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Covington, Tameka (PHMSA)

From: Wang, Henry [Henry.Wang@bwpm1p.com ]

Sent: Monday, June 25, 2007 4:22 PM

To: Nanney, Steve <PHMSA>

Cc: Binns, Terri J. <PHMSA>; Roberson, Gene <PHMSA>; Seeley, Rodrick M. <PHMSA>;
Simpson, Ray; Maraia, Frank; Goodwin, David; Adams, Jack; Earley, John; Bennett, Walt

Subject: Gulf South - 42" Pipeline - East Texas to Mississippi - Jindal Mill visit - follow-up items and
responses
Attachments: Responses to PHMSA 6-18-2007 follow-up Items.doc; Plan Production Schd_20 June.xls;
Defect list Scope PUT LamUT.xls; DOUBLE JOINT SUMMARY.XLS; Clean Blast-Chloride
Remediation Procedures.doc; Chloride Test Results ASTM D512 METHOD 07.XLS; ID PULL
TEST.doc

Steve,
Attached documents are our responses to your follow-up items. The first Word document — "Responses to
PHMSA 6-8-2007 follow-up items.doc" has the written responses with references to the other attached files. If you
have any questions, please let us know. Thanks.

Henry Wang
Director, Integrity Management
9 Greenway Plaza, Suite 2800 (RM 2611)
Houston, Texas 77046
Phone 713-479-8120 Cell 832-722-1417
Email: henry.wang@bw_p_mlp,com

From: Steve.Nanney@dot.gov [mailto:Steve.Nanney@dot.gov]

Sent: Monday, June 18, 2007 8:00 AM
To: Wang, Henry; Simp4on, Ray
Cc: Terri.J.Binns@dot.gm1; Gene. Roberson@dot.gov ; Steve.Nanney@dot.gov ; Racick.M.Seeley@dot.gov
Subject: Gulf South - 42" Pipeline - East Texas to Mississippi - Jindal Mill visit - foHN.ip items

Henry, thank you and Ray for taking the time to go to the Jindal Mill with rri and I on Friday. Below
are the follow-up items from the mill visit.

Gulf South will follow-up to PHMSA SW Region the following quality co trol information since the
mill re-started Gulf South's pipe in late- y:
1) Pipe Rolling and Coating Schedule June — September
2) Hydrotest — update of problem, howl g was the problem and how many pipe joints did it
affect
3) Weld seam fluoroscope — documentation Of calibration and rejects — number and % of pipe
4) Plate UT — number and % rejects and type, equipment calibration intervals
5) Pipe end UT — rejects and type — number and 'af of pipe
6) Doubling Jointing - x-ray repairs and cut-outs, niz ber of joints double jointed and % of pipe
repaired and cut-outs
7) Pipe tracking process due to hydrotester problem — is it being communicated/ pipe
marked/documented on pipe for plant workers to ensure . quality control traceability of the pipe
8) Oil contamination- how is oil contamination on pipe 1D/0 being handled and quality test
results.
9) Pipe internal and external chloride contamination and cleaning rocedures that were used at
Baton Rouge. Gulf South found chloride contamination of pipe at this facility. The pipe had been

11/10/2009
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shipped from India. How was the cleaned, pipe surface tested, and coating tested for QA? Please
submit documentation.

The above quality a • ur e documentation will be submitted to PHMSA- SW Region by Monday, June
25 by Henry Wang.

Thanks, Steve

Steve Nanney
PHMSA - Southwest Region
Office - 713-272-2855
Mob# - 713-628-7479
E-mail - steve.nanney@dot.gov

11/10/2009
Responses to PHMSA's questions:

1) Pipe Rolling and Coating Schedule — June — September

See attached spreadsheet for pipe rolling and coating schedule (File name: Plan
Production schd_20_,Tune.xls)

2) Hydrotest — update of problem, how long was the problem and how many pipe
joints did it affect
Hydrotester went down on 5/25/2007 and came back up on 6/11/2007. The ram
cylinder and piston of the hydrotester got stuck up and had to be opened up. The
cylinder and the piston had actually got damaged therefore they were rebuilt and
machined to the original tolerances. None of the pipes got affected due to this as
none of the pipes were processed at hydrotester during this period. About 1309
pieces were set aside in the yard for hydro testing and processing.

3) Weld seam fluoroscope — documentation of calibration and rejects — number and

% of pipe
Calibration is done every 4 hours. The total defects observed from fluoroscope is
1832 pipes (7.6% of the total pipes processed). See attached spreadsheet (File
name: Defect list scope PUT LamUT.xls) tab 1 - Scopel for details.
Documentation of calibration is in hard copy form.

4) Plate UT — number and % rejects and type, equipment calibration intervals.

Plate UT calibration is done every 4 hours. The defect plate number from Plate
UT is 59 plates (0.23% of the total plates processed). See attached spreadsheet
(File name: Defect list scope PUT LamUT.xls) tab 2 - PUT for details.

5) Pipe end UT — rejects and type — number and % of pipe

Pipe end UT calibration is done every 4 hours. The defect pipe number from pipe
end UT (Lam UT) is 883 pipes (3.6% of the total pipes processed). See attached
spreadsheet (File name: Defect list scope PUT LamUT.xls) tab 3 - LAM UT for
details.

6) Doubling Jointing - x-ray repairs and cut-outs, number of joints double jointed
and % of pipe repaired and cut-outs
There were total of 1892 double jointing welds with 1828 accepted x-ray or
3.38% rejection rate. There were 29 cut-outs due to repairs (1.53% cut-outs rate).
See attached spreadsheet (File name: Double Joint Summary) for details.

7) Pipe tracking process due to hydrotester problem — how is it being communicated/

pipe marked/documented on pipe for plant workers to ensure quality control
traceability of the pipe
The pipes were not processed beyond the hydrotester station. The pipes after
expansion were stacked separately in the yard, therefore no traceability problem
on the product. These pipes had pipe numbers on the outside on both ends. The
same information was made available in the pipe tracking system.
8) Oil contamination- how is oil contamination on pipe ID/OD being handled and
quality test results.
The pipe is cleaned at the pre-wash station after forming to clean it from all oil
contamination in the ID and OD. After the entire process is completed, the pipes
are cleaned again before final inspection.

All the pipes on which oil was observed were 0.670" wall pipe kept aside after
expansion. The pipes had soluble oil inside them which is used at the expander for
lubrication in the expander head and between the pipe and expander dies to
reduce friction between moving parts.

This soluble oil is later rinsed at hydrotester and completely cleaned at inside
wash station before pipes are offered for final inspection. Therefore the oil was
visible on these pipes only because they were un-processed pipes which still had
to go through the process of cleaning through the regular cycle.

When these pipes feed back in the mill, they will be cleaned at the wash station
and inspected by the inspectors. Both ID and OD surface conditions will have to
meet the coating specifications before coating can be applied.

9) Pipe internal and external chloride contamination and cleaning procedures that
were used at Baton Rouge. Gulf South found chloride contamination of pipe at
this facility. The pipe had been shipped from India. How was the cleaned, pipe
surface tested, and coating tested for QA? Please submit documentation.
According to Gulf South coating specifications, if 5 [tg/cm 2 or more of chloride is
present, a phosphoric acid wash should be performed.

Clean Blast Services, Inc. provides the service and procedures to clean chloride
from the pipe internal surface at Bayou Coating Baton Rouge. The chloride
remediation procedures includes pre-rinse, acid wash and post rinse. See attached
document (File name . Clean Blast — Chloride Remediation Procedure.doc) for
detailed procedures. Acid wash is also performed on all pipe external surfaces.

For a quantitative measure the ASTM D512 Mercuric Nitrate test method was
used for chloride measurement. Tests performed after the acid wash indicates all
chloride levels are below the 5 1.ig/cm2 requirement. See attached spreadsheet (File
name: Chloride test results ASTM D 512 method 07.xls) Tab 6 -9 for test results
after acid wash.

Standard coating tests such as bend test, cathodic disbondment test, moisture
permeation test are performed per coating specifications on external FBE.

For internal coating, a portable adhesion tester was used to determine the
adhesion strength of the internal coating (Valspar 930 HS epoxy) applied to the
internal surface of the pipe with a finished product of 2 to 3 dry mils. The dollies
were glued and the pull test was performed and witnessed by Randy Fair. The
results are as follows.

1D# PULL STRENGTH

DJ 62 3300psi
DJ 1004 2400psi
DJ 512 3100psi
DJ 509 3200psi

All tests that were performed had a glue failure instead of a coating failure. Most
two part epoxy paints has a minimum failure @ 800psi and these tests well
exceeded that minimum. See attached document (file name: ID Pull Test.doc) for
details.