 30,\n2010, and reconfirmed this survey on July 1, 2015.\n5 The Class 3 location special permit segments were originally a Class 1 location that were upgraded to Class 2\nlocation in accordance with§ 192.611 (a) hydrostatic test.\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 2 of25\n\n<<<PAGE 5>>>\n\n• Special permit inspection area: 24~inch Line R-70 1 - 28.31 miles, Sta. 0+00 to Sta.\n1494+96\nThe special permit inspection area is located in Lawrence County, Ohio. The special permit\ninspection area starts downstream ofthe CGT Burlington, Ohio, pig launcher at Sta. 0+00 and\nends at Sta. 1494+96 at approximately 0.76 miles north of Cauley Creek Road. The total length\nof the special permit inspection area is approximately 28.31 miles and includes the special\npermit segments.\nPHMSA grants this special permit based on the findings set forth in the \"Special Permit Analysis\nand Findings\" document, which can be read in its entirety in Docket No. PHMSA-2008-0345 in\nthe Federal Docket Management System (FDMS) located on the internet at\nwww.Regulations. gov.\nConditions:\nPHMSA grants this special permit subject to the following conditions:\n1) MAOP: No later than December 31, 2016, special permit segments 1, 2 and 3 must be\ncompletely replaced with pipe compliant with 49 CFR Part 192 for the current class location\nand a certification letter sent to PHMSA in accordance with Condition 27(a), or the MAOP\nmust be lowered by that date to meet the requirements of§§ 192.611 and 192.619 for the\ncurrent class location. In the interim, CGT must continue to operate the special permit\nsegments at or below their existing MAOP as follows: 24-inch Line R-701 - MAOP 900\nps1g.\n2) Integrity Management Program: CGT must incorporate each of the special permit .\nsegments and special permit inspection area6 into its written integrity management program\n(IMP) as a \"covered segment\" in a \"high consequence area (HCA)\" per§ 192.903, except\nfor the reporting requirements contained in§ 192.945. CGT need not include the special\n6 \"Each condition that requires CGT to perform an action with respect to the Special Permit Inspection Area shall\nalso require CGT to perform that action on all Special Permit Segments within such Areas.\"\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 3 of25\n\n<<<PAGE 6>>>\n\npermit segments described in this special permit in its IMP baseline assessment plan unless\nthose segments are in HCAs, in accordance with§ 192.905.\n3) Close Interval Surveys: CGT must perform a close interval survey (CIS) of the 24-inch Line\nR -701 pipeline along the entire length of all special permit segments and special permit\ninspection area and remediate any areas of inadequate cathodic protection no later than 21\nmonths after the renewal of this special permit 7\n• A CIS and remediation need not be\nperformed ifCGT has performed a CIS and remediation on the 24-inch Line R-701 pipeline\nalong the entire length of the special permit inspection area less than two (2) years prior to\nthe grant or renewal of this special permit. If factors beyond CGT's control prevent the\ncompletion of the CIS and remediation within 21 months, a CIS and remediation must be\ncompleted as soon as practicable and a letter justifying the delay and providing the\nanticipated date of completion must be submitted to the Director, PHMSA Eastern Region8\nno later than 21 months after the grant or renewal of this special permit.\n4) Close Interval Surveys- Reassessment Interval: CGT must perform periodic CIS of the\nspecial permit segments and special permit inspection area no later than 21 months after the\nrenewal of this special permit. A CIS need not be performed ifCGT has performed a CIS of\nthe 24-inch Line R-701 pipeline along its entire length of the special permit inspection area\nless than two (2) years prior to renewal of this special permit. CGT must also integrate CIS\ndata with in-line inspection (ILl) data, and data on any other threats, in accordance with\n49 CFR §§ 192.937 (a) and (b), 192.917, and 192.939.\n5) Coating Condition Surveys: Within 21 months ofthe grant or renewal of this special\npermit9 CGT must perform a Direct Current Voltage Gradient (DCVG) survey or an\n7 CGT may replace the special permit segments with pipe compliant with 49 CFR Part 192 for the current class\nlocation, no later than December 31, 2016, instead of conducting a CIS as defmed in Conditions 3 and 4.\n8 \"In the case of any Special Permit condition that requires CGT to provide documentation to the PHMSA Region,\nCGT must also send a copy of such documentation to the appropriate state authorities, in states that have interstate\nagent agreements with PHMSA.\"\n9 CGT may replace the special permit segments with pipe compliant with 49 CFR Part 192 for the current class\nlocation, no later than December 31, 2016, instead of conducting a Coating Condition Survey as defmed in\nCondition 5.\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 4 of25\n\n<<<PAGE 7>>>\n\nAlternating Current Voltage Gradient (ACVG) survey of each special permit segment to\ndetermine the pipeline coating conditions and must then remediate any integrity issues in the\nspecial permit segments. A DCVG or ACVG survey and remediation need not be performed\non the special permit segments if CGT has performed a DCVG or ACVG and remediation in\naccordance with this special permit condition on the 24-inch Line R -701 pipeline along the\nentire length of the special permit inspection area less than two (2) years prior to the grant or\nrenewal of this special permit. CGT must remediate any damaged coating indications found\nduring these assessments that are classified as moderate (i.e. 35% IR and above for DCVG or\n50 dB!l V and above for ACVG) or severe based on NACE International Recommended\nPractice 0502-2002, \"Pipeline External Corrosion Direct Assessment Methodology, \" (NACE\nRP 0502-200210). A minimum of two (2) coating survey assessment classifications must be\nexcavated, classified and/or remediated per each survey crew per each time the survey is\nperformed. If factors beyond CGT's control prevent the completion of the DCVG or ACVG\nsurvey and remediation within 21 months of this special permit renewal, a DCVG or ACVG\nsurvey and remediation must be performed as soon as practicable and a letter justifying the\ndelay and providing the anticipated date of completion must be submitted to the Director,\nPHMSA Eastern Region no later than 30 days prior to the expiration date to conduct the\nsurvey.\n6) Stress Corrosion Cracking Direct Assessment (SCCDA) : CGT must evaluate the 24-inch\nLine R-701 pipeline for stress corrosion cracking (SCC) as follows:\na) CGT must perform a SCCDA or other appropriate assessment method for SCC [such as\npressure test or ILl with a crack detection tool] ofthe 24-inch Line R-701 pipeline along\nthe entire length of the special permit inspection area, according to the requirements of\n§ 192.929 and/or NACE SP 0204-2008 and remediate any SCC found or replace the\nspecial permit segment(s) with pipe compliant with 49 CFR Part 192 for the current\nclass location, no later than December 31, 2016, after the renewal of this special permit.\nThe SCCDA or other approved method must address both high pH SCC and near neutral\npH SCC. A SCCDA need not be performed ifCGT has performed a SCCDA ofthe 24-\n10 When PHMSA adopts a revised edition of a referenced NACE or ASME standard into 49 CFR Part 192, the\nreferenced requirements of those revised standards are automatically incorporated into these special permit\nconditions.\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 5 of25\n\n<<<PAGE 8>>>\n\ninch Line R -701 pipeline along the entire length of the special permit inspection area\nless than two (2) years prior to the renewal of this special permit. If factors beyond\nCGT's control prevent the completion of the SCCDA survey and remediation within 21\nmonths, a SCCDA and remediation must be performed as soon as practicable and a letter\njustifying the delay and providing the anticipated date of completion must be submitted\nto the Director, PHMSA Eastern Region no later than 21 months after the renewal of this\nspecial permit. CGT may eliminate this Condition 6(a), provided CGT provides an\nengineering assessment showing that the pipeline does not meet any of the criteria for\nboth near neutral and high pH SCC per the applicable edition of the American Society of\nMechanical Engineers Standard B31.8S, \"Managing System Integrity of Gas Pipelines\"\n(ASME B31.8S) Appendix A3, or NACE SP 0204-2008, \"Stress Corrosion Cracking\n(SCC) Direct Assessment Methodology\", Section 1.2.1.1 and 1.2.2).\nb) When the CGT 24-inch Line R-701 pipeline is exposed for any reason in the special\npermit segments and special permit inspection area and the coating has been identified\nas poor during the pipeline examination, then CGT must directly examine the pipe for\nsec using an accepted industry detection practice such as dry or wet magnetic particle\ntests. Poor coating is a coating that has become damaged and is losing adhesion to the\npipe which is shown by falling off the pipe, is porous, has pin holes, and/or shields the\ncathodic protection. Visual inspection is not sufficient to determine if the coating is\ndamaged and a holiday detection test at the correct voltage must be performed. CGT\nmust keep coating records of all excavation locations for the special permit segments and\nspecial permit inspection area to demonstrate the coating condition.\n7) Reporting of Pipe and Coating Remediation: CGT must submit the DCVG or ACVG, CIS\nand SCCDA [or other PHMSA approved methods of determining SCC] findings including\nremediation actions in a written report to the Director, PHMSA Eastern Region, no later than\n21 months after the grant or renewal of this special permit.\n8) O&M Manual- In-Line Inspection and Reassessment Intervals: CGT must amend\napplicable sections of its operations and maintenance (O&M) manual(s) to incorporate the\ninspection and reassessment intervals by in-line inspection (ILl) including both metal loss\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 6 of25\n\n<<<PAGE 9>>>\n\nand geometry tools ofthe 24-inch Line R-701 pipeline along the entire length of the special\npermit segments and special permit inspection area at a frequency consistent with 49 CPR\nPart 192, Subpart 0. [Deformation tools may be substituted for geometry tools in accordance\n.\nwith Condition 20 (c).] Condition 20(c) requires CGT to run deformation tools on the\npipelines.\n9) O&M Manual - CIS Inspection and Reassessment Intervals: CGT must amend applicable\nsections of its O&M manual( s) to require CIS inspection and reassessment intervals of the\n24-inch Line R -701 pipeline special permit segments and special permit inspection area at a\nfrequency consistent with 49 CPR Part 192, Subpart 0, but at least once every five (5)\ncalendar years at reassessment intervals not exceeding 63 months.\n1 0) In-Line Inspection Initial Assessment: CGT must perform an ILl assessment along the\nentire length of the special permit segments and special permit inspection area using high\nresolution MPL and deformation in-line inspection tools within six ( 6) months of issuance of\nthis permit and must remediate discovered conditions in accordance with Condition 20 of this\npermit. Subsequent ILl assessments of the 24-inch Line R-701 pipeline along the entire\nlength of the special permit inspection area must conform to the required maximum\nreassessment intervals specified in§ 192.939, but at least once every five (5) calendar years\nat reassessment intervals not exceeding 63 months.\n11) In-Line Inspection Reassessment Intervals: CGT must schedule ILl reassessment dates\nfor the 24-inch Line R-70 1 pipeline along the entire length of the special permit segments\nand special permit inspection area according to§ 192.939 by adding the required time\ninterval to the previous assessment date, but reassessments must be at least once every five\n(5) calendar years at reassessment intervals not exceeding 63 months.\n12) Damage Prevention Best Practices: CGT must incorporate the applicable best practices of\nthe Common Ground Alliance (CGA) into its damage prevention program within the special\npermit segments and special permit inspection area.\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 7 of25\n\n<<<PAGE 10>>>\n\n13) Field Activity Advance Notice to PHMSA: CGT must give a minimum of 14 days advance\nnotice11 to the Director, PHMSA Eastern Region to enable him/her to observe the\nexcavations relating to Conditions 5, 6 (b), 19, 20, 21, 22, 23 and 24 in the special permit\nsegments and special permit inspection area. Immediate response conditions do not require\na 14-day advance notice, but the PHMSA Regional Director must be notified by CGT no\nlater than two (2) business days after the immediate condition is discovered.\n14) High Consequence Area Assessments: CGT must not use this special permit as a basis for\ndeferring any of its assessments for HCAs under 49 CFR Part 192, Subpart 0.\n15) Annual Reports to PHMSA: Within three (3) months following the grant or renewal of this\nspecial permit and annually12 thereafter, CGT must report the following to the Director,\nPHMSA Eastern Region; Director, PHMSA Standards and Rulemaking Division; and submit\na copy to the Federal Register Docket (PHMSA-2008-0345) at www.Regulations.gov:\na) In the first annual report, CGT must describe the economic benefits of the special permit\nincluding both the costs avoided from not replacing the pipe and the added costs of the\ninspection program. Subsequent annual reports should address any changes to these\neconomic benefits.\nb) In the first annual report, fully describe whether the public benefits from energy\navailability. This should address the benefits of avoided disruptions as a consequence of\npipe replacement and the benefits of maintaining system capacity. Subsequent reports\nmust indicate any changes to this initial assessment.\nc) The number of new residences, other structures intended for human occupancy and\npublic gathering areas built within the special permit segments and special permit\ninspection area.\nd) Any new integrity threats identified during the previous year and the results of any ILl or\ndirect assessments performed (including any un-remediated anomalies over 30% wall\n11 CGTC must give notice of any planned field activities under this special permit to the Director, PHMSA Eastern\nRegion. PHMSA Region Director may elect to not witness and be noticed on some field activities.\n12 Annual reports must be received by PHMSA by the last day of the month in which the Special Permit is dated.\nFor example, the annual report for a Special Permit dated Aprill3, 2010, must be received by PHMSA no later\nthan April 30, each year beginning in 2011. For special permit renewals the annual report date would remain the\nsame reporting month as previously established.\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 8 of25\n\n<<<PAGE 11>>>\n\ne) f) loss; cracking found in the pipe body, weld seam or girth welds; and dents with metal\nloss, cracking or stress riser) during the previous year in the special permit segments and\nspecial permit inspection area.\nAny reportable incident, any leak normally indicated on the DOT Annual Report and all\nrepairs on the pipeline that occurred during the previous year in the special permit\nsegments and special permit inspection area.\nAny on-going damage prevention initiatives affecting the special permit segments and\nspecial permit inspection area and a discussion of the success of the initiatives.\ng) Any mergers, acquisitions, transfer of assets, or other events affecting the regulatory\nresponsibility of the company operating the pipeline.\n16) Cathodic Protection Test Station- Location: At least one (1) cathodic protection (CP)\npipe-to-soil test station must be located within each HCA with a maximum spacing between\ntest stations of one-half mile within an HCA. In cases where obstructions or restricted areas\nprevent test station placement, the test station must be placed in the closest practical location.\nThis requirement applies to any HCA within the special permit segments and special permit\ninspection area.\n17) Cathodic Protection Test Station - Remediation: If any annual CP test station readings on\nthe 24-inch Line R -701 pipeline within the special permit segments and special permit\ninspection area fall below 49 CPR Part 192, Subpart I requirements, remediation must occur\nwithin six (6) months and include a CIS on each side of the affected test station to the next\ntest station and perform any identified corrosion system modifications to ensure acceptable\ncorrosion control. If factors beyond CGT's control prevent the completion of remediation\nwithin six months, remediation must be completed as soon as practicable and a letter\njustifying the delay and providing the anticipated date of completion must be submitted to the\nDirector, PHMSA Eastern Region no later than the end of the six (6) months completion\ndate. Any extended evaluation and remediation schedules submitted to PHMSA from CGT\nmust receive a \"no objection\" from the Director, PHMSA Eastern Region.\n18) Interference Currents Control: CGT must address induced AC from parallel electric\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 9 of25\n\n<<<PAGE 12>>>\n\ntransmission lines and other interference issues in the special permit segments and special\npermit inspection area that may affect the pipeline. An induced AC program or DC program\nand remediation to protect the pipeline from corrosion caused by stray currents must be in\nplace within one (1) year of the date of this special permit.\n19) Field Coating: The coatings used on the pipeline and girth weld joints in the special permit\nsegments and special permit inspection area must be non-shielding to CP. In the event that\nthe coating type is unknown or is known to shield CP for girth weld joints then CGT must\ntake special care to:\na) Analyze ILl logs in the areas of girth welds for potential corrosion indications.\nb) Any ILl corrosion indications above 30% wall loss at girth welds where the coating type\nis unknown or is known to shield CP, girth weld joints must be exposed and evaluated\neach time the ILl is run or until the girth weld coating is replaced.\nc) A minimum oftwo (2) girth weld joints at locations most likely to have shielding and\ncorrosion shall be exposed and evaluated each time ILl is run. If corrosion is found, the\nnext most likely joint is to be exposed and evaluated until no corrosion is found.\n20) Anomaly Investigation, Evaluation, and Repair:\na) General: CGT must account for ILl tool tolerance and corrosion growth rates in\nscheduled response times and repairs with documentation and technical justification of\nthe values used. CGT must demonstrate ILl Tool tolerance accuracy for each ILl Tool\nrun by usage of calibration excavations (minimum of 5 excavations for each ILl Tool\nrun) and unity plots that demonstrate ILl Tool accuracy for depth within+ 10% accuracy\nfor 80% of the time. The unity plots must show: a) actual anomaly depth versus\npredicted depth and b) actual failure pressure/MAOP versus predicted failure\npressure/MAOP. Discovery date must be within 60 days of an ILl Tool run for each type\nILl Tool (geometry, deformation or high resolution MFL)\nb) Dents: CGT must repair dents to the 24-inch Line R-701 pipeline in the special permit\ninspection areas in accordance with§ 192.933 repair criteria. Special permit segments\nand the special permit inspection area must have a geometry tool inspection as part of\nthe initial ILl and all dent repairs made in accordance with§ 192.933 repair criteria The\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 10 of25\n\n<<<PAGE 13>>>\n\ngeometry tool can be from past ILl inspections. The timing for these dent repairs should\nfollow CGT's O&M Manual but must not be longer than one (1) year after discovery.\nc) Deformation Tool: CGT must run a deformation tool through all special permit\nsegments and the special permit inspection area within six (6) months of the grant of\nthis special permit and remediate all expanded pipe in accordance with PHMSA's\n\"Interim Guidelines for Confirming Pipe Strength in Pipe Susceptible to Low Yield\nStrength\" dated September 10, 2009, within 12 months of grant date of this special\npermit.\nd) Investigation and Repair Criteria: Investigation, evaluation, and repair criteria applies\nto all anomalies located on the 24-inch Line R-701 pipeline within the special permit\nsegments and the special permit inspection area when they have been excavated,\ninvestigated, and remediated in accordance with§§ 192.485 and 192.933 incorporating\nappropriate class location design factors in the anomaly repair criteria, including HCAs\nas follows:\n• Special permit segments - Repair any anomaly within a special permit segment\nthat meets either: (1) a failure pressure ratio13 (FPR) less than or equal to 1.39 for\noriginal Class 1 location pipe in a Class 3 location operating up to 72% of the\nspecified minimum yield strength (SMYS); (2) an anomaly depth greater than or\nequal to 40% of pipe wall thickness.\n• Special permit inspection areas - Repair any anomaly within a special permit\ninspection area that meets either: (1) an FPR less than design factor- for Class 1\nlocation - FPR equal to or less than 1.3 9; for Class 2 location- FPR equal to or\nless than 1.67; and for Class 3 location- FPR equal to or less than 2.0; (2) an\nanomaly depth equal to or greater than 60% wall thickness loss.\n- Repair anomalies in original Class 1 location pipe that are now in a Class 2\nlocation in accordance with§§ 192.5 and 192.611 that meets either: (1) is\nequal to or less than the Class I location FPR of 1.39; (2) an anomaly depth\nequal to or greater than 50% wall thickness loss for anomaly repairs.\n13 Failure pressure ratio (FPR) is based upon the class location where the special permit segment or special permit\ninspection area pipe is located in accordance with§ 192.5 and is the reciprocal of the class location design factor\nin§ 192.1ll(a).\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 11 of25\n\n<<<PAGE 14>>>\n\ne) - Repair anomalies in original Class 2 location pipe that is now in a Class 3\nlocation in accordance with§ 192.611 that meets either: (1) is equal to or less\nthan the Class 2 location FPR of 1.67; (2) an anomaly depth equal to or\ngreater than 50% wall thickness loss for anomaly repairs.\nResponse Time for ILl Results: The following guidelines provide the required timing\nfor excavation, investigation, and remediation of anomalies based on ILl data results in\naccordance with§§ 192.485 and 192.933, and must incorporate appropriate class\nlocation design factors in the anomaly repair criteria for special permit segments and\nspecial permit inspection area including all HCAs. Reassessment by ILl will reset the\ntiming for anomalies not already investigated and/or repaired. CGT must evaluate ILl\ndata by using either the ASME Standard B31 G, \"Manual for Determining the Remaining\nStrength of Corroded Pipelines\" (ASME B31G), the modified B31G (0.85dL) orR-\nSTRENG for calculating the predicted FPR to determine anomaly responses.\n• Special permit segments:\n- Immediate response: Any anomaly within a special permit segment operating\nup to 72% SMYS that meets either: (1) an FPR equal to or less than 1.1; (2) an\nanomaly depth equal to or greater than 80% wall thickness loss.\n- One-year response: Any anomaly within a special permit segment with\noriginal Class 1 location pipe in a Class 3 location operating up to 72% SMYS\nthat meets 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- Monitored response: Any anomaly within a special permit segment with\noriginal Class 1 location pipe in a Class 3 location operating up to 72% SMYS\nthat meets both: (1) an FPR greater than 1.39; (2) an anomaly depth less than\n40% wall thickness loss. The schedule for the response must take tool\ntolerance and corrosion growth rates into account.\n• Special permit inspection areas:\n- Immediate response: Any anomaly within a special permit inspection area\noperating up to 72% SMYS that meets either: (1) an FPR equal to or less than\n1.1; (2) an anomaly depth equal to or greater than 80% wall thickness loss.\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 12 of25\n\n<<<PAGE 15>>>\n\n- One-year response: Any anomaly within a special permit inspection area that\nmeets either: (1) an FPR less than design factor- for Class 1 location- FPR\nequal to or less than 1.39; Class 2 location- FPR equal to or less than 1.67;\nand for Class 3 location- FPR equal to or less than 2.0; (2) an anomaly depth\nequal to or greater than 60% wall thickness loss.\nAny anomaly for Class location changes from original Class 1 to 2 location or\noriginal Class 2 to 3 location in accordance with§§ 192.5 and 192.611 that\nmeets either: (1) an anomaly FPR equal to or less than the FPR of the original\nClass location; (2) an anomaly depth equal to or greater than 50% wall\nthickness loss.\n- Monitored response: Any anomaly within a special permit inspection area\nthat meets both: (1) an FPR less than design factor - for Class 1 location-\nFPR greater than 1.39; Class 2location- FPR greater than 1.67; and for Class\n3 location- FPR greater than 2.0; (2) an anomaly depth less than 60% wall\nthickness loss.\nAny anomaly repairs for Class location changes from original Class 1 to 2\nlocation or original Class 2 to 3 location in accordance with§§ 192.5 and\n192.611 that meets both: (1) an anomaly FPR greater than the FPR of the\noriginal Class location; (2) an anomaly depth less than 50% wall thickness\nloss. The schedule for the response must take tool tolerance and corrosion\ngrowth rates into account.\n21) Girth Welds: CGT must provide records to PHMSA to demonstrate the girth welds on the\n24-inch Line R-701 pipeline were nondestructively tested at the time of construction in\naccordance with:\na) The Federal pipeline safety regulations at the time the pipelines were constructed. If\nnot, show that at least 10% of the girth welds in each special permit segment were\nnon-destructively tested after construction but prior to the application for this special\npermit provided at least two (2) girth welds in each special permit segment were\nexcavated and inspected. If CGT cannot provide girth weld records to PHMSA to\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 13 of25\n\n<<<PAGE 16>>>\n\nb) demonstrate either of the above in Condition 21 (a), CGT must accomplish either: (i);\nor (ii) and either (iii) or (iv) of the following:\ni) Certify to PHMSA in writing that there have been no in-service leaks or\nbreaks in the girth welds on the 24-inch Line R-701 pipeline within the\nentire special permit inspection area for the entire life of the pipelines; or\nii) Evaluate the terrain along the special permit segments for threats to girth\nweld integrity from soil or settlement stresses and remediate all such\nintegrity threats; and\niii) Excavate1\\ visually inspect and nondestructively test at least two girth\nwelds on the 24-inch Line R-701 pipeline in each special permit segment in\naccordance with the American Petroleum Institute Standard 1104, \"Welding\nof Pipelines and Related Facilities\" (API 1104) as follows:\nA. Use the edition of API 1104 current at the time the pipelines were\nconstructed; or\nB. Use the edition of API 1104 recognized in the Federal pipeline safety\nregulations at the time the pipelines were constructed; or\nC. Use the edition of API 1104 currently recognized in the Federal\npipeline safety regulations.\niv) As an alternative to Condition 21 (a) (iii), CGT may perform an HRMFL in-\nline inspection capable of identifying girth weld anomalies. If this\ntechnique is employed, CGT must develop a technical basis for evaluating\nthe serviceability of the girth welds based on HRMFL ILl data. The girth\nweld ILl inspection plan including ILl findings, technical determination for\nidentifying weld anomalies and confirmation excavations must be submitted\nto Director, PHMSA Eastern Region for approval 14 days prior to\nconfirmation excavations.\nIf any girth weld in any of the special permit segments does not comply with API\n1104, CGT must repair the girth weld immediately15 and then prepare an inspection\n14 CGTC must evaluate for SCC any time the 24-inch Line R-70 1 pipeline is uncovered in accordance with\nCondition 6 (b) of this special permit.\n15 Any extended evaluation and remediation schedules submitted to PHMSA from CGT must receive a \"no\nobjection\" from the Director, PHMSA Eastern Region.\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 14 of25\n\n<<<PAGE 17>>>\n\nc) d) and remediation plan for all remaining girth welds in the special permit segments\nbased upon the repair findings and the threat to the special permit segments. CGT\nmust submit the inspection and remediation plan for girth welds to the Director,\nPHMSA Eastern Region and remediate girth welds in the special permit segments in\naccordance with the inspection and remediation plan within 60 days of finding girth\nwelds that do not meet this Condition 21 (c).\nAdditionally, all oxy-acetylene girth welds, mechanical couplings and wrinkle bends\nin special permit segments must be removed.\nCGT must complete the girth weld testing, and the girth weld inspection and\nremediation plan, within six ( 6) months after the grant of this special permit. If\nfactors beyond CGT' s control prevent the completion of these tasks within six ( 6)\nmonths, the tasks must be completed as soon as practicable and a letter justifying the\ndelay and providing the anticipated date of completion must be submitted to the\nDirector, PHMSA Eastern Region no later than six (6) months after the original grant\nof this special permit. Any extended evaluation and remediation schedules submitted\nto PHMSA from CGT must receive a \"no objection\" from the Director, PHMSA\nEastern Region.\n22) Casings: CGT must identify all shorted casings (metallic or electrolytic) within the special\npermit segments and the special permit inspection area no later than six ( 6) months after the\ngrant of this special permit and classify any shorted casings as either having a \"metallic\nshort\" (the carrier pipe and the casing are in metallic contact) or an \"electrolytic short\" (the\ncasing is filled with an electrolyte) using a commonly accepted method such as the\nPanhandle Eastern, Pearson, DCVG, ACVG or AC Attenuation.\na) Metallic Shorts: CGT must clear any metallic short on a casing in the special permit\nsegments and the special permit inspection area no later than six (6) months after the\nshort is identified.\nb) Electrolytic Shorts: CGT must remove the electrolyte from the casing/pipe annular\nspace on any casing in the special permit segments and the special permit inspection\narea that has an electrolytic short no later than six ( 6) months after the short is\nidentified.\nSpecial Permit Renewal: PHMSA-2008-0345\nColumbia Gas Transmission, LLC (CGT)\nPage 15 of25\n\n<<<PAGE 18>>>\n\nc) All Shorted Casings: CGT must install external corrosion control test leads on both\nthe carrier pipe and the casing in accordance with§ 192.471 to facilitate the future\nmonitoring for shorted conditions and may then choose to fill the casing/pipe annular\nspace with a high dielectric casing filler or other material which provides a corrosion\n","truncated":true,"body_characters":61343}