NTSB Safety Recommendation P-10-001

NTSB safety recommendation P-10-001.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Through appropriate and expeditious means such as advisory bulletins and posting on your website, immediately inform the pipeline industry of the circumstances leading up to and the consequences of the September 9, 2010, pipeline rupture in San Bruno, California, and the National Transportation Safety Board’s urgent safety recommendations to Pacific Gas and Electric Company so that pipeline operators can proactively implement corrective measures as appropriate for their pipeline systems. (Urgent)

Priority: CLASS I

Overall Status: Closed - Acceptable Action

Issued Date: 2011-01-03

Adopted Date: 2010-12-30

Overall Date Closed: 2011-02-14

Synopsis: On September 9, 2010, about 6:11 p.m. Pacific daylight time,1 a 30-inch-diameter natural gas transmission pipeline (Line 132) owned and operated by Pacific Gas and Electric Company (PG&E) ruptured in a residential area in the city of San Bruno, California. The accident killed eight people, injured many more, and caused substantial property damage. The rupture on Line 132 occurred near milepost 39.33, 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 rupture created a crater about 72 feet long by 26 feet wide. A ruptured pipe segment about 28 feet long was found about 100 feet away from the crater. The released natural gas was ignited sometime after the rupture; the resulting fire destroyed 37 homes and damaged 18.

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 Action

Addressee Date Closed: 2011-02-14

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2011-11-23

Communication Type: Official Correspondence

Communication Contents: -From NTSB. –To: Christina Sames, Vice President Operations and Engineering, American Gas Association. NOT TO THE ADDRESSEE. NOT TO PHMSA. Thank you for your June 14, 2011, letter, regarding Safety Recommendations P-10-01 through -04, which the National Transportation Safety Board (NTSB) issued on January 3, 2011, regarding the San Bruno, California, pipeline accident. Safety Recommendation P-10-01 was issued to the Pipeline and Hazardous Materials Safety Administration (PHMSA), and Safety Recommendations P-10-02 through -04 were issued to the Pacific Gas and Electric Company (PG&E); all were urgent recommendations. The San Bruno pipeline accident report and the related safety recommendation issuance letters are posted on the NTSB’s website at http://www.ntsb.gov/doclib/reports/2011/PAR1101.pdf and http://www.ntsb.gov/recsletters/ DisplayLetters.aspx?FolderYR=2011, respectively. Your interpretations of our intent in issuing these recommendations, stated in your letter, are correct. To address another of your concerns, the NTSB does not intend for Federal or state agencies to codify the language from our safety recommendations directly into state and Federal rules and regulations. We believe that each agency should develop appropriate language for its own rules and regulations, to address and accomplish the intent of our safety recommendations. Of particular concern to you and your organization is the requirement for a postconstruction hydrostatic pressure test. For pipelines constructed before 1970 that were not required to be hydrostatically tested, 49 Code of Federal Regulations (CFR) 192.619(a)(3), commonly referred to as the “grandfather clause,” allows the maximum allowable operating pressure (MAOP) to be based on “the highest actual operating pressure to which the segment was subjected during the 5 years preceding … July 1, 1970.” In contrast to MAOP based on hydrostatic pressure testing, the grandfather clause does not specify a minimum amount of time that the historical pressure must have been held to be used as the basis for the MAOP. Studies have shown that hydrostatic pressure testing is most effective when it incorporates a spike test in which the pipeline is initially pressurized to a higher level for a short time. Accordingly, the NTSB recommended that PHMSA amend 49 CFR 192.619 to delete the grandfather clause and to require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. Additional information regarding this safety recommendation can be obtained in our San Bruno pipeline accident report, at the address cited above. The NTSB considers the San Bruno accident report and the safety recommendations issued as a result of our findings, to be of the utmost importance to the gas pipeline industry and to the American people. We encourage all involved interests, including the AGA, to ensure that pipelines are maintained properly and are operated safely. Thank you for your interest in these very important pipeline safety issues. Should you require any additional information or clarification, please contact us.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2011-02-14

Communication Type: Official Correspondence

Communication Contents: The NTSB is pleased that, upon receiving this recommendation, PHMSA promptly submitted an advisory bulletin (ADB-11-01) for publication in the Federal Register, informing the pipeline industry of the circumstances leading up to, and the consequences of, the 2010 San Bruno accident as well as the NTSB’s urgent safety recommendations to Pacific Gas and Electric Company. ADB-11-01 was subsequently published at 76 Federal Register 1504 (January 10, 2011). In addition, PHMSA posted the same information on its website at http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Pipeline/Regulations/AdvisoryBulletins/ADB-11-01.pdf and www.PHMSA.dot.gov. Accordingly, Safety Recommendation P-10-1 is classified CLOSED – ACCEPTABLE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2011-01-05

Communication Type: Official Correspondence

Communication Contents: CC# 201100006: - From Cynthia L. Quaterman, Administrator: I am sending you this letter in response to the National Transportation Safety Board's (NTSB) safety recommendation P-IO-1 issued to the Pipeline and Hazardous Materials Safety Administration (PHMSA) on January 3, 2011 in response to the NTSB's investigation of a September 9, 2010 natural gas pipeline rupture that occurred in a residential area in the city of San Bruno, California. The NTSB recommended that PHMSA, through appropriate and expeditious means such as advisory bulletins and posting on the PHMSA website, immediately inform the pipeline industry of the circumstances leading up to and the consequences of the September 9, 2010, pipeline rupture in San Bruno, California, and the NTSB's urgent safety recommendations to Pacific Gas and Electric Company so that pipeline operators can proactively implement corrective measures appropriate for their pipeline systems. PHMSA sent the enclosed Advisory Bulletin to the Federal Register on January 4, 2011, informing the pipeline industry of the circumstances leading up to and the consequences of the September 9, 2010, pipeline rupture in San Bruno, California, and the NTSB's urgent safety recommendations to Pacific Gas and Electric Company so that pipeline operators can proactively implement corrective measures appropriate for their pipeline systems. This information has also been published on the PHMSA website and can be found by using the following web links: http://www.phmsa.dot.gov/staticfiles/PHMSAlDownloadableFiles/PipelinelRegulations/Advisory Bulletins/ADB-II-01.pdf, or www.PHMSA.dot.gov. PHMSA takes the safety recommendations from the NTSB seriously and is focused on fulfilling the requirements of all pipeline safety recommendations. Through the publication of this advisory bulletin and the information posting on the PHMSA website, we have communicated the recommended information from NTSB safety recommendation P-l 0-1 and therefore request the classification of the recommendation be "Closed-Acceptable Action." If you have questions, concerns, or comments, please feel free to contact me at 202-366-4433.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2011-06-14

Communication Type: Official Correspondence

Communication Contents: From The American Gas Association, NOT FROM THE ADDRESSEEE. NOT FROM PHMSA. –From Christina Sames, Vice President, Operations and Engineering, American Gas Association: The American Gas Association (AGA) has reviewed the safety recommendations issued by the National Transportation Safety Board (NTSB) on January 3, 2011 (P-10-1 through P-10-7). As is our practice, AGA forwarded the recommendations to its member companies. AGA has received a number of questions from its members regarding the' NTSB recommendations and is therefore seeking clarification. Our members, who operate approximately 50,000 miles of transmission pipeline, have been actively engaged in following the developments of the investigation and have been considering how that information should be used to reduce the probability of similar incidents on their system. To that end, the NTSB's recommendations serve as prudent guidance regarding potential safety problems that operators may need to act on if it addresses a relevant factor on their system. Given these recommendations have not gone through the cost-benefit analysis, public notice and comment due process or analysis for potential adverse consequences, which are all normal steps in the rulemaking process, it is assumed these recommendations should not be considered a regulatory mandate nor should they be followed verbatim if the circumstances are not applicable for their system. To ensure appropriate response, AGA is seeking clarification from the NTSB that it did not intend for federal or state regulators to codify the exact language in the safety recommendations into state and federal pipeline safety codes which are applicable to all operators. In many cases, the safety recommendations appear to conflict with existing language, in other instances, the recommendations omit key provisions of the pipeline safety regulations. The clarification of the intended scope and applicability of the safety recommendations will allow operators nationwide to focus finite resources on appropriate areas that will provide real improvement in pipeline safety rather than diluting efforts in as that were never intended by the NTSB. Specific NTSB safety: recommendations that AGA believes should be clarified to achieve a consistent interpretation across the natural gas industry include P-10-1 to P-:-10-4 as follows. P-10-001: Please clarify the NTSB's intent relative to recommendation P-10-1. AGA believes the NTSB intended that PHMSA should inform pipeline operators of the circumstances and consequences surrounding the pipeline rupture in San Bruno and that, based on this information, operators should take appropriate action, if necessary, to conduct additional records searches based on the unique circumstances of their individual systems. AGA believes that the NTSB did not intend all natural gas transmission pipeline operators to implement an exhaustive records search or the other provisions detailed in recommendations P-10-2 to P-10-4 (below). P-10-002: Please clarify the NTSB's intent related to recommendation P-10-2. AGA believes that the NTSB intended that the recommendation to "aggressively and diligently search for all as-built drawings, alignment sheets, and specifications, and all design, construction, inspection, testing, maintenance, and other related records" applied exclusively to Pacific Gas and Electric Company or other operators who in individually determine the need to conduct a detailed records search for their natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had a maximum allowable operating pressure (MAOP) established through prior hydrostatic or pressure testing. AGA also requests that the NTSB clarify its use of the term "hydrostatic testing." AGA believes the intent of the recommendation was to focus the record search on pipelines where MAOP has not been previously established through "pressure testing" in accordance with 49 CFR Part 192, Subpart J add 192.619 (see the request for clarification to P-10-4 below). AGA also requests clarification for transmission pipelines installed prior to the enactment of Subpart J. AGA believes the phrase "established through prior hydrostatic pressure testing" is meant to address the stability of transmission pipeline longitudinal seams through a post construction pressure test and no a requirement to have all pipelines be tested to Subpart J standards. Finally, AGA requests that the NTSB provide clarification to the phrase "traceable, verifiable and complete". AGA believes that the recommendation was intended to direct Pacific Gas and Electric to identify records confirming the strength of the line pipe and related components from the time of construction. In the event that the appropriate records are unavailable for any reason, AGA believes the N SB intended PG&E, or other operator who individually determines the need to conduct a detailed records search, to make a conservative default assumption relative to the strength of the respective pipe or components. P-10-003: Please clarify the NTSB's intent related to recommendation P-10-3. AGA believes that the NTSB intended the recommendation to use traceable, verifiable, and complete records located by implementation of P-0-2 to determine the valid MAOP of natural gas transmission lines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had an MAOP established through prior hydrostatic or pressure testing to apply exclusively to Pacific Gas and Electric Company or those operators who individually determine the need to re-establish the MAOP of natural gas transmission lines based on the information contained in the PHMSA Advisory. As noted in the response to P-10-2 (above) and P-10-4 (below), please clarify NTSB's intent that the MAOP could have been previously established using "pressure testing" as defined by the provisions of 49 CFR Part 192, Subpart J and 1 2.619. P-10-004: Please clarify the NTSB's intent related to recommendation P-10-4. AGA believes that the NTSB intended for recommendation P-10-4, requiring natural gas transmission pipelines in class 3 and class 4 locations and class 1 and class 2 high consequence areas that have not had a maximum allowable operating pressure established through "prior pressure testing" to have the MAOP determined by a spike test followed by a hydrostatic pressure test, to apply exclusively to Pacific Gas and Electric Company. AS the NTSB noted in the safety recommendations, an operator may not be able to comply with safety recommendations P-10-2 and P-10-3. Operators have stated before the California Public Utility Commission (CPUC) that "traceable, verifiable and complete records for pipelines installed over 50 years ago was a very difficult, if not infeasible threshold to achieve." The phrase is not used in applicable regulations. As the NTSB noted, "Although hydrostatic testing is recognized to be a direct and effective methodology for validating an MAOP, its implementation requires that operating lines be shut down, which may adversely affect customers dependent on the natural gas supplied by the pipeline, particularly if the pipe fails during the test, which could necessitate a protracted shutdown." In addition, AGA notes that by placing water, a corrosive fluid, in a pipeline there is a very real possibility of introducing an unintended consequence of internal corrosion to the pipeline if the water is not eliminated completely after the hydro-test. Complete dehydration is extremely difficult for a pipeline that has already been placed into se ice and lines that include certain valves and laterals. Since the pipeline safety code, 49 CFR Part 192 -Transportation of Natural Gas by Pipeline: Minimum Federal Safety Standards, was established in 1970, operators and regulators have been very clear on the regulatory requirements for establishing the MAOP of new,