# NTSB Safety Recommendation P-82-042 **Citation:** P-82-042 **Type / status:** guidance / guidance **Agency:** National Transportation Safety Board **Effective:** 1982-10-05 **Published:** 1982-10-05 THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: DISCONTINUE THE PRACTICE OF GRANTING WAIVERS PROSPECTIVELY WHICH PERMITS THE REPAIR RATHER THAN THE REPLACEMENT OF DEFECTIVE WELDS ON PIPELINES YET TO BE CONSTRUCTED. ## Document text NTSB safety recommendation P-82-042. THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: DISCONTINUE THE PRACTICE OF GRANTING WAIVERS PROSPECTIVELY WHICH PERMITS THE REPAIR RATHER THAN THE REPLACEMENT OF DEFECTIVE WELDS ON PIPELINES YET TO BE CONSTRUCTED. Priority: CLASS II Overall Status: Closed - Unacceptable Action Issued Date: 1982-10-05 Adopted Date: 1982-09-22 Overall Date Closed: 1987-05-18 Synopsis: THE NATIONAL TRANSPORTATION SAFETY BOARD HAS REVIEWED THE NOTICES PUBLISHED BY THE MATERIALS TRANSPORTATION BUREAU (MTB) OF THE U.S. DEPARTMENT OF TRANSPORTATION: "PETITION FOR WAIVER" AND "GRANT OF WAIVER," DOCKET NO. 82-3W, NOTICES NOS. 1 AND 2, WHICH APPEARED AT 47 FR 16248 AND 47 FR 20715 ON APRIL 15, 1982, AND MAY 13, 1982, RESPECTIVELY. BOTH NOTICES CONCERNED THE REPAIR OF GIRTH WELD DEFECTS IN APPROXIMATELY 635 MILES OF 42-INCH DIAMETER GAS TRANSMISSION PIPELINE CONSTRUCTED BY THE NORTHERN BORDER PIPELINE COMPANY (COMPANY). THIS PIPELINE SECTION WAS CONSTRUCTED IN 1981 THROUGH THE STATES OF MONTANA, NORTH DAKOTA, MINNESOTA, AND IOWA. THE NOTICES ALSO CONCERNED "POSSIBLE REPAIR OF DEFECTS IN APPROXIMATELY 181 MILES (OF PIPELINE) TO BE CONSTRUCTED IN 1982." AS REPORTED IN NOTICE NO. 1, THE WELD DEFECTS WERE NOT DETECTED BY THE COMPANY'S X-RAY TECHNICIANS RESPONSIBLE FOR QUALITY ASSURANCE, BUT RATHER WHEN AN AUDIT OF THE WELD X-RAYS WAS PERFORMED AFTER THE PIPE WAS BURIED. THE SAFETY BOARD IS CONCERNED THAT IMPORTANT ISSUES RAISED BY THE AUDIT WERE NOT ADDRESSED IN YOUR PETITION. Ntsbnumber: 80502 Report Number: None Addressee Name: RSPA Addressee Status: Closed - Unacceptable Action Addressee Date Closed: 1987-05-18 Addressee Acronym: RSPA Addressee Organization Type: G-Federal Government Communication Date: 1982-10-26 Communication Type: Official Correspondence Communication Contents: RSPA LETTER: THE MTB INITIATED A REGULATORY REVIEW OF THE WELD REPAIR REQUIREMENTS IN PARTS 192 AND 195 IN 1981. PURSUANT TO THAT REVIEW, WE ARE PROPOSING TO AMEND THE GAS AND LIQUID PIPELINE SAFETY REGULATIONS CONCERNING WELD REPAIR TO ALLOW THE REPAIR OF CERTAIN CRACKS AND MULTIPLE REPAIR OF GIRTH WELD DEFECTS. THIS PROPOSAL IS BASED UPON A CONSIDERABLE AMOUNT OF TECHNICAL AND ECONOMIC DATA WHICH HAD BEEN SUBMITTED TO THE DEPARTMENT IN PROCEEDINGS FOR FOUR WAIVERS GRANTED BY MTB AUTHORIZING THE CONDITIONAL REPAIR OF GIRTH WELD CRACKS AND MULTIPLE REPAIR OF GIRTH WELD DEFECTS. PROCEDURAL REQUIREMENTS BASED UPON AMERICAN PETROLEUM INSTITUTE STANDARD 1104 WOULD BE INCORPORATED IN THE WELD REPAIR REGULATIONS TO ASSURE SOUND, DUCTILE WELDS UPON COMPLETION OF THE WELD REPAIR. I AN ENCLOSING A DRAFT COPY OF A NOTICE OF PROPOSED RULEMAKING CONCERNING THESE DAMAGES. ADOPTION OF SUCH A REVISION TO THE REPAIR PROCEDURES IN BOTH GAS AND LIQUID PIPELINE SAFETY REGULATIONS WOULD ELIMINATE THE NEED FOR "PROSPECTIVELY" GRANTING WAIVERS FOR THE REPAIR OF CERTAIN GIRTH WELD DEFECTS AND THEREBY MAKE SAFETY RECOMMENDATION P-82-42 MOOT. Addressee Acronym: RSPA Addressee Organization Type: G-Federal Government Communication Date: 1987-05-18 Communication Type: Official Correspondence Communication Contents: THIS IS ACTUALLY A FOLLOWUP AND THE FOLLOWING IS A HISTORY OF PAST CORRESPONDENCE. RSPA'S INITIAL RESPONSE OF OCTOBER 26, 1982. NTSB'S FOLLOWUP LETTER OF MAY 4, 1983. NTSB'S MARCH 14, 1983, COMMENTS OF THE MATERIALS TRANSPORTATION BUREAU ON THE NPRM REGARDING THE REPAIR OR REMOVAL OF GIRTH WELD DEFECTS. MTB'S FINAL RULE PUBLISHED IN THE FEDERAL REGISTER ON THURSDAY, OCTOBER 20, 1983. Addressee Acronym: RSPA Addressee Organization Type: G-Federal Government Communication Date: 1983-05-04 Communication Type: Official Correspondence Addressee Acronym: RSPA Addressee Organization Type: G-Federal Government Communication Date: 1987-05-18 Communication Type: Official Correspondence Addressee Acronym: RSPA Addressee Organization Type: G-Federal Government Communication Date: 1987-05-05 Communication Type: Official Correspondence ## Provenance - Official: Yes - Source: - Source ID: `ntsb-pipeline` - SHA-256: `9f9cc0ecea66266d3e55c10bafd91d56fc9e9cb3f8ddc5006a0f2a306f024e62` - Retrieved: 2026-08-20T04:57:24.741Z - Exported: 2026-08-22T23:56:28.846Z - Document slug: `ntsb-recommendation-p-82-042` ### Source metadata ```json { "recordKind": "ntsb_safety_recommendation", "safetyRecommendationNumber": "P-82-042", "recommendationMode": "Pipeline", "topicMode": "Pipeline", "ntsbNumber": "80502", "priority": "CLASS II", "overallStatus": "Closed - Unacceptable Action", "overallStatusAcronym": "CUA", "overallDateClosed": "1987-05-18", "lastModifiedDate": "2016-11-15", "reportNumber": "None", "reportUrl": null, "transmittalLetterUrl": "http://www.ntsb.gov/safety/safety-recs/recletters/P82_42.pdf", "addressees": [ { "addresseeName": "RSPA", "addresseeStatusAcronym": "CUA", "addresseeStatus": "Closed - Unacceptable Action", "addresseeDateClosed": "1987-05-18", "addresseeDetails": [ { "addresseeAcronym": "RSPA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "1982-10-26", "communicationType": "Official Correspondence", "communicationContents": "RSPA LETTER: THE MTB INITIATED A REGULATORY REVIEW OF THE WELD REPAIR REQUIREMENTS IN PARTS 192 AND 195 IN 1981. PURSUANT TO THAT REVIEW, WE ARE PROPOSING TO AMEND THE GAS AND LIQUID PIPELINE SAFETY REGULATIONS CONCERNING WELD REPAIR TO ALLOW THE REPAIR OF CERTAIN CRACKS AND MULTIPLE REPAIR OF GIRTH WELD DEFECTS. THIS PROPOSAL IS BASED UPON A CONSIDERABLE AMOUNT OF TECHNICAL AND ECONOMIC DATA WHICH HAD BEEN SUBMITTED TO THE DEPARTMENT IN PROCEEDINGS FOR FOUR WAIVERS GRANTED BY MTB AUTHORIZING THE CONDITIONAL REPAIR OF GIRTH WELD CRACKS AND MULTIPLE REPAIR OF GIRTH WELD DEFECTS. PROCEDURAL REQUIREMENTS BASED UPON AMERICAN PETROLEUM INSTITUTE STANDARD 1104 WOULD BE INCORPORATED IN THE WELD REPAIR REGULATIONS TO ASSURE SOUND, DUCTILE WELDS UPON COMPLETION OF THE WELD REPAIR. I AN ENCLOSING A DRAFT COPY OF A NOTICE OF PROPOSED RULEMAKING CONCERNING THESE DAMAGES. ADOPTION OF SUCH A REVISION TO THE REPAIR PROCEDURES IN BOTH GAS AND LIQUID PIPELINE SAFETY REGULATIONS WOULD ELIMINATE THE NEED FOR \"PROSPECTIVELY\" GRANTING WAIVERS FOR THE REPAIR OF CERTAIN GIRTH WELD DEFECTS AND THEREBY MAKE SAFETY RECOMMENDATION P-82-42 MOOT." }, { "addresseeAcronym": "RSPA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "1987-05-18", "communicationType": "Official Correspondence", "communicationContents": "THIS IS ACTUALLY A FOLLOWUP AND THE FOLLOWING IS A HISTORY OF PAST CORRESPONDENCE. RSPA'S INITIAL RESPONSE OF OCTOBER 26, 1982. NTSB'S FOLLOWUP LETTER OF MAY 4, 1983. NTSB'S MARCH 14, 1983, COMMENTS OF THE MATERIALS TRANSPORTATION BUREAU ON THE NPRM REGARDING THE REPAIR OR REMOVAL OF GIRTH WELD DEFECTS. MTB'S FINAL RULE PUBLISHED IN THE FEDERAL REGISTER ON THURSDAY, OCTOBER 20, 1983." }, { "addresseeAcronym": "RSPA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "1983-05-04", "communicationType": "Official Correspondence", "communicationContents": "" }, { "addresseeAcronym": "RSPA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": true, "communicationDate": "1987-05-18", "communicationType": "Official Correspondence", "communicationContents": "" }, { "addresseeAcronym": "RSPA", "addresseeOrganizationType": "G-Federal Government", "isFromNtsb": false, "communicationDate": "1987-05-05", "communicationType": "Official Correspondence", "communicationContents": "" } ] } ], "jurisdiction": "US" } ```