# NTSB Safety Recommendation P-11-014 **Citation:** P-11-014 **Type / status:** guidance / guidance **Agency:** National Transportation Safety Board **Effective:** 2011-09-26 **Published:** 2011-09-26 TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Amend Title 49 Code of Federal Regulations 192.619 to delete the grandfather clause and require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. ## Document text NTSB safety recommendation P-11-014. TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Amend Title 49 Code of Federal Regulations 192.619 to delete the grandfather clause and require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. Priority: CLASS II Overall Status: Closed - Acceptable Alternate Action Issued Date: 2011-09-26 Adopted Date: 2011-09-12 Overall Date Closed: 2020-01-23 Synopsis: On September 9, 2010, about 6:11 p.m. Pacific daylight time,1 a 30-inch-diameter underground natural gas transmission pipeline (which is identified by the company as Line 132), owned and operated by Pacific Gas and Electric Company (PG&E), ruptured in a residential area in San Bruno, California. The accident killed eight people, injured many more, and caused substantial property damage. The rupture on Line 132 occurred near mile point 39.28, at the intersection of Earl Avenue and Glenview Drive in San Bruno. About 47.6 million standard cubic feet of natural gas were released as a result of the rupture. The released natural gas was ignited after the rupture; the subsequent explosion created a crater about 72 feet long by 26 feet wide, and the resulting fire destroyed 38 homes and damaged 70. A ruptured pipe segment about 28 feet long was found about 100 feet away from the crater. Probable Cause: The National Transportation Safety Board determines that the probable cause of the accident was the Pacific Gas and Electric Company's (PG&E) (1) inadequate quality assurance and quality control in 1956 during its Line 132 relocation project, which allowed the installation of a substandard and poorly welded pipe section with a visible seam weld flaw that, over time grew to a critical size, causing the pipeline to rupture during a pressure increase stemming from poorly planned electrical work at the Milpitas Terminal; and (2) inadequate pipeline integrity management program, which failed to detect and repair or remove the defective pipe section. Ntsbnumber: DCA10MP008 Report Number: PAR-11-01 Addressee Name: PHMSA Addressee Status: Closed - Acceptable Alternate Action Addressee Date Closed: 2020-01-23 Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2011-12-07 Communication Type: NPRM Response Communication Contents: Notation 8360: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) Advance Notice of Proposed Rulemaking (ANPRM), “Pipeline Safety: Safety of Gas Transmission Pipelines,” that was published in the Federal Register on August 25, 2011. PHMSA is considering whether changes to the regulations governing the safety of gas transmission pipelines are needed, and is inviting comments on 14 specific topic areas in 2 broad categories—integrity management-related requirements and nonintegrity management requirements. In the area of integrity management, PHMSA is seeking comments and information about revising the definition of high consequence areas (HCA), including more prescriptive language, and placing additional restrictions on the use of specific pipeline assessment methods. In the nonintegrity management area, PHMSA is seeking information and comments about strengthening or expanding requirements for the spacing of mainline valves; installation of remotely operated or automatically operated valves; and corrosion control of steel pipelines, gas gathering lines, and underground gas storage facilities. The NTSB believes that the regulations for gas transmission pipelines can and should be improved and supports the overall intent of the ANPRM. However, the publication of the ANPRM 5 days before the NTSB public meeting on the Pacific Gas and Electric Company (PG&E) natural gas transmission pipeline rupture in San Bruno, California, precluded any mention in the ANPRM of the safety recommendations the NTSB adopted at the public meeting held on August 30, 2011, and issued on September 26, 2011. As a result of the Board Meeting, the NTSB issued 13 safety recommendations (P-11-8 through P-11-20) to PHMSA to improve the safety of natural gas transmission pipelines. The NTSB believes PHMSA should seek comments and information related to its safety recommendations to PHMSA issued as a result of the San Bruno investigation to take certain regulatory actions. In the ANPRM, PHMSA is also seeking information that would be relevant to Safety Recommendation P-93-9 the NTSB issued as a result of its accident investigation of an explosion and fire of a natural gas pipeline from a salt dome storage cavern in Brenham, Texas, on April 7, 1992. The accident resulted in 3 fatalities and 21 injuries. Safety Recommendation P-93-9 was classified “Closed—Unacceptable Action” on July 27, 1998, after a rulemaking proceeding to regulate underground gas storage was terminated in 1997. The NTSB supports PHMSA’s intention to reconsider regulating underground gas storage and is pleased PHMSA is revisiting this issue by seeking information and comment in this ANPRM. In support of our position, the NTSB is providing the following table listing the NTSB’s responses (that is, previously issued safety recommendations) to certain specific questions posed by PHMSA in the ANPRM: PHMSA’s ANPRM Questions NTSB’s Responses (Safety Recommendations) K.1. Should PHMSA develop Federal standards governing the safety of underground gas storage facilities? If so, should they be voluntary? If so, what portions of the facilities should be addressed in these standards? Develop safety requirements for storage of highly volatile liquids and natural gas in underground facilities, including a requirement that all pipeline operators perform safety analyses of new and existing underground geologic storage systems to identify potential failures, determine the likelihood that each failure will occur, and assess the feasibility of reducing the risk; require that operators incorporate all feasible improvements. (P-93-9) K.6. What standards are used for emergency shutdowns, emergency shutdown stations, gas monitors, local emergency response communications, public communications, and O&M Procedures? Require operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to provide system-specific information about their pipeline systems to the emergency response agencies of the communities and jurisdictions in which those pipelines are located. This information should include pipe diameter, operating pressure, product transported, and potential impact radius. (P-11-8) L.1. Are there standards used by the pipeline industry to guide management processes including management of change? Do standards governing the management of change process include requirements for IM procedures, O&M manuals, facility drawings, emergency response plans and procedures, and documents required to be maintained for the life of the pipeline? Require operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to ensure that their control room operators immediately and directly notify the 911 emergency call center(s) for the communities and jurisdictions in which those pipelines are located when a possible rupture of any pipeline is indicated. (P-11-9) PHMSA’s ANPRM Questions NTSB’s Responses (Safety Recommendations) B.4. What measures, if any, should operators be required explicitly to implement? Should they apply to all HCAs, or is there some reasonable basis for tailoring explicit mandates to particular HCAs? Should additional preventative and mitigative measures include any or all of the following: Additional line markers (line-of-sight); depth of cover surveys; close interval surveys for cathodic protection (CP) verification; coating surveys and recoating to help maintain CP current to pipe; additional right-of-way patrols; shorter ILI run intervals; additional gas quality monitoring, sampling, and in-line inspection tool runs; and improved standards for marking pipelines for operator construction and maintenance and one-calls? Require that all operators of natural gas transmission and distribution pipelines equip their supervisory control and data acquisition systems with tools to assist in recognizing and pinpointing the location of leaks, including line breaks; such tools could include a real-time leak detection system and appropriately spaced flow and pressure transmitters along covered transmission lines. (P-11-10) Amend Title 49 Code of Federal Regulations 192.935(c) to directly require that automatic shutoff valves or remote control valves in high consequence areas and in class 3 and 4 locations be installed and spaced at intervals that consider the factors listed in that regulation. (P-11-11) M.4. Are there any standards that exist that PHMSA could adopt or from which PHMSA could adapt concepts for Quality Management System (QMS)? Amend Title 49 Code of Federal Regulations 199.105 and 49 Code of Federal Regulations 199.225 to eliminate operator discretion with regard to testing of covered employees. The revised language should require drug and alcohol testing of each employee whose performance either contributed to the accident or cannot be completely discounted as a contributing factor to the accident. (P-11-12) Issue immediate guidance clarifying the need to conduct postaccident drug and alcohol testing of all potentially involved personnel despite uncertainty about the circumstances of the accident. (P-11-13) N.2. Should PHMSA repeal the MAOP exemption for pre-1970 pipelines? Should pre-1970 pipelines that operate above 72% SMYS be allowed to continue to be operated at these levels without increased safety evaluations such as periodic pressure tests, in-line inspections, coating examination, CP surveys, and expanded requirements on interference currents and depth of cover maintenance? N.3. Should PHMSA take any other actions with respect to exempt pipelines? Amend Title 49 Code of Federal Regulations 192.619 to delete the grandfather clause and require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. (P- Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2016-06-06 Communication Type: NPRM Response Communication Contents: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) notice of proposed rulemaking (NPRM), Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines, published on April 8, 2016. This NPRM addresses issues raised in an August 25, 2011, advance notice of proposed rulemaking (ANPRM) regarding the revision of pipeline safety regulations applicable to the safety of gas transmission and gas gathering pipelines, particularly those involving integrity management (IM). Proposal Topic N—Exemption of Facilities Installed Prior to the Regulations Summary In the accident report of the September 9, 2010, pipe rupture in San Bruno, California, the NTSB recommended that PHMSA repeal the “grandfather clause” provided in 49 CFR 192.619(c) that allows exemptions for pressure testing to establish the MAOP of certain pipelines. In this safety recommendation, the NTSB urged PHMSA to require that all gas transmission pipelines be pressure tested, including a spike test, to establish the MAOP. Amend Title 49 Code of Federal Regulations 192.619 to delete the grandfather clause and require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. (P-11-14) PHMSA proposes to repeal the grandfather clause and establish comprehensive pressure test requirements for verification of the MAOP for certain on-shore, steel, gas transmission pipelines. PHMSA also proposes requirements to confirm and record the physical and operational characteristics for covered pipelines for which adequate records are not available. Response The NTSB is pleased that PHMSA is moving forward with the activities necessary to implement the actions proposed in the recommendation. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2020-01-23 Communication Type: Official Correspondence Communication Contents: We note that, on April 8, 2016, you published an NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” to address these recommendations, and in our June 6, 2016, comments about the NPRM, we said the proposed rule was likely to satisfy Safety Recommendations P 11 14 and 15. The final rule, however, published on October 1, 2019, and effective July 1, 2020, does not completely eliminate the grandfather clause in certain low-risk situations, as recommended. Further, you did not include a requirement for spike testing, as recommended, because you believe such a requirement should be discussed in the context of integrity management (IM). However, you have implemented a new regulatory section, 192.624, to address Safety Recommendation P 11 14, which also addresses mandates specified in the 2011 Pipeline Safety Act. The new section specifies that the following methods can be used to reconfirm the MAOP: • Pressure test. • Pressure reduction. • Engineering critical assessment. • Pipe replacement. • Pressure reduction. • Alternative technology. These actions are an alternative that meets the intent of Safety Recommendation P 11 14, which is classified CLOSED--ACCEPTABLE ALTERNATE ACTION We further note that revisions to section 192.917(e) (3) in the final rule satisfy Safety Recommendation P 11 15, which is classified "Closed--Acceptable Action." Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2018-02-21 Communication Type: Official Correspondence Communication Contents: We note that, on April 8, 2016, you published an NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” to address these recommendations, and in our June 6, 2016, comments about the NPRM, we said it was likely to satisfy them. We further note that, although you expected to publish the final rule by the end of 2017, publication has been delayed by the governmentwide regulatory review required by executive order. Pending publication of the final rule, Safety Recommendations P-11-14 and -15 remain classified OPEN--ACCEPTABLE RESPONSE. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2016-12-05 Communication Type: Official Correspondence Communication Contents: On June 6, 2016, in our comments to your NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” published on April 8, 2016, we expressed approval that you were moving forward on actions necessary to implement this recommendation. We appreciate this update, which gives an overview of the actions taken and those planned to address this issue. Pending publication of final rules, Safety Recommendation P-11-14 is classified OPEN—ACCEPTABLE RESPONSE. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2014-01-03 Communication Type: Official Correspondence Communication Contents: We are encouraged that, on August 7, 2013, PHMSA conducted a public workshop to present its proposed Integrity Verification Process (IVP) for ensuring that pipeline operators address testing requirements to demonstrate seam stability and confirm the material strength of untested gas transmission pipelines. We note that PHMSA will formalize the IVP in upcoming rulemaking and is considering the recommended removal of the grandfather clause. Pending publication of the final rule as recommended, Safety Recommendations P-11-14 and -15 remain classified OPEN—ACCEPTABLE RESPONSE. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2015-04-08 Communication Type: Official Correspondence Communication Contents: We are aware from your August 29, 2013, update that you conducted a public workshop on the integrity verification, planned to formalize the process in rulemaking, and were considering the recommended removal of the grandfather clause. We are disappointed that you still have not initiated the expected rulemaking; however, we are encouraged that you plan to do so. We encourage you to expedite this action. Pending timely publication of a final rule that satisfies these recommendations, Safety Recommendations P-11-14 and -15 remain classified OPEN—ACCEPTABLE RESPONSE. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2012-04-24 Communication Type: Official Correspondence Communication Contents: Because PHMSA initiated regulatory action to address these issues, with the August 2011 issuance of an ANPRM, Pipeline Safety: Safety of Gas Transmission Pipelines, Safety Recommendations P-11-11, -14, and -15 are classified OPEN—ACCEPTABLE RESPONSE, pending publication of the recommended final rule. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2019-04-01 Communication Type: Official Correspondence Communication Contents: -From Howard R. Elliott, Administrator: PHMSA appreciates the NTSB's comments on the NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines" (the Gas Rule),2 noting PHMSA's efforts to implement this recommendation. PHMSA developed a maximum allowable operating pressure (MAOP) reconfirmation process that includes additional testing requirements to confirm the material strength of certain gas transmission pipelines, including pipelines where, pursuant to 49 CFR § 192.619, the operator established the MAOP using the grandfather clause. PHMSA proposed this MAOP reconfirmation process in the Gas Rule NPRM . In March 2018, PHMSA separated the Gas Rule into the following three rulemaking actions: • Pipeline Safety: Safety of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments (RIN 2137-AE72); • Pipeline Safety: Safety of Gas Transmission Pipelines, Repair Criteria, Integrity Management (IM) Improvements, Cathodic Protection, Management of Change, and Other Related Amendments (RIN 2137-AF39); and • Pipeline Safety: Safety of Gas Gathering Pipelines (RIN 2137-AF38). PHMSA believes that this separation will help move each individual proposed rule forward more quickly. PHMSA plans to address this recommendation in the "Pipeline Safety: Safety of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments" final rule, which is expected to be published in August 2019, according to the DOT's March 2019 Significant Rulemakings Report. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2019-12-03 Communication Type: Official Correspondence Communication Contents: -From Howard R. Elliott, Administrator: PHMSA proposes closure of this recommendation. On October 1, 2019, PHMSA published the "Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments" final rule. Section 192.624 of the final rule requires operators to reconfirm the MAOP of grandfathered pipelines in high consequence areas (HCAs), Class 3 locations, Class 4 locations, and "moderate consequence areas" that can accommodate inspection by means of an instrumented inline inspection tool. PHMSA also included a spike testing methodology in § 192.506 that operators will use whenever required by other requirements in part 192 to address crack remediation and the integrity threat of cracks and crack-like defects. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2017-11-13 Communication Type: Official Correspondence Communication Contents: -From Howard R. Elliott, Administrator: PHMSA appreciates NTSB's comments on the Gas Transmission NPRM, expressing approval on PHMSA's actions towards implementing this recommendation. PHMSA developed an Integrity Verification Process (IVP), which includes additional testing requirements to demonstrate seam stability and to confirm material strength of untested gas transmission pipelines operating under the Grandfather Clause. IVP was proposed in PHMSA's NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines" (81 FR 20721 ), published on April 8, 2016 (https://www.federalregister.gov/documents/2016/04/08/2016-063 82/pipeline-safetysafety-of-gas-transmission-and-gathering-pipelines ). PHMSA held Gas Pipeline Advisory Committee (GPAC) meetings on the rule on January 12, 2017, and on June 6-7, 2017. PHMSA plans to hold additional meetings in December 2017 to continue discussing the proposed rule. The final rule was initially expected to publish by the end of2017. Due to the continued process of gathering GP AC recommendations, we are expecting delays and currently assessing impacts. Like many other issues before us, this is part of an ongoing regulatory review pursuant to the executive order issued by the President. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2016-08-17 Communication Type: Official Correspondence Communication Contents: -From Marie Therese Dominguez, Administrator: PHMSA has developed an integrity Verification Process (IVP), which includes additional testing requirements to demonstrate seam stability and to confirm material strength of untested gas transmission pipelines operating under the "Grandfather Clause." The IVP was proposed in PHMSA 's NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines," published on April 8, 2016. The comment period closed on July 7, 2016. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2013-08-29 Communication Type: Official Correspondence Communication Contents: -From Cynthia L. Quarterman, Administrator: PHMSA is developing an Integrity Verification Process (IVP) to assure that pipeline operators take the appropriate steps to ensure safe operation, address testing requirements to demonstrate seam stability, and confirm the material strength of untested gas transmission pipelines. On August 7, 2013, PHMSA conducted a public workshop to present its proposed IVP and seek comment. PHMSA expresses its thanks to the Honorable Christopher A. Hart, NTSB Vice-Chair, for presenting the findings of the San Bruno investigation and providing NTSB’s perspective on integrity verification during the workshop. PHMSA will formalize the IVP in an upcoming rulemaking. PHMSA is also considering rulemaking to remove the “Grandfather Clause.” Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2015-01-22 Communication Type: Official Correspondence Communication Contents: -From Timothy P. Butters, Acting Administrator: PHMSA is formalizing an NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines," which will address this recommendation. PHMSA has developed a proposed Integrity Verification Process (IVP) to assure that pipeline operators take the appropriate steps to ensure safe operations, which includes additional testing requirements to demonstrate seam stability and to confirm material strength of untested gas transmission pipelines. On August 7, 2013, PHMSA conducted a public workshop to present its proposed IVP and seek comment. PHMSA expresses its gratitude to the Honorable Christopher A. Hart, NTSB Acting Chair, for presenting the findings of the San Bruno investigation and providing NTSB's perspective on integrity verification during the workshop. The NPRM is currently under agency review, and we expect to publish in 2015. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2011-12-14 Communication Type: Official Correspondence Communication Contents: -From Cynthia L. Quarterman, Administrator: In our August 2011 gas transmission ANPRM referenced earlier, PHMSA began rulemaking on this and other issues relating to the San Bruno failure. We intend to advance rulemaking to address this topic during CY 2012. Removing the grandfather clause for all gas transmission pipelines will involve significant technical and economic challenges and is likely to require time to implement. Notwithstanding, PHMSA will evaluate several options for implementing this recommendation. To commence these actions PHMSA is initiating an OMB-approved information collection effort to gather key data needed to characterize the quantity and locations of pre-1970 gas transmission pipelines operating under the grandfather clause accurately. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Type: Official Correspondence ## Provenance - Official: Yes - Source: - Source ID: `ntsb-pipeline` - SHA-256: `a3a5671985fc5ee9987e0bf0ffa39133cdaef3d217c31b8947863879597b3c92` - Retrieved: 2026-08-20T04:57:24.741Z - Exported: 2026-08-22T15:38:36.840Z - Document slug: `ntsb-recommendation-p-11-014` ### Source metadata ```json { "recordKind": "ntsb_safety_recommendation", "safetyRecommendationNumber": "P-11-014", "recommendationMode": "Pipeline", "topicMode": "Pipeline", "ntsbNumber": "DCA10MP008", "priority": "CLASS II", "overallStatus": "Closed - Acceptable Alternate Action", "overallStatusAcronym": "CAAA", "overallDateClosed": "2020-01-23", "lastModifiedDate": "2023-08-30", "reportNumber": "PAR-11-01", "reportUrl": "https://www.ntsb.gov/investigations/Pages/DCA10MP008.aspx", "transmittalLetterUrl": "http://www.ntsb.gov/safety/safety-recs/recletters/P-11-008-020.pdf", "addressees": [ { "addresseeName": "PHMSA", "addresseeStatusAcronym": "CAAA", "addresseeStatus": "Closed - Acceptable Alternate Action", "addresseeDateClosed": "2020-01-23", "addresseeDetails": [ { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "2011-12-07", "communicationType": "NPRM Response", "communicationContents": "Notation 8360: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) Advance Notice of Proposed Rulemaking (ANPRM), “Pipeline Safety: Safety of Gas Transmission Pipelines,” that was published in the Federal Register on August 25, 2011. \r\nPHMSA is considering whether changes to the regulations governing the safety of gas transmission pipelines are needed, and is inviting comments on 14 specific topic areas in 2 broad categories—integrity management-related requirements and nonintegrity management requirements. In the area of integrity management, PHMSA is seeking comments and information about revising the definition of high consequence areas (HCA), including more prescriptive language, and placing additional restrictions on the use of specific pipeline assessment methods. In the nonintegrity management area, PHMSA is seeking information and comments about strengthening or expanding requirements for the spacing of mainline valves; installation of remotely operated or automatically operated valves; and corrosion control of steel pipelines, gas gathering lines, and underground gas storage facilities. \r\nThe NTSB believes that the regulations for gas transmission pipelines can and should be improved and supports the overall intent of the ANPRM. However, the publication of the ANPRM 5 days before the NTSB public meeting on the Pacific Gas and Electric Company (PG&E) natural gas transmission pipeline rupture in San Bruno, California, precluded any mention in the ANPRM of the safety recommendations the NTSB adopted at the public meeting held on August 30, 2011, and issued on September 26, 2011.\r\nAs a result of the Board Meeting, the NTSB issued 13 safety recommendations (P-11-8 through P-11-20) to PHMSA to improve the safety of natural gas transmission pipelines. The NTSB believes PHMSA should seek comments and information related to its safety recommendations to PHMSA issued as a result of the San Bruno investigation to take certain regulatory actions.\r\nIn the ANPRM, PHMSA is also seeking information that would be relevant to Safety Recommendation P-93-9 the NTSB issued as a result of its accident investigation of an explosion and fire of a natural gas pipeline from a salt dome storage cavern in Brenham, Texas, on April 7, 1992. The accident resulted in 3 fatalities and 21 injuries. Safety Recommendation P-93-9 was classified “Closed—Unacceptable Action” on July 27, 1998, after a rulemaking proceeding to regulate underground gas storage was terminated in 1997. The NTSB supports PHMSA’s intention to reconsider regulating underground gas storage and is pleased PHMSA is revisiting this issue by seeking information and comment in this ANPRM. \r\nIn support of our position, the NTSB is providing the following table listing the NTSB’s responses (that is, previously issued safety recommendations) to certain specific questions posed by PHMSA in the ANPRM: \r\n\r\nPHMSA’s \r\nANPRM Questions\tNTSB’s Responses\r\n(Safety Recommendations)\r\n\r\nK.1. Should PHMSA develop Federal standards governing the safety of underground gas storage facilities? If so, should they be voluntary? If so, what portions of the facilities should be addressed in these standards?\t\r\nDevelop safety requirements for storage of highly volatile liquids and natural gas in underground facilities, including a requirement that all pipeline operators perform safety analyses of new and existing underground geologic storage systems to identify potential failures, determine the likelihood that each failure will occur, and assess the feasibility of reducing the risk; require that operators incorporate all feasible improvements. (P-93-9)\r\n\r\n\r\nK.6. What standards are used for emergency shutdowns, emergency shutdown stations, gas monitors, local emergency response communications, public communications, and O&M Procedures?\t\r\nRequire operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to provide system-specific information about their pipeline systems to the emergency response agencies of the communities and jurisdictions in which those pipelines are located. This information should include pipe diameter, operating pressure, product transported, and potential impact radius. (P-11-8)\r\n\r\n\r\nL.1. Are there standards used by the pipeline industry to guide management processes including management of change? Do standards governing the management of change process include requirements for IM procedures, O&M manuals, facility drawings, emergency response plans and procedures, and documents required to be maintained for the life of the pipeline?\r\n\t\r\nRequire operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to ensure that their control room operators immediately and directly notify the 911 emergency call center(s) for the communities and jurisdictions in which those pipelines are located when a possible rupture of any pipeline is indicated. (P-11-9)\r\n\r\n \r\nPHMSA’s \r\nANPRM Questions\tNTSB’s Responses\r\n(Safety Recommendations)\r\n\r\nB.4. What measures, if any, should operators be required explicitly to implement? Should they apply to all HCAs, or is there some reasonable basis for tailoring explicit mandates to particular HCAs? Should additional preventative and mitigative measures include any or all of the following: Additional line markers (line-of-sight); depth of cover surveys; close interval surveys for cathodic protection (CP) verification; coating surveys and recoating to help maintain CP current to pipe; additional right-of-way patrols; shorter ILI run intervals; additional gas quality monitoring, sampling, and in-line inspection tool runs; and improved standards for marking pipelines for operator construction and maintenance and one-calls?\r\n\t\r\nRequire that all operators of natural gas transmission and distribution pipelines equip their supervisory control and data acquisition systems with tools to assist in recognizing and pinpointing the location of leaks, including line breaks; such tools could include a real-time leak detection system and appropriately spaced flow and pressure transmitters along covered transmission lines. (P-11-10)\r\n\r\nAmend Title 49 Code of Federal Regulations 192.935(c) to directly require that automatic shutoff valves or remote control valves in high consequence areas and in class 3 and 4 locations be installed and spaced at intervals that consider the factors listed in that regulation. (P-11-11)\r\n\r\nM.4. Are there any standards that exist that PHMSA could adopt or from which PHMSA could adapt concepts for Quality Management System (QMS)?\t\r\nAmend Title 49 Code of Federal Regulations 199.105 and 49 Code of Federal Regulations 199.225 to eliminate operator discretion with regard to testing of covered employees. The revised language should require drug and \r\nalcohol testing of each employee whose performance either contributed to the accident or cannot be completely discounted as a contributing factor to the accident. \r\n(P-11-12)\r\n\r\nIssue immediate guidance clarifying the need to conduct postaccident drug and alcohol testing of all potentially involved personnel despite uncertainty about the circumstances of the accident. (P-11-13)\r\n\r\n\r\nN.2. Should PHMSA repeal the MAOP exemption for pre-1970 pipelines? Should pre-1970 pipelines that operate above 72% SMYS be allowed to continue to be operated at these levels without increased safety evaluations such as periodic pressure tests, in-line inspections, coating examination, CP surveys, and expanded requirements on interference currents and depth of cover maintenance? \r\n\r\nN.3. Should PHMSA take any other actions with respect to exempt pipelines?\r\n\t\r\nAmend Title 49 Code of Federal Regulations 192.619 to delete the grandfather clause and require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. (P-" }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "2016-06-06", "communicationType": "NPRM Response", "communicationContents": "The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) notice of proposed rulemaking (NPRM), Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines, published on April 8, 2016. This NPRM addresses issues raised in an August 25, 2011, advance notice of proposed rulemaking (ANPRM) regarding the revision of pipeline safety regulations applicable to the safety of gas transmission and gas gathering pipelines, particularly those involving integrity management (IM). \r\nProposal Topic N—Exemption of Facilities Installed Prior to the Regulations\r\nSummary\r\nIn the accident report of the September 9, 2010, pipe rupture in San Bruno, California, the NTSB recommended that PHMSA repeal the “grandfather clause” provided in 49 CFR 192.619(c) that allows exemptions for pressure testing to establish the MAOP of certain pipelines. In this safety recommendation, the NTSB urged PHMSA to require that all gas transmission pipelines be pressure tested, including a spike test, to establish the MAOP.\r\nAmend Title 49 Code of Federal Regulations 192.619 to delete the grandfather clause and require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. (P-11-14)\r\nPHMSA proposes to repeal the grandfather clause and establish comprehensive pressure test requirements for verification of the MAOP for certain on-shore, steel, gas transmission pipelines. PHMSA also proposes requirements to confirm and record the physical and operational characteristics for covered pipelines for which adequate records are not available.\r\nResponse\r\nThe NTSB is pleased that PHMSA is moving forward with the activities necessary to implement the actions proposed in the recommendation." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "2020-01-23", "communicationType": "Official Correspondence", "communicationContents": "We note that, on April 8, 2016, you published an NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” to address these recommendations, and in our June 6, 2016, comments about the NPRM, we said the proposed rule was likely to satisfy Safety Recommendations P 11 14 and 15. The final rule, however, published on October 1, 2019, and effective July 1, 2020, does not completely eliminate the grandfather clause in certain low-risk situations, as recommended. Further, you did not include a requirement for spike testing, as recommended, because you believe such a requirement should be discussed in the context of integrity management (IM). However, you have implemented a new regulatory section, 192.624, to address Safety Recommendation P 11 14, which also addresses mandates specified in the 2011 Pipeline Safety Act. The new section specifies that the following methods can be used to reconfirm the MAOP:\r\n\r\n•\tPressure test. \r\n•\tPressure reduction. \r\n•\tEngineering critical assessment. \r\n•\tPipe replacement. \r\n•\tPressure reduction. \r\n•\tAlternative technology. \r\n\r\nThese actions are an alternative that meets the intent of Safety Recommendation P 11 14, which is classified CLOSED--ACCEPTABLE ALTERNATE ACTION We further note that revisions to section 192.917(e) (3) in the final rule satisfy Safety Recommendation P 11 15, which is classified \"Closed--Acceptable Action.\"" }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "2018-02-21", "communicationType": "Official Correspondence", "communicationContents": "We note that, on April 8, 2016, you published an NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” to address these recommendations, and in our June 6, 2016, comments about the NPRM, we said it was likely to satisfy them. We further note that, although you expected to publish the final rule by the end of 2017, publication has been delayed by the governmentwide regulatory review required by executive order. Pending publication of the final rule, Safety Recommendations P-11-14 and -15 remain classified OPEN--ACCEPTABLE RESPONSE." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "2016-12-05", "communicationType": "Official Correspondence", "communicationContents": "On June 6, 2016, in our comments to your NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” published on April 8, 2016, we expressed approval that you were moving forward on actions necessary to implement this recommendation. We appreciate this update, which gives an overview of the actions taken and those planned to address this issue. Pending publication of final rules, Safety Recommendation P-11-14 is classified OPEN—ACCEPTABLE RESPONSE." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "2014-01-03", "communicationType": "Official Correspondence", "communicationContents": "We are encouraged that, on August 7, 2013, PHMSA conducted a public workshop to present its proposed Integrity Verification Process (IVP) for ensuring that pipeline operators address testing requirements to demonstrate seam stability and confirm the material strength of untested gas transmission pipelines. We note that PHMSA will formalize the IVP in upcoming rulemaking and is considering the recommended removal of the grandfather clause. Pending publication of the final rule as recommended, Safety Recommendations P-11-14 and -15 remain classified OPEN—ACCEPTABLE RESPONSE." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "2015-04-08", "communicationType": "Official Correspondence", "communicationContents": "We are aware from your August 29, 2013, update that you conducted a public workshop on the integrity verification, planned to formalize the process in rulemaking, and were considering the recommended removal of the grandfather clause. We are disappointed that you still have not initiated the expected rulemaking; however, we are encouraged that you plan to do so. We encourage you to expedite this action. Pending timely publication of a final rule that satisfies these recommendations, Safety Recommendations P-11-14 and -15 remain classified OPEN—ACCEPTABLE RESPONSE." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "2012-04-24", "communicationType": "Official Correspondence", "communicationContents": "Because PHMSA initiated regulatory action to address these issues, with the August 2011 issuance of an ANPRM, Pipeline Safety: Safety of Gas Transmission Pipelines, Safety Recommendations P-11-11, -14, and -15 are classified OPEN—ACCEPTABLE RESPONSE, pending publication of the recommended final rule." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "2019-04-01", "communicationType": "Official Correspondence", "communicationContents": "-From Howard R. Elliott, Administrator: PHMSA appreciates the NTSB's comments on the NPRM titled \"Pipeline Safety: Safety of Gas Transmission Pipelines\" (the Gas Rule),2 noting PHMSA's efforts to implement this recommendation.\r\n\r\nPHMSA developed a maximum allowable operating pressure (MAOP) reconfirmation process that includes additional testing requirements to confirm the material strength of certain gas transmission pipelines, including pipelines where, pursuant to 49 CFR § 192.619, the operator established the MAOP using the grandfather clause. PHMSA proposed this MAOP reconfirmation process in the Gas Rule NPRM \r\n. In March 2018, PHMSA separated the Gas Rule into the following three rulemaking actions:\r\n• Pipeline Safety: Safety of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments (RIN 2137-AE72);\r\n• Pipeline Safety: Safety of Gas Transmission Pipelines, Repair Criteria, Integrity Management (IM) Improvements, Cathodic Protection, Management of Change, and Other Related Amendments (RIN 2137-AF39); and\r\n• Pipeline Safety: Safety of Gas Gathering Pipelines (RIN 2137-AF38). PHMSA believes that this separation will help move each individual proposed rule forward more quickly. PHMSA plans to address this recommendation in the \"Pipeline Safety: Safety of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments\" final rule, which is expected to be published in August 2019, according to the DOT's March 2019 Significant Rulemakings Report." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "2019-12-03", "communicationType": "Official Correspondence", "communicationContents": "-From Howard R. Elliott, Administrator: PHMSA proposes closure of this recommendation. On October 1, 2019, PHMSA published the \"Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments\" final rule. Section 192.624 of the final rule requires operators to reconfirm the MAOP of grandfathered pipelines in high consequence areas (HCAs), Class 3 locations, Class 4 locations, and \"moderate consequence areas\" that can accommodate inspection by means of an instrumented inline inspection tool.\r\n\r\nPHMSA also included a spike testing methodology in § 192.506 that operators will use whenever required by other requirements in part 192 to address crack remediation and the integrity threat of cracks and crack-like defects." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "2017-11-13", "communicationType": "Official Correspondence", "communicationContents": "-From Howard R. Elliott, Administrator: PHMSA appreciates NTSB's comments on the Gas Transmission NPRM, expressing approval on PHMSA's actions towards implementing this recommendation.\r\n\r\nPHMSA developed an Integrity Verification Process (IVP), which includes additional testing requirements to demonstrate seam stability and to confirm material strength of untested gas transmission pipelines operating under the Grandfather Clause. IVP was proposed in PHMSA's NPRM titled \"Pipeline Safety: Safety of Gas Transmission Pipelines\" (81 FR 20721 ), published on April 8, 2016 (https://www.federalregister.gov/documents/2016/04/08/2016-063 82/pipeline-safetysafety-of-gas-transmission-and-gathering-pipelines ). PHMSA held Gas Pipeline Advisory Committee (GPAC) meetings on the rule on January 12, 2017, and on June 6-7, 2017. PHMSA plans to hold additional meetings in December 2017 to continue discussing the proposed rule.\r\n\r\nThe final rule was initially expected to publish by the end of2017. Due to the continued process of gathering GP AC recommendations, we are expecting delays and currently assessing impacts. Like many other issues before us, this is part of an ongoing regulatory review pursuant to the executive order issued by the President." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "2016-08-17", "communicationType": "Official Correspondence", "communicationContents": "-From Marie Therese Dominguez, Administrator: PHMSA has developed an integrity Verification Process (IVP), which includes additional testing requirements to demonstrate seam stability and to confirm material strength of untested gas transmission pipelines operating under the \"Grandfather Clause.\" The IVP was proposed in PHMSA 's NPRM titled \"Pipeline Safety: Safety of Gas Transmission Pipelines,\" published on April 8, 2016. The comment period closed on July 7, 2016." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "2013-08-29", "communicationType": "Official Correspondence", "communicationContents": "-From Cynthia L. Quarterman, Administrator: PHMSA is developing an Integrity Verification Process (IVP) to assure that pipeline operators take the appropriate steps to ensure safe operation, address testing requirements to demonstrate seam stability, and confirm the material strength of untested gas transmission pipelines. On August 7, 2013, PHMSA conducted a public workshop to present its proposed IVP and seek comment. PHMSA expresses its thanks to the Honorable Christopher A. Hart, NTSB Vice-Chair, for presenting the findings of the San Bruno investigation and providing NTSB’s perspective on integrity verification during the workshop. \r\nPHMSA will formalize the IVP in an upcoming rulemaking. PHMSA is also considering rulemaking to remove the “Grandfather Clause.”" }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "2015-01-22", "communicationType": "Official Correspondence", "communicationContents": "-From Timothy P. Butters, Acting Administrator: PHMSA is formalizing an NPRM titled \"Pipeline Safety: Safety of Gas Transmission Pipelines,\" which will address this recommendation. PHMSA has developed a proposed Integrity Verification Process (IVP) to assure that pipeline operators take the appropriate steps to ensure safe operations, which includes additional testing requirements to demonstrate seam stability and to confirm material strength of untested gas transmission pipelines. On August 7, 2013, PHMSA conducted a public workshop to present its proposed IVP and seek comment. PHMSA expresses its gratitude to the Honorable Christopher A. Hart, NTSB Acting Chair, for presenting the findings of the San Bruno investigation and providing NTSB's perspective on integrity verification during the workshop. The NPRM is currently under agency review, and we expect to publish in 2015." }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "2011-12-14", "communicationType": "Official Correspondence", "communicationContents": "-From Cynthia L. Quarterman, Administrator: In our August 2011 gas transmission ANPRM referenced earlier, PHMSA began rulemaking on this and other issues relating to the San Bruno failure. We intend to advance rulemaking to address this topic during CY 2012. Removing the grandfather clause for all gas transmission pipelines will involve significant technical and economic challenges and is likely to require time to implement. Notwithstanding, PHMSA will evaluate several options for implementing this recommendation. To commence these actions PHMSA is initiating an OMB-approved information collection effort to gather key data needed to characterize the quantity and locations of pre-1970 gas transmission pipelines operating under the grandfather clause accurately.\r\n\r\n" }, { "addresseeAcronym": "PHMSA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": null, "communicationType": "Official Correspondence", "communicationContents": "" } ] } ], "jurisdiction": "US" } ```