NTSB Safety Recommendation P-03-004

NTSB safety recommendation P-03-004.

The National Transportation Safety Board therefore makes the following safety recommendation to NACE International: Establish an accelerated schedule for completion of an industry standard for the control of internal corrosion in steel pipelines that will replace or update NACE standard RP0175-75.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2003-02-27

Adopted Date: 2003-02-11

Overall Date Closed: 2007-05-02

Synopsis: This recommendation addresses the prevention of internal corrosion in natural gas pipelines. The recommendation is derived from the Safety Board’s investigation of the August 19, 2000, natural gas pipeline rupture and subsequent fire near Carlsbad, New Mexico, and is consistent with the evidence we found and the analysis we performed. As a result of this investigation, the Safety Board has issued four safety recommendations, one of which is addressed to NACE International. Information supporting this recommendation is discussed below. The Safety Board would appreciate a response from you within 90 days addressing the actions you have taken or intend to take to implement our recommendation.

Probable Cause: The National Transportation Safety Board determines that the probable cause of the August 19, 2000, natural gas pipeline rupture and subsequent fire near Carlsbad, New Mexico, was a significant reduction in pipe wall thickness due to severe internal corrosion. The severe corrosion had occurred because El Paso Natural Gas Company’s corrosion control program failed to prevent, detect, or control internal corrosion within the company’s pipeline. Contributing to the accident were ineffective Federal preaccident inspections of El Paso Natural Gas Company that did not identify deficiencies in the company’s internal corrosion control program.

Ntsbnumber: DCA00MP009

Report Number: PAR-03-01

Addressee Name: NACE International

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2007-05-02

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2003-04-17

Communication Type: Official Correspondence

Communication Contents: The Safety Board was pleased to learn that a NACE task group met during the week of March 16-20, 2003, reviewing comments on the first proposed draft standard on internal corrosion in steel pipelines. The Board notes that NACE intends to publish a new standard on detection and control of internal pipeline corrosion by the end of 2003. Accordingly, Safety Recommendation P-03-4 is classified "Open--Acceptable Response," pending completion of a NACE standard on detection and control of internal pipeline corrosion.

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2006-12-13

Communication Type: Official Correspondence

Communication Contents: The Safety Board notes that a NACE working group is finalizing action on a standard Control of Internal Corrosion in Steel Pipelines and Piping Systems, which appears to be responsive to the recommendation, and publication is expected soon. Accordingly, pending publication of this standard, Safety Recommendation P-03-4 is classified Open Acceptable Response. Thank you for the comprehensive update and your commitment to pipeline safety.The Safety Board looks forward to receiving a copy of the technical standard responsive to Safety Recommendation P-03-4.

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2004-05-13

Communication Type: Official Correspondence

Communication Contents: This letter addresses Safety Recommendations P-98-40 and P-03-4, which the National Transportation Safety Board issued to NACE International (NACE). Safety Recommendation P-98-40, stated below, was issued to NACE on November 18, 1998, as a result of the Safety Board’s investigation of the pipeline rupture, liquid butane release, and fire at Lively, Texas, on August 24, 1996. P-98-40: Develop a standard for microbial sampling and testing of external surfaces on an underground pipeline. On February 25, 1999, in response to information provided in NACE International’s January 7, 1999, letter, the Safety Board classified Safety Recommendation P-98-40 "Open--Acceptable Response," pending publication of the proposed NACE standard, Detection and Control of Microbially Influenced External Corrosion for Buried, Partially Buried or Submerged Metallic Piping Systems. Safety Recommendation and P-03-4, stated below, which was issued to NACE on February 27, 2003, as a result of the Safety Board’s investigation of the August 19, 2000, natural gas pipeline rupture and subsequent fire near Carlsbad, New Mexico. P-03-4: Establish an accelerated schedule for completion of an industry standard for the control of internal corrosion in steel pipelines that will replace or update NACE standard RP0175-75. On March 10, 2003, NACE advised the Board that a task group met during the week of March 16-20, 2003, reviewing comments on the first proposed draft standard on internal corrosion in steel pipelines and that NACE intended to publish a new standard on detection and control of internal pipeline corrosion by the end of 2003. Accordingly, on April 17, 2003, Safety Recommendation P-03-4 was classified "Open--Acceptable Response," pending completion of a NACE standard on detection and control of internal pipeline corrosion. On November 18, 2002, the Safety Board requested information on the action that has been or is planned for implementation of Safety Recommendation P-98-40. To date, the Safety Board has received no further information from NACE on the status of activities related to Safety Recommendations P-98-40 and P-03-4. The Board is interested in knowing whether and how its recommendations are implemented, both to ensure that the public is provided the highest level of safety, and to identify creative solutions that might be shared with others. That is why we monitor the implementation of all our recommendations. We would appreciate receiving an update from you regarding actions taken or planned to implement this recommendation. Copies of the recommendation letter and associated correspondence are enclosed for your reference. Please address your reply to Ms. Ellen Engleman Conners, Chairman, National Transportation Safety Board. Thank you for your assistance, we look forward to receiving information on P-98-40 and P-03-4. Please call me at 202-314-6174 if you have any questions. Sincerely, Michael T. Brown, Pipeline Safety Recommendations.

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2004-06-25

Communication Type: Official Correspondence

Communication Contents: The Safety Board notes that NACE's Task Group 038 is finalizing and expects to publish a technical standard, Control of Internal Corrosion in Steel Pipelines and Piping Systems, before the end of 2004. Pending publication of the standard, Safety Recommendation P-03-4 is classified "Open--Acceptable Response."

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2005-05-02

Communication Type: Official Correspondence

Communication Contents: The Safety Board notes that NACE recently published the revised standard, SP0106-2006, Control of Internal Corrosion in Steel Pipelines and Piping Systems, and that this document is responsive to the recommendation. Accordingly, Safety Recommendation P-03-4 is classified Closed Acceptable Action.

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2007-05-02

Communication Type: Official Correspondence

Communication Contents: The Safety Board notes that NACE recently published the revised standard, SP0106-2006, Control of Internal Corrosion in Steel Pipelines and Piping Systems, and that this document is responsive to the recommendation. Accordingly, Safety Recommendation P-03-4 is classified Closed Acceptable Action.

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2003-03-10

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 3/19/2003 5:41:29 PM MC# 2030156 NACE management staff and technical committee officers have read with interest your letter and safety recommendation dated February 27, 2003. We agree that the problem of internal corrosion in natural gas pipelines is a serious issue that must be addressed by pipeline operators in the interest of public safety. NACE has been working with industry groups and government representatives for the past few years to help address pipeline integrity issues in light of the Carlsbad, New Mexico, accident and others that have caused loss of life and property. As a result, several standards have either been published or are being prepared to assist pipeline operators. NACE Standard RP0175-75 was officially withdrawn in 1995 as a result of its not being revised or reaffirmed after five years, which is a requirement of both NACE and American National Standards Institute (ANSI) procedures. These procedures are in place to ensure the technical integrity of standards that are available to the public. NACE technical committee members had planned to write three standards to replace RP0l75, but consensus was not reached on these standards, and it was still necessary to withdraw RP0175. This standard cannot be updated. A NACE task group is currently working to write a new standard based on the old one, but expanding the technical information. A ballot of the first draft has been completed, and the task group is in the process of reviewing negative votes and comments received. The task group will meet at NACE's annual conference, CORROSION/2003, March 16-20, to discuss the comments, and an Open Review will be held in the Specific Technology Group (STG) meeting of the STG that administers this task group. NACE staff editors and administrative staff dealing with the technical committees and this standard are giving priority to the completion of this standard, and a revised draft will be distributed for a reballot as soon as possible after CORROSION/2003. Voters have six weeks to respond to the ballot, and then negative votes and comments must be dealt with. The committees meet again at Corrosion Technology WeeW2003, September 7-l 1, and we anticipate that issues relating to the reballot will be discussed. It is our intent to publish this new standard by the end of 2003. I will provide an update following the task group and STG meetings at NACE's annual conference, and will certainly let you know if significant delays occur in regard to the plan to publish a new NACE standard on internal corrosion in steel pipelines. 3/25/03. Staff contacted Mr. Littleton and also spoke to Ms. Linda Goldberg, NACE Technical staff support, about the March 16-10, 2003 meetings addressing this recommendation at NACE's annual conference, CORROSION/2003. As a result of these meetings, the proposed standard to address the detection and control of internal pipeline corrosion continues to be on track to be completed by the end of 2003.

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2006-12-21

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 1/9/2007 2:29:29 PM MC# 2070008:The new standard pertaining to Safety Recommendation P-03-4 from the National Transportation Safety Board (NTSB) has been completed. NACE Standard SPOlO6-2006, "Control of Internal Corrosion in Steel Pipelines and Piping Systems," was recently published and is available for download from the NACE Web site, www.nace.org, and in printed form. A copy is enclosed. Please let me know if you would like additional copies. We appreciate your patience during the standards development process. NACE is an ANSI-accredited standards development organization, and as such, we are obligated to address all comments during the open voting process for new and revised standards. Sincerely, Tony Keane, Executive Director

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2004-05-17

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 5/24/2004 11:52:54 AM MC# 2040237: Task Group 038 has completed a ballot and a reballot on its proposed standard, "Control of internal Corrosion in Steel Pipelines and Piping Systems." Five negative votes were received on the reballot; these negatives must be reviewed but they do not have to be resolved if the committee doesn't agree with the voters. This committee also has had changes in leadership. Publication of this standard is still expected before the end of 2004. I will let you know as soon as work has been completed on these two standards, and will send you a copy of each when they are printed. Sincerely, Linda Goldberg, Manager, Technical Activities

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2006-05-17

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 5/22/2006 1:06:19 PM MC# 2060247:Task Group 038 has completed two ballots on its proposed standard, Control of Internal Corrosion in Steel Pipelines and Piping Systems. Five negative votes were received on the reballot; these negatives must be reviewed but they do not have to be resolved if the committee doesn’t agree with the voters. The negatives on this ballot include many comments for consideration, but Headquarters staff will provide extra assistance and request assistance from the Specific Technology Group (STG) chair in the review of these comments to expedite completion of this standard. Publication of this Standard is expected before the end of 2006.

Addressee Acronym: NACE

Addressee Organization Type: P-Private Industry

Communication Date: 2006-09-21

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 9/27/2006 2:29:31 PM MC# 2060485:Task Group 038 has completed two ballots on its proposed standard, Control of Internal Corrosion in Steel Pipelines and Piping Systems. Five negative votes were received on the reballot; these negatives must be reviewed but they do not have to be resolved if the committee doesn’t agree with the voters. The negatives on this ballot include many comments for consideration, but Headquarters staff will provide extra assistance and request assistance from the Specific Technology Group (STG) chair in the review of these comments to expedite completion of this standard. Publication of this Standard is expected before the end of 2006.