This adds a significant complication to our option of lining the #1 10" line 
with polyethylene.  Ronny, Rick and I will review this and try to talk 
directly to Fred Joyner, the DOT Region Chief.

Cutty
----- Forwarded by Cutty Cunningham/Houston/Eott on 07/20/00 05:40 PM -----

	Ronny Davenport
	07/19/00 08:49 PM
		 
		 To: Richard Johnson/Houston/Eott@Eott
		 cc: Cutty Cunningham/Houston/Eott@Eott, Dan Cole/Remote/Eott@Eott
		 Subject: Polyethylene liner in steel pipe

Per my action step from the meeting with Dana Gibbs and Dan Cole, I have 
contacted the Atlanta region of DOT.  I inquired about their take on the 
potential for installing a polyethylene liner in an existing steel pipe, at 
least as it relates to existing DOT regulations.   The Region Chief, Fred 
Joyner, was not in so I visited with a senior inspector. (I am in Midland, my 
notes in Houston and his name escapes me at the moment.)
 
Here is my understanding of the situation:
1. A waiver would be required.  
2. If the PE liner depends on the steel pipe for some of its strength, tests 
and study results would probably have to be submitted to DOT for their 
approval, before a waiver would be granted.  
3.  A liner not dependent on the steel pipe for strength could possibly be 
approved in 3-4 weeks.
4. I found four waivers that have been issued to date, one for Koch (now 
EOTT), one for Sun (now EOTT), and a couple of others.  All were for small 
diameter gathering lines that became jurisdictional by virture of their 
location.  No mention of a pipe liner in liquids service was found or 
referenced.  

 I will try another region, or perhaps Richard Sanders at TSI, on Friday.

In my judgment we are in uncharted water.  We can step out and take a risk 
(from a regulatory perspective) or we can try to bring the regulators on 
board using the "new and better technology" virtures of the liner.  In this 
scenario i believe the fluted liner would have a special appeal to them.  My 
thinking is that making them a partner in the application of new technology 
would hasten the approval process.  This type of liner meets the dual wall 
pipe concept so popular with the industry detractors of today.  Maybe, just 
maybe, in certain cases, it is a viable answer to that demand.  However, it 
is not the panacea that some would like.  Bottom line, I think perhaps a 
meeting with some DOT brass and the SE Region Chief would be appropriate.  We 
could have our vendor of choice present facts, figures and test results at 
that time.  I also believe the liner vendors have a tremendous vested 
interest in the outcome of this project.  This may be a factor in vendor 
selection, in that we want someone who offers well designed and tested 
product that can be supported in a professional manner.