MIDCONTINENT EXPRESS

PIPELINE LLC

August 25, 2009

Via E-Mail/Federal Express

Mr. Alan Mayberry

Director, Engineering and Emergency Support
US Department of Transportation
Pipeline and Hazardous Materials Safety Administration
1200 New Jersey Avenue SE, E22-328
Washington, DC 20590
• Reference: Midcontinent Express Pipeline LLC (MEP) — Special Permit: PHMSA-2007-27842
Dear Mr. Mayberry:
On behalf of MEP, I, M. Dwayne Burton, Vice President of Operations and Engineering, certify
that the 42" OD portion (approximately 267 miles, from Paris, Texas to Delhi, Louisiana) of
MEP has been constructed and is operating in compliance with the referenced Special Permit
PHMSA-2007-27842 and 49 CFR Part 192. All Special Permit conditions as per condition #46
with the exception of condition #35 have been completed, with the project/construction
documentation and the operations and maintenance (O&M) procedure manual updates submitted
to your office for review.
On July 16, 2008, I formally requested that Special Permit Condition #35 be revised to require
the DCVG survey on MEP to be completed within six (6) months of the installation of the
cathodic protection system. I believe this change is in line with the criteria for DCVG survey in
the recent MAOP alternative rule and will result in a better assessment of the pipeline coating.
There are no identified safety concerns on the MEP pipeline system.
In addition, MEP has reviewed its damage prevention program to assure that the MEP damage
prevention program meets or exceeds the CGA best practices.
Supplemental requirements imposed by PHMSA regarding operating MEP at the .8 design
MAO? pressure have been completed and can be explained as follows:
• Conduct a high resolution caliper tool inspection of the pipe and technically justify
Nominal OD variations.
o The 267 miles of 42" OD pipe installed in the MEP system was inspected
utilizing the TD Williams "Magpie" high resolution caliper tool.

One Allen Center 500 Dallas Suite 1000 Houston, TX 77002 713-369-9000
 Mr. Alan Mayberry
USDOT, PHMSA
August 25, 2009
• Page 2 of 2

o All data requested by PHMSA concerning the results of the tool run have been
delivered to PHMSA.
o The one nominal OD variation of 2.08% in the 42" pipeline section is scheduled
for replacement on August 26, 2009. The joint of pipe will be replaced with a
pre-tested joint of pipe that has been inspected for and cleared of any OD
variation from the manufacturing specification.
o All other identified variations are less than 1 34% and are justified for continued
operation in the pipeline in the attached Technical Discussion — Appendix A.
• I certify that the method to calculate nominal OD variations is sound and accurate. The
method uses specific data from the high resolution caliper tool run and specifically
addresses any variation from the original manufacture dimensions for each specific joint
of installed pipe. Those persons involved in the process of data collection, analysis, and
presentation of the variation data are technically qualified.

As such, on behalf or MEP, I am requesting authorization to begin operating the 42" OD portion
(267 miles) of MEP at the .8 design MAOP by September 1, 2009.

Your expedited review and authorization of this increase in MAOP is appreciated.

Very truly yours,

&AA)
M. Dwayne on
Vice President, Operations and Engineering
Office 713.369.9356

c: Rod Seeley, PHMSA, Houston, Texas

 APPENDIX A
TECHNICAL DISCUSSION FOR PIPE DIAMETERS IN EXCESS OF 0.6% OF PIPE
BODY DIAMETER FOR MIDCONTINENT EXPRESS PIPELINE (MEP)
August 25, 2009

INTRODUCTION

The Kinder Morgan Midcontinent Express Pipeline (MEP) is a 42, 36, and 30-inch diameter
pipeline system constructed by Midcontinent Express Pipeline LLC to transport natural gas at a
maximum allowable operating pressure (MAOP) of 1,480 psig. The design and construction of
the pipeline is conventional and in accordance with the requirements of 49 CFR Part 192 and
industry practices. Although not required by the regulations and/or special permit, after
hydrostatically testing the 42-inch diameter segment of the pipeline, PHMSA requested pipe
diameter measurements to be obtained by performing an internal caliper/deformation tool survey.
MEP acquiesced to this request with the understanding that any pipe body diameter
measurements less than 1.5% of the outside diameter (OD) would require no remedial actions.
Then PHMSA requested data on those joints having pipe body diameter measurements in excess
0.6% of the OD; therefore, the results of the deformation tool survey were sorted to provide
information and discuss those joints. Based on specific discussions with PHMSA, it was MEP's
understanding that the requested data for those joints having pipe body diameter measurements
in excess of 0.6% and up to 1.5% was for information purposes only, and again, was not
intended to nor would require remedial actions.

MEP excavated and examined several of the pipe joints that contained indications where the pipe
body diameter exceeded 0.6% to verify the accuracy of the deformation tool data and to gather
additional information on the pipe joints, including the condition of the coating and wall
thickness measurements. Mill test report (MTR) documents were gathered for various pipe
joints to establish a representative sample of the mechanical properties of the coil/plate used to
form the pipe. Field hydrostatic test information was also gathered to establish actual test
pressures at the various joints.

The hydrostatic test information confirms that pipe designed to operate at a 0.8 design factor in
class 1 locations was successfully tested to pressures producing a hoop stress in excess of 100%
and up to 105% of the pipe specified minimum yield strength (SMYS). The significance of this
hydrostatic test is that the test pressures and resulting hoop stress exceeds the pipe SMYS and
serves to verify that the pipe joints are free of any weld seam or material defects.

It is a regulatory requirement to subject the pipe to a pressure test prior to placing the pipeline in
gas service in order to verify that no seam defects, material defects, transportation or
construction related damages are present that could impair the integrity or serviceability of the
pipe, and one of the most positive ways to accomplish this is to test to higher pressures [3] .
However, one must take into consideration that testing a pipeline to a high percentage of SMYS
inevitably results in some small amounts of yielding and plastic strain; studies have shown that
testing above 100% SMYS, a small amount of pipe may experience strain up to 2% PI. Of those
pipe joints that undergo minor yielding, the yielding does not hurt or damage sound pipe and
does not affect pipeline integrity M . The primary effect of stressing the pipe to beyond the elastic
limit, aside from introducing permanent strain (e.g., dimensional change) is that the yield stress
is effectively increased to the stress level necessary to equilibrate the internal pressure. Studies
have also shown that a hydrostatic test at pressures high enough to induce some yielding does not
damage the pipe, and from the strength standpoint, can be viewed as beneficial in part because
the cold expansion process proof loads the seam weld above actual yielding and stresses the pipe
body removing defects that may be injurious.

CONCLUSIONS

Studies have shown that cold work in small amounts such as what occurred in some of the MEP
pipe does not cause adverse effects that could impair the serviceability of the pipe in its intended
service. The strain observed in some of the pipe joints is a form of cold work which is not
without precedent in pipe making, field hydrostatic testing, field bending, and other situations.
Pipe may experience plastic deformation in other normal situations besides pressure testing.
Cold field bends may experience between 1 and 3 percent strain, while ASME B31.8 §833.5
"Design Stress Greater than Yield" permits plastic design of steel pipe up to 2 percent strain for
longitudinal stresses. Yielding under such conditions is indistinguishable from the yielding that
occurs during a pressure test to above the yield strength of the pipe material. The successful
 completion of hydrostatic proof testing at pressures in excess of 100% of the pipe SMYS
establishes and proves the strength of the pipeline.

The results of the deformation tool survey identified that only a small percentage of pipe joints
(0.16%) exceeded 0.6% of the pipe body diameter. This represents only 1906 ft out of the
approximate 267-mile long (1,409,760 ft) pipeline segment.

An analysis of credible integrity threats determined that the minor yielding and plastic strain
does not interact with integrity threats, with threats either absent or not worsened such that
integrity management activities that would normally suffice are adequate and effective with the
MEP pipe as manufactured, tested, and installed.

TECHNICAL ANALYSIS

Background

It is a regulatory requirement to subject the pipe to a pressure test prior to placing the pipeline in
gas service in order to verify that no seam defects, material defects, transportation or
construction related damage are present that could. impair the integrity or serviceability of the
pipe. MEP subjected all pipe in the pipeline project to suchpressure tests with test pressures
resulting in pipe stress up to 105% of pipe SMYS. It was observed following completion of the
pressure tests that some joints of pipe that were tested to pressures in excess of 100% SMYS
may have experienced minor expansion. This minor yielding and plastic strain was identified by
making diameter measurements of each pipe by performing a caliper/deformation tool inspection
of the pipeline.

The results of the deformation tool survey identified that only a small percentage of pipe joints
. (0.16%) exceeded 0.6% of the pipe body diameter and represents only 1906 ft out of the 267-
mile long (1,409,760 ft) pipeline segment. When assessing the overall performance of the pipe,
of the 1906 ft, all but one joint were within 0.61 % to 1.32% of the pipe body diameter with the
one joint indicating approximately 2.08%. This single joint is 1 out of over 34,920 joints used to
construct the 42-inch diameter pipeline; from a statistical perspective it can be considered to be a
"one-off' as being on the low end of the manufacturing specification tolerances. This joint is
therefore being removed from the project and the pipeline. As will be discussed later, the
remaining pipe was successfully strength tested and is suitable for use in its intended service.

Testing at elevated test pressures in excess of 100% SMYS can result in minor yielding and
plastic strain of the pipe but that occurrence does not affect the strength requirements of the pipe.
Minor strain can be a form of cold work which is not without precedent in pipe making, field
hydrostatic testing, field bending, and other situations. Studies have shown that cold work in
small amounts such as what is being observed in some .of the MEP pipe does not cause adverse
effects that could impair the integrity or serviceability of the pipe in its intended service. Studies
have shown that a hydrostatic test at pressures high enough to induce some yielding does no
damage to a line but is in fact beneficial Pl. This is supported by the excellent service
performance of lines tested to yield with measurement after such tests showing that yielding is
minor and mechanical property changes due to plastic strains are negligible.

The possibility that the pipe was expanded during the pipe manufacturing process was also
considered. Although the dimensional inspections made in the pipe mill are typically performed
at every pipe end, such inspections of the pipe body are only made on a sampling basis.
Therefore, some of the observed indications may have occurred at the mill from the pipe forming
process, from uneven pipe end loading during the mill hydrostatic testing, or from field
hydrostatic test pressures in excess of 100% of the pipe SMYS. Several pipe joints with the
larger indications were excavated and examined. Visual inspections of the fusion-bonded epoxy
coating (FBE) revealed only slight discolorations but no apparent stress cracks or other
longitudinally aligned FBE imperfections suggesting that some of the pipe joints underwent
minor yielding and plastic strain. However, other smaller indications may be pipe mill induced.

FBE Coating inspection

The test results indicate that the coating can be expected to provide acceptable performance,
especially in light of the fact that the pipeline is also catholically protected.

The coating system used on the MEP pipe strings consisted of a fusion-bonded epoxy (FBE) as
the primary coating: MEP performed pipe coating tests on the FBE in order to validate the
integrity of the coating. Initially, the FBE coating was visually inspected for indications of
coating stress and coating cracks. MEP also performed coating adhesion tests to determine
whether the visual indications on those pipe joints that experienced plastic strain caused adverse
effects on the coating. Finally, electronic holiday detection and coating thickness tests were
performed to provide additional validation of the visual inspection and to provide for final
holiday repair prior to backfill.

Visual Inspection for Coating Stress / Coating Cracks

Visual examination was performed utilizing five separate grading classifications. The
classifications were divided into coating stress indications and coating cracking indications.
Stress indications are surface discolorations that provide evidence of coating stress. However,
coating stress indications do not penetrate beneath the coating surface and are more cosmetic in
nature. The categories of stress indications are no stress, low stress and moderate stress. Coating
crack indications are indications that penetrate beneath the surface of the coating. The two
categories of coating cracks are coating crack (sub-surface penetration) and through-coating
cracks (crack penetration to the steel substrate).

The three pipe joints that were excavated and inspected were representative of the worst-case
indications reported in the high resolution caliper tool survey results along the entire length of
the MEP 42-inch segment from Paris to Macon Bayou. MEP did not observe any coating cracks
on any of the three pipe joints excavated and inspected.. The worst visual indications observed
were cosmetic surface discolorations noted as stress marks in accordance with MEP's established
grading scale.

Adhesion Tests

MEP performed coating adhesion tests on pipe joints to establish the level of adhesion to the
steel pipe substrate. Coating adhesion tests were performed utilizing ASTM D6677-01 (Standard
Test Method for Evaluating Adhesion by Knife). The rating scale on this test method ranges
from 0 to 10 with a total of six even numbered ratings (i.e. 0, 2, 4, 6, 8, and 10). According to
the rating system, a rating of 0 indicates the least degree of adhesion (poor. adhesion) and 10
indicate the best degree adhesion (excellent adhesion). The degree of adhesion is graded
according to the size of the fragments removed when performing the test method. The adhesion
 at indications of no coating stress was rated at 8 to 10. The adhesion in the areas of greatest stress
(moderate stress) was rated an 8 which is considered good and is comparable to the areas with no
indications of stress.

Electronic Holiday Detection

Electrical inspection of the FBE coating was performed utilizing a high-voltage electrical holiday
detector. The average coating thickness was measured to establish a conservative setting for the
holiday detection voltage (the industry standard is based on a less conservative nominal
thickness). The purpose of holiday detection was to provide further electrical validation of the
coating integrity and to identify and repair any coating holidays. The coating holiday tester
validated that there were no through-coating cracks and identified only minor coating holidays
that resulted from contact with probe rods while locating the pipe depth during the excavation
and contact with shovels while removing the hard clay soil during the excavation process.

Regulatory Considerations

There are no prohibitions in the regulations contained in 49 CFR Part 192 against using pipe that
has been expanded by internal pressure, nor is expansion identified as an actionable condition.
Part 192 contains no prohibitions against the testing of pipe beyond the actual or specified
minimum yield strength, nor are there limitations on the use of pipe so tested.

Section 192.619 provides specifically for deliberately yielding pipe during a hydrostatic test in
order to establish the effective in-situ yield strength of pipe and subsequently the maximum
allowable operating pressure (MAOP), when converting a pipeline to gas service or up rating and
where the SMYS is not known. While the situations contemplated in § 192.619 are not directly
applicable to the analysis of the MEP pipe, these provisions acknowledge that pipe that has been
subjected to yielding during a hydrostatic pressure test may be used in service.

. Both industry standards (ASME B31.8) and Federal regulations require that cold expanded pipe
be derated to 75 percent of its designated strength if it is heated (for purposes other than welding
or weld stress relieving) to more than 60G F for more than 1 hour or 900 F for any period. This
limitation does not apply to MEP because the pipe bas not been and will not be so heated post-
expansion.
The Stress-Strain Relationship

Steel exhibits a linear relationship between applied stress and strain up to the proportional limit.
The slope of the stress-strain curve continuously decreases as stress is increased to levels greater
than the stress at the proportional or elastic limit, as shown in Figure 1. The proportional limit
coincides with the maximum elastic stress and strain level in the material. Applied stress in
excess of the elastic limit results in plastic strain, meaning permanent deformation. The exact
point at which the proportional limit is attained is not always readily distinguished, so the "yield
strength" is defined by convention as the stress at which a total extension in the test specimen
equal to 0.5 percent is observed while under load. The maximum elastic strain may be as low as
0.10 percent, while the maximum elastic stress necessarily will be below the reported "yield
stress" corresponding to the specified strain of 0.5 percent. Hence, testing a pipeline to a high
percentage of SMYS in pipe inevitably results in some small amounts of yielding and plastic
strain. The amount of yielding and the number of joints affected depends on the statistical
distribution of actual strength properties with respect to specified values, as determined by
steelmaking and pipe making process variables. The elongation of the pipe material in. a tensile
test is specified to be a minimum of 22% and can generally be expected to be considerably
greater. Hence small amounts of plastic strain represent a small fraction of the total strain
capacity of the material.

Cold Expansion in Pipe Manufacturing

The fact that yielding at levels of between 1 and 2 percent total strain is not harmful is
demonstrated by the fact that thousands of miles of pipeline have been constructed using pipe
that was cold expanded as part of its manufacturing process. In some cases, the pipe was
expanded for sizing to the specified outside diameter, while in others the expansion was part of
the strategy for attaining the specified strength levels. Cold expansion has been employed by
Kaiser, US Steel, National Tube, Bethlehem, Napa, SAW Pipes, Stelpipe, Republic,
Youngstown, and Big Inch, among others, generally for pipe sizes larger than 18 inches in
diameter Ell. The process remains in use by those manufacturers listed above who are still in the
pipe-making business. A number of other manufacturers have employed another cold-work
process, stretch reduction, in which the pipe is pulled longitudinally through a die, in order to
achieve final dimension in smaller pipe sizes. Cold expanded line pipe has had a good service
record, in part because the cold expansion process proof loaded the seam weld well above actual
yielding and failed the joint if it contained significant flaws. Joints of pipe that survived the cold
expansion process were thus much less likely to have seam flaws that could be injurious at the
operating pressure.

Cold expansion at the pipe mill may be achieved hydraulically by use of internal pressure to
expand the pipe into external dies, or mechanically by use of a hydraulically actuated mandrel.
Whether pipe yielded dining a hydrostatic test in the field or from cold expansion in. the pipe mill
is indistinguishable. The only fact that can be ascertained is that the final dimension of the pipe
is not specifically controlled to a uniform value.

Expansion of Pipe by Hydrostatic Pressure Testing

It has been proven statistically from pipe mill test data and also from gauging pig runs following
hydrostatic tests that the number of joints of pipe yielded in a test of the pipeline to 100 percent
or more of SMYS, or to actual yielding, are relatively few. [21 . In those studies, expansion of up to
2 % was observed. Occasionally, expanded joints of pipe are identified by pipeline operators
today when running routine in-line inspection fo•maintenance purposes: Often, these joints of
pipe have been in service for several decades without apparent problem.

Historically, tens of thousands of miles of pipeline have been tested up to and beyond the actual
yield strength of the pipe. The results were that the pipeline segments so tested exhibited a high
degree of reliability, including at operating levels up to 84% of SMYS [31. We are also aware of
anecdotal reports of operators unintentionally testing above the yield strength of the pipe, or
discovering that pipe had been yielded at some time in the past based on results from routine in-
line inspections. We believe PHMSA technical personnel are acquainted with the historical
history of pressure testing to and above actual yielding, and the fact that such pipe has exhibited
acceptable service.

Cold Work of Pipe in Other Forms

Pipe may experience plastic deformation in other normal situations besides pressure testing.
Cold field bends may experience between 1 and 3 percent strain, while ASME B31.8 §833.5
"Design Stress Greater than Yield" permits plastic design of steel pipe up to 2 percent strain for
longitudinal stresses. Yielding under such conditions is indistinguishable from the yielding that
occurs during a pressure test to above the yield strength of the pipe material.

Effects on Strength Properties

The primary effect of stressing the pipe to beyond the elastic limit, aside from introducing
permanent strain (e.g., dimensional change) is that the yield stress is effectively increased to the
stress level necessary to equilibrate the internal pressure. From the strength standpoint alone,
this can be viewed as beneficial, regardless of whether the expansion occurred during
manufacturing or field testing. Furthermore, noncritical defects which may have survived a
high-pressure proof test are mechanically stress-relieved [21. •

Effects on Ductility Properties

Cold working of steel is known to reduce its ductility. Ductility is measured in several ways: (a)
elongation at fracture in •a uniaxial tensile strap, which is a measure of the ultimate strain
capacity of the material, •(b) the ratio of yield to tensile strengths (Y/T), which relates to the
ability of the material to plastically flow at the root of a defect, and (c) the Charpy V-notch
(CVN) impact fracture toughness, which indicates a material's -ability to resist fracture
propagation.

Elongation

Tests have shown that elongation may decrease approximately 2 percent for every 1 percent of
cold work up to 4 percent, and remains flat beyond that Pi. Typical elongation properties of the
MEP pipe range from 34% to 41%. The elongation in the pipe population would not have been
reduced or adversely affected even if expansions did occur up to 2%. Thus no degradation in
ultimate strain capacity of the affected pipe is likely to have occurred.

Y/T Ratio

Plastic strain up to 7 or 8 percent strain has a less pronounced effect on the ultimate tensile
strength than on the yield strength, so the ratio of yield strength to tensile strength (Y/T ratio)
will tend to increase as a result of cold work. The line-pipe product specification API 5L
specifies an upper limit of 0.93 on the Y/T ratio for cold expanded pipe. As the Y/T ratio
approaches 1.0, the pressure at which the pipe yields approaches the pressure at which it would
burst. While some decrease in defect tolerance has been demonstrated at extremely high levels
of Y/T (above 0.93), no definable limit to Y/T above which line pipe would no longer be suitable
for use has been identified E43.. The Y/T values for the MEP pipe ranges from 0.80 to 0.91, thus
no meaningful degradation in defect tolerance would be expected.

INTEGRITY MANAGEMENT

The principles of pipeline integrity management were applied to identify threats to the pipeline
integrity which may arise. The matrix of integrity threats was reviewed to identify which of
those threats are affected by minor yielding and plastic strain. The matrix consisted of the same
threat categories used for integrity management of high consequence areas (HCAs) in
accordance with § 192.452 and ASME B31.8 S, although the segments of interest may not be
-

true HCAs. The primary categories were time-dependent, time-stable, and random events, with
all 21 recognized threat types implied by these categories.

The results are shown in Table 1 and are discussed below.

Time Dependent Threats

-

The category of time-dependent threats includes internal corrosion, external corrosion, and
stress-corrosion cracking (SCC). It is noted that plastic strain has no effect on the susceptibility
of the pipe to the occurrence of internal or external corrosion, or if corrosion were to occur, on
the rate of corrosion. With the pipe operating at a standard design factor, F, the critical defect
sizes relative to the pipe wall are no smaller than for any pipe using the same design
requirements.

One can estimate the corrosion rate applicable to the reassessment intervals governed by the line
representing pipe operating at 50% of SMYS or greater in Figure 4 of B31.8-S. This is given as

Clqty,=1,0 — rWtp=0.50) YS
Rr=G.5:0 = 1,000 33t
IS Lars FS nar 10,0
where rwtF is the uniform remaining wall thickness that could just survive at the hoop stress
corresponding to FxYSE8). The conclusion from this is that small amounts of strain will not
result in the variables to change and thus cause any corrosion that occurs to become critical in
sufficiently less time than would be the case with the original pipe to necessitate periodic
reinspection at shorter intervals than would ordinarily be the case.

A similar critical rate applies to internal corrosion. For the high-ductility pipe, a similar rate
could also be considered applicable with SCC, except that with the use of FBE coating SCC is
not considered a credible integrity threat. The reasons for this are: (a) the pipe surface
preparation imparts slight compressive stresses which resist SCC initiation (b) the FBE exhibits
,

high surface adherence and tends not to disbond while remaining intact, (c) the FBE absorbs
moisture which facilitates the ionic transfer necessary for effective cathodic protection, and (d)
no incidents of SCC have been reported where FBE coating was presentM.

Time-Stable Threats

The category of time-stable threats includes those caused by defective manufacturing or

inspection of the pipe body or seam, defective girth welds or adverse features related to the
construction of the pipeline, and defects associated with equipment or components other than the
pipe. It is obvious that minor yielding and plastic strain do not interact with threats associated
with non-pipe equipment such as valves, pressure regulators, instruments, or control equipment.
The pipe body strain is also insensitive to defective girth welding because failures at weld
defects are generally governed by the toughness and mechanical properties of the weld.

MEP was successfully tested with no pipe body failures to this minimum and in excess of 125
times the MAOP. Hydrostatic testing is an integrity assessment technique to ascertain the
condition of a pipeline segment with respect to a threat resulting from defective manufacturing or
inspection of the pipe body or seam. Hydrostatic pressure testing has a proven track record as an
effective assessment of the strength of pipe for safely operating at maximum pressures that are
below the test pressure by a suitable margin (113. According to ASME B31.8-S Paragraphs 6.3
"Pressure Testing" and A4 "Manufacturing Threat (Pipe Seam and Pipe)", a one-time hydrostatic
pressure test to a minimum pressure of 1.25 times the MAOP is an effective and adequate
assessment of pipe affected by pipe manufacturing defects in the time-stable category and
mitigation of that threat. Thus, MEP's successful completion of the Subpart J hydrostatic
pressure test to a minimum of 1.25 of the design MAOP effectively demonstrates the fitness of
any joints of pipe affected by a "manufacturing defect".

The possibility of pressure-cycle induced fatigue crack growth in the seams of natural gas
pipelines has been shown to be extremely low11°3. Therefore, this threat in a gas pipeline is not
considered a credible threat.

Random Event Integrity Threats

Random events that affect the pipe integrity include those due to mechanical damage caused by
the pipe being struck by equipment, natural events such as soil movement or flooding, operator
error, and deliberate human acts against the security of the system are not influenced by minor
yielding and plastic strain.

MEP is committed to conducting pipeline patrols on a monthly basis and is active in the
Common Ground Alliance and Public Awareness Programs to minimize third party damage. For
those situation that could result in a breach of the pressure boundary through penetration or
puncture, the resistance is primarily a function of the wall thickness, and secondarily a function
of the ultimate material strength. It is almost impossible for a backlioe or excavator in the size
range used with most construction projects to penetrate pipe wall in excess of 1/2 inch [123 .
Equipment much larger than the norm would be required. MEP uses pipe with wall thicknesses
of 0.555 inches and greater and therefore provides protection above that afforded by most pipe
wall dimensions.

Steel linepipe for MEP to a 65 ton excavator based on industry established calculations. The
bucket digging force F1 (in units of kN) is a function of the excavator weight WE (in units of
metric tonnes).

F= 30.39 + 5.450 WE - 0 .0211 9 WE + ELI

ELi is a random variable representing the model error introduced in curve fitting, which is
normally distributed with a mean value of 0. Since 65 U.S. tons equals 58.97 metric tonnes,

FP-- 278 kN
 The puncture resistance R (in units of kN) is a function of the pipe diameter (D), pipe wall
thickness (T), length of the bucket tooth (L), width of the bucket tooth cross section (W) and
ultimate tensile strength of the pipe (au).

R= [1.17- 0.0029 (D/T)] (L+W) T + ER

ER is a random variable representing the model error introduced in curve fitting, which is
normally distributed with a mean value of 0.8333 kN.

For NPS 42 x 0.555" (14.09 mm) WT API 5L Grade X70 line pipe (the thinnest pipe wall used
for the 42" segment of MEP) the puncture resistance equation reduces to:

R 0.01339 (L+W) at, + 0.8333

The document indicates the bucket parameters L and W have uniform distributions with mean
values of 90 mm for L and 3.5 mm for W with the ultimate tensile strength normally distributed.

. Using the mean values for L, W, and ou, the mean puncture resistance would be:

R^ 802 kN
—_
Since the mean resistance is approximately 802 kN while the force from a 65 ton excavator is
only 278 kN, the puncture resistance is demonstrated.

REFERENCES
1. Kiefaer, J. F., and Clark, E. B., History of Line Pipe Manufacturing in North America,
CRTD-Volume 43, ASME, 1996.
2. Duffy, A. R., McClure, G. M., Maxey, W. A., and Atterbury, T. J., "Study of Feasibility
of Basing Natural Gas Pipeline Operating Pressure on Hydrostatic Test Pressure", A. G.
A. Catalogue No. L30050, February 1968.
3. Brooks, L., "High-Pressure Testing – Pipeline Defect behavior and Pressure Reversals",
ASME, 68-PET-24, 1968.
4. Kiefaer, J. F., Maxey, W. A., and Duffy, A. R., "The Significance of the Yield-to-Tensile
Strength Ratio of Line Pipe Materials", Battelle Summary Report to Pipelines Research
Committee, A.G.A., March 31, 1971.
5. Boulger, F. W.,-"Role of Manufacturing Variables on the Properties of Line Pipe",
Symposium on Line Pipe Research, A.G.A, 1965.
6. Williams, D. N., "The Use of Flattened Specimens to Measure the Charpy V-Notch
Impact Properties of Thin-Wall Pipe", NG-18 Report No. 182, A.GA., December 1989.
7. Kiefner, J. F., and Maxey, W. A., "The Benefits and Limitations of Hydrostatic Testing"
8. Kiefner, J. F., Criteria of Reassessment Intervals for Low Stress Pipelines, GRI 02/0060,
2002.
9. TT08 Stress Corrosion Cracking Study, Integrity Management. Delivery Order Di RS56-
02-D-70036, Prepared by Michael Baker, Jr., Inc., January 2005.
10.Kiefner, J. F., and Rosenfeld, M. J., Effects of Pressure Cycles on Gas Pipelines, GRI-
04/0178, September 17, 2004.
11.Kiefner and Associates, Inc., Guide for Locating and Using Pipeline Industry Research, "Section
4, Hydrostatic Testing", GRI-00/0192.04, March 2001.
12.Chen, Q., and Nessim, M., "Reliability-Based Prevention of Mechanical Damage to
Pipelines", PR-244-9729, Pipeline Research Council International, Inc., Catalog No.
L51816, August 1999.
 Strobl

Figure 1. Stress Strain Curve Schematic

-
 • It .•••
_Lame I. inre Ty mana emenr inrearrixMat •
WAR :Si regg. •974gitifINTO,,7 0. lir 74-1 ef- .-tru ItinfoillfMart
Tflim 004ent :
Internal Smaller critical defect No interaction between ILI at standard
corrosion size minor strain and intervals
corrosion rate
External Smaller critical defect No interaction between ILI at standard
corrosion size minor strain and intervals
corrosion rate •
Stress corrosion Smaller critical defect No interaction between FBE coating, SCC not
cracking size minor strain and a credible threat
corrosion rate -
'zm e ,sta
. .:.:
Pipe and seam Smaller critical defect No interaction between Hydrostatic pressure
manufacturing size; possible seam minor strain and test at elevated
fatigue corrosion rate pressures.
Welding and None No interaction between 100% NDE,
fabrication minor strain and hydrostatic test
. corrosion rate
Non-pipe None No interaction between None necessary
equipment minor strain and
corrosion rate
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OP 1.:.:14 - ....!:;: .: -., _ 3.,-,:..:: _,..,2,,,,u. ; , '".:
,
Mechanical Smaller critical defect No interaction between Monthly pipeline
damage size minor strain and patrol, damage
corrosion rate prevention, puncture
resistance
Natural forces None No interaction between No known subsidence
minor strain and or fault lines in
corrosion rate _pipeline ROW
Operator error None No interaction between None necessary
minor strain and .
corrosion rate
Security threats None No interaction between None necessary
minor strain and •
corrosion rate