August 27, 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 Ave. SE, E22-328
Washington, DC 20590

Reference: Rockies Express Pipeline, LLC (REX); Waiver: PHMSA-2006-23998

Dear Mr. Mayberry:

On behalf of REX, I, M. Dwayne Burton, Vice President of Operations and Engineering, certify
that the first portion of REX East pipeline (approximately 437 miles of 42" OD pipeline, from
Mexico, Missouri to Hamilton, Ohio) has been constructed and is operating in compliance with
the referenced Waiver PHMSA-2006-23998 and 49 CFR Part 192. All waiver/permit conditions
have been completed, with the project/construction documentation and the operations and
maintenance (O&M) procedure manual updates submitted to your office for review.

There are no identified safety concerns on the REX pipeline system that has been placed into .72
design MAOP service or safety concerns with elevating the pipeline pressure to .8 design
MAOP.

In addition, REX has reviewed its damage prevention program to assure that the REX damage
prevention program meets or exceeds the CGA best practices.

Supplemental requirements imposed by PHMSA regarding operating REX East at the .8 design
MAOP 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 437 miles of 42" OD pipe installed as the REX East system was inspected
utilizing the TD Williams "Magpie" high resolution caliper tool.
o All data requested by PHMSA concerning the results of the tool run have been
delivered to PHMSA.
o There are no .8 design pipe joints with nominal OD variation greater than 0.67 %.

One Allen Center 500 Dallas Street Suite 1000 Houston, Texas 77002
Mr. Alan Mayberry
USDOT — PHMSA
August 27, 2009
Page 2

o There are no other design factor pipe joints with nominal OD variation greater
than 0.79 %.
o All variations to the nominal OD 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 REX, I am requesting authorization to begin operating the REX East
portion of the project (437 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,

M. Dwayne BJrton
Vice President, Operations and Engineering
713.369.9356 Office

c: Ivan Huntoon, PHMSA

 APPENDIX A
TECHNICAL DISCUSSION FOR PIPE DIAMETERS IN EXCESS OF 0.6%
VARIATION TO THE PIPE BODY NOMINAL DIAMETER FOR ROCKIES EXPRESS
PIPELINE (REX)
August 27, 2009

INTRODUCTION

The Rockies Express Pipeline (REX) is a 42-inch diameter pipeline system constructed by
Rockies 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 REX EAST
segment of the pipeline from Mexico, MO to Hamilton, IL (approximately 437 miles), PHMSA
requested pipe diameter measurements to be obtained by performing an internal high resolution
caliper tool survey. PHMSA requested data on those joints having pipe body diameter
measurements in excess of a 0.6% variation from the outside nominal diameter (OD); therefore,
the results of the caliper tool survey were sorted to provide information and discuss those joints.
It was REX EAST'S understanding that the requested data for those joints having pipe body
diameter measurements in excess of 0.6% and up to 1.5% variation was for informational
purposes only, and was not intended to nor would require remedial actions.

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 108% 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 and standard practice 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,

1
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 131 . 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% [21 Of those pipe joints that undergo minor yielding, the yielding does not hurt or
.

damage sound pipe and does not affect pipeline integrity Pl. 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 may have occurred in some of
the REX EAST 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
(0.006%) exceeded the 0.6% pipe body nominal OD that may be attributable to field hydrostatic
testing at elevated pressures. This represents only 101 ft out of the approximate 437-mile long

2
(2,307,360 ft) pipeline segment or 3 joints out of 52,460 pipe joints used to construct the pipeline
segment.

An analysis of credible integrity threats determined that 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 REX
EAST pipe as manufactured, tested, and installed.

TECHNICAL ANALYSIS

Background

It is a regulatory requirement and standard practice 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. REX EAST subjected all pipe in the pipeline project to such pressure
tests with test pressures resulting in pipe stress up to 108% of pipe SMYS. It was observed
following completion of the pressure tests that some joints of pipe that were tested to these
elevated pressures may have experienced minor expansion. This minor yielding and plastic
strain was identified by making diameter measurements of each pipe by performing a high
resolution caliper tool inspection of the pipeline.

The results of the caliper tool survey identified that only a small percentage of pipe joints
(0.02%) exceeded the pipe body dimensional tolerance and represents approximately 434 ft out
of the 437-mile long (2,307,360 ft) pipeline segment. When assessing the overall performance
of the pipe, of the 434 ft, the joints had indications ranging from 0.61 % to 1.07% of the pipe
OD. The 434 ft corresponds to 11 joints out of over 52,460 joints used to construct the pipeline
segment. Further assessment of the joints shows that the measured OD variability of 8 out of the
11 joints resulted from the pipe mill manufacturing processes and not as the result of the field
hydrostatic test. The diameter of these 8 joints were measured as-received from the mill prior to
subjecting them to a field hydrostatic test, and then the OD was again measured after the field
hydrostatic test with no increase to the previously measured OD of the pipe. This essentially
removes these joints from the analysis. Therefore, after eliminating the 8 joints with dimensional

3
tolerance attributable to the pipe mill and manufacturing process, only 3 joints or 0.006% (101
ft) may be attributable the mill manufacturing process or to field hydrostatic testing at elevated
pressures and show marginal OD variability ranging from 0.61% to 0.79%. As will be discussed
later, the three remaining pipe joints were successfully strength tested and are suitable for use in
the 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 REX EAST 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 [2] . 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 OD variability was a result of the manufacturing process was
considered, and for several of the above referenced pipe joints, was confirmed. 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 when
testing in excess of 100% of the pipe SMYS.

FBE Coating inspection

The coating system used on the REX EAST consisted of a fusion-bonded epoxy (FBE) as the
primary coating. REX EAST performed pipe coating tests on the FBE in order to validate the
integrity of the coating. The coating on the above referenced 8 joints that were received from the
pipe mill with pipe the body measurements in excess of the tolerance was initially visually
inspected for indications of coating stress and coating cracks. The coating was also subjected to

4
electronic holiday detection after the field hydrostatic test 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 can be performed utilizing five separate grading classifications. The
classifications are 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 coating inspection of the eight referenced pipe joints did not observe any coating cracks or
stress indications prior to the field hydrostatic test and then again after the field hydrostatic test.
The results of this inspection verify that these eight pipe joints did not undergo yielding or plastic
strain from the field hydrostatic test.

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 REX EAST 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 600 F•for more than 1 hour or 900 F for any period. This
limitation does not apply to REX EAST because the pipe has 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

6
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 [11 . 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 during 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 [23 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 for 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

7
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 [2] .

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 [23 . Elongation properties of the REX
EAST pipe range from 33% to 36%. The elongation in the pipe population would not have been

8
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 143. The Y/T values for the REX EAST pipe are approximately 0.88,
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

9
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

tF=1,0 — riiirtp=0:,5, 0) YS
JR.F=0,50, = 1,000 15 yrs YS 10,000

where rwtF is the uniform remaining wall thickness that could just survive at the hoop stress
corresponding to FxYS [8] . 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 present [91 .

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.

10
REX EAST was successfully tested with no pipe body failures to this minimum and in excess of
1.25 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 marginf l 13 . 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, REX EAST'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 low"i. 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.

REX EAST 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 situations 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. REX EAST uses high strength API 5L X80 and X70 pipe with
wall thicknesses of 0.486 inches and greater and therefore provides a high level of protection.

The steel pipe for REX EAST can resist punctures to a 65 ton excavator and larger based on
industry calculation methods. The bucket digging force F1 of an excavator (in units of kN) is a
function of the excavator weight WE (in units of metric tonnes).

11
F= 30.39 + 5.450 WE 0.02119 WE 2 + 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 35 U.S. tons equals 31.75 metric tonnes,
182 kN
According to the document, 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 CTu + 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 0.486" (12.34 mm) WT API 5L Grade X80 linepipe, the puncture resistance
equation reduces to:
RR 0.0113 (L+W) +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. The document assumes the ultimate tensile strength is
normally distributed.
Table 6.3 of the document lists a mean tensile strength of 640 MPa for Grade X70 (75 MPa
above the API 5L specified minimum tensile strength of 565 MPa). For Grade X80, if the mean
tensile strength is similarly assumed to be 75 MPa above the API 5L specified minimum of 621
MPa, the mean tensile strength would be 696 MPa.
Using the mean values for L, W, and au, the mean puncture resistance would be:
RR 736 kN
Since the mean resistance is approximately 736 kN while the force from a 65 ton excavator is
only 278 kN, the puncture resistance is demonstrated.
REFERENCES
1. Kiefner, 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. Kiefner, 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.G.A., December 1989.
7. Kiefner,..T. F., and Maxey, W. A., "The Benefits and Limitations of Hydrostatic Testing"

12
8. Kiefner, J. F., Criteria of Reassessment Intervals for Low Stress Pipelines, GRI 02/0060,
2002.
9. TTO8 Stress Corrosion Cracking Study, Integrity Management Delivery Order DTRS56-
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 Nessirn, M., "Reliability-Based Prevention of Mechanical Damage to
Pipelines", PR-244-9729, Pipeline Research Council International, Inc., Catalog No.
L51816, August 1999.

13
Stress

Yield
Elastic
limit

0.005 Strain

Figure 1. Stress Strain Curve Schematic

-

14
Table 1. Integrity Management Threat Matrix
Tliteat: . Me,-1,Pf, educe tY Oilimen. . :Mitigation
Time dependent
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
Time stable
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
Random
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

15