NTSB Safety Recommendation P-11-009

NTSB safety recommendation P-11-009.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: 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. (Supersedes Safety Recommendation P-11-002)

Priority: CLASS II

Overall Status: Closed - Acceptable Alternate Action

Issued Date: 2011-09-26

Adopted Date: 2011-09-12

Overall Date Closed: 2026-07-13

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: 2026-07-13

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: 2020-03-25

Communication Type: NPRM Response

Communication Contents: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) notice of proposed rulemaking (NPRM), Pipeline Safety: Valve Installation and Minimum Rupture Detection Standards, published on February 6, 2020. In this notice, PHMSA is proposing to “revise the Pipeline Safety Regulations applicable to newly constructed and entirely replaced onshore natural gas transmission and hazardous liquid pipelines to mitigate ruptures. Additionally, PHMSA is revising the regulations regarding rupture detection to shorten pipeline segment isolation times.” This NPRM responds to congressional mandates and recommendations from the NTSB. PHMSA states that this action is needed “to reduce the consequences of large-volume, uncontrolled releases of natural gas and hazardous liquid pipeline ruptures.” The NPRM references three open NTSB safety recommendations (P-11-9 through -11) that were issued to PHMSA as a result of our investigation of the September 9, 2010, rupture of a Pacific Gas and Electric Company natural gas pipeline and resulting fire in San Bruno, California. It also refers to an earlier closed safety recommendation (P-95-1) that was issued to PHMSA’s predecessor, the Research and Special Programs Administration (RSPA), as a result of our investigation of the March 23, 1994, natural gas pipeline explosion and fire in Edison, New Jersey. These safety recommendations are: 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) (Open—Acceptable Alternative Response) 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) (Open?Acceptable Response) 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) (Open—Acceptable Response) Expedite requirements for installing automatic- or remote-operated mainline valves on high-pressure pipelines in urban and environmentally sensitive areas to provide for rapid shutdown of failed pipeline segments. (P-95-1) (Closed—Acceptable Action) Although this NPRM addresses some aspects of Safety Recommendation P-11-9, important points are missed. For example, the proposed changes to Title 49 Code of Federal Regulations (CFR) 192.615(a)(8) and 195.402(e)(7) do not require immediate and direct notification to local jurisdictions of possible ruptures as recommended by Safety Recommendation P-11-9. Specifically, the NPRM’s clarifications to when notification is required could unnecessarily delay notification to local authorities and possibly exclude some ruptures, such as systems or portions of systems which do not contain “rupture-mitigation” valves, from the notification requirement. This would mean that ruptures to distribution systems and existing transmission systems may not be reported to local jurisdictions. In addition, clarifications are needed for some of the verbiage used in this NPRM. Terminology such as “large volume” and “uncontrolled release” can be interpreted in a myriad of ways, and thus, it does not clearly identify which releases can be excluded from the notification requirement. Although Safety Recommendation P-11-10 specifically called for PHMSA to require leak detection equipment on gas transmission and distribution pipelines, that action is not proposed in the NPRM. Instead, PHMSA intends to address leak detection through future rulemaking, research and development, and new or updated standards. PHMSA states in this NPRM that by requiring pressure monitoring upstream and downstream of all rupture-mitigation valves, ruptures can be better detected. PHMSA also notes that this pressure monitoring equipment can be used for leak detection once the technology becomes further developed. However, the criteria proposed is not specific to leak detection and the proposed requirements for installing rupture-mitigation valves exclude most of the systems that are the subject of Safety Recommendation P-11-10. For instance, gas distribution systems are excluded entirely, as are existing transmission lines, newly constructed or entirely replaced transmission lines which are less than 6-inches in diameter, and offshore transmission lines. Furthermore, the basis for the spacing intervals proposed in the NPRM is not clear and may not provide sufficient mitigation capability for those systems that are not excluded. Although PHMSA's actions to enhance leak detection and management through other avenues can be beneficial, the NTSB encourages PHMSA to act on Safety Recommendation P-11-10 to institute a more comprehensive and effective leak detection system for the pipeline industry as a whole. Safety Recommendation P-11-11 addresses the importance of having automatic shutoff valves (ASV) and remote-control valves (RCV) installed to facilitate the rapid shutdown of failed pipe segments in populated areas. The NTSB first identified this need almost 50 years ago and has continued to advocate for it. This safety recommendation is currently on the NTSB MWL of Transportation Safety Improvements. In this NPRM, PHMSA proposes changes to 49 CFR 192.935(c) that are not consistent with Safety Recommendation P-11-11. Instead of directly requiring ASVs or RCVs in high consequence areas (HCA) and Class 3 and 4 locations, the proposed changes to 49 CFR 192.935(c) would add further requirements that must be met once an operator determines that ASVs or RCVs would be efficient means of adding protection to an HCA. The additional requirements exclude most of the pipelines that are subject to 49 CFR 192.935(c) since they are only applicable to newly constructed or entirely replaced onshore gas transmission pipelines that have nominal diameters greater than or equal to 6 inches. One of the additional requirements would be to install rupture mitigation valves within specified maximum spacing intervals that extend between 8 and 20 miles for HCAs based on class location. However, the valves are not required to be spaced at intervals that consider the factors indicated in Safety Recommendation P-11-11, such as the swiftness of leak detection and pipe shutdown capabilities, the type of gas being transported, the operating pressure, the rate of potential release, the pipeline profile, the potential for ignition, and the location of nearest response personnel. The basis for the maximum rupture-mitigation valve spacing intervals may not be sufficient to mitigate the consequence of the pipe failure. The proposed changes to 49 CFR 192.935(c) also specify minimum standards for isolating ruptures and would require that operators isolate the segment as soon as practicable but within 40 minutes of rupture identification. This maximum timeframe is longer than what would be expected of an ASV and RCV and may not provide sufficient mitigation capability. For example, an ASV was installed on a service line to a school in Gary, Indiana, when its low-pressure distribution system was overpressurized on June 3, 1969. The ASV shut in time to avoid any damage to the school itself. PHMSA proposes to add a paragraph to 49 CFR 192.179 to require that “all valves on newly constructed or entirely replaced onshore

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2026-07-13

Communication Type: Official Correspondence

Communication Contents: On April 1, 2019, PHMSA proposed an alternative approach to meet the intent of this recommendation, including providing new guidance via frequently asked questions (FAQs) and new inspection assistant (IA) questions that your inspectors use to assess operators’ emergency contact procedures. We note that PHMSA proposed incorporating the FAQs and IA questions into its inspector training courses. The gas distribution IA question set includes questions related to an operator’s policy for liaising with emergency response officials and designating a person to notify emergency call centers after a potential rupture. We understand that PHMSA began training inspectors on the Valve Rule requirements in January 2023. Although the Valve Rule does not require control room operators to directly contact emergency call centers as recommended, the rule’s intent to explicitly require operators to implement policies to contact emergency responders when notified of a potential rupture meets the intent of this recommendation. Therefore, the Board has voted to classify Safety Recommendation P-11-9 CLOSED-- ACCEPTABLE ALTERNATE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2022-05-02

Communication Type: Official Correspondence

Communication Contents: On April 1, 2019, PHMSA proposed an alternative approach to meet the intent of this recommendation. Rather than establishing a requirement, through rulemaking, that 911 call centers be notified immediately when a pipeline ruptures, PHMSA proposed a multistep approach that builds on the current requirements in Title 49 Code of Federal Regulations (CFR) Part 192, which requires that operations manuals include “prompt and effective response to emergencies, including notifying and coordinating with emergency response officials.” On January 23, 2020, we replied that the current guidance in 49 CFR 192 may be applicable, specifically Part 195.402, Procedural Manual for Operations, Maintenance and Emergencies, and Part 192.615, Emergency Plans, which contain guidance on emergency response notification. Although these requirements, combined with the proposed additional actions described below, might be an alternative approach to meet the intent of this recommendation, we pointed out that, as we first noted on April 8, 2015, Safety Recommendation P-11-9 specifically asks for a requirement that control-room operators immediately and directly notify 911 emergency call centers. The current regulatory requirements cited above do not contain this exact wording and may not be precise enough to address the primary safety issue identified in our San Bruno accident investigation. In our comments about PHMSA’s February 6, 2020, notice of proposed rulemaking (NPRM), “Pipeline Safety: Valve Installation and Minimum Rupture Detection Standards,” we noted that, although this NPRM addressed some aspects of Safety Recommendation P-11-9, important points were missed. The proposed changes to 49 CFR 192.615(a)(8) and 195.402(e)(7) did not require immediate and direct notification to local jurisdictions of possible ruptures. The NPRM’s clarifications of when notification is required could unnecessarily delay notification to local authorities and possibly exclude some ruptures, such as systems or portions of systems which do not contain “rupture-mitigation” valves. This would mean that ruptures to distribution systems and existing transmission systems may not be reported to local jurisdictions. On April 8, 2022, PHMSA published the final rule proposed in the NPRM, but the final rule does not address all the shortcomings we pointed out in our comments about the NPRM. We note that you are continuing to work on the following additional actions, first described in PHMSA’s April 1, 2019, letter. that are part of your planned alternative response: • Reviewing comments about new guidance to operators in the form of frequently asked questions (FAQs) that more explicitly require controllers and other assigned operator personnel to promptly contact emergency responders. • Developing new inspection assistant (IA) questions that your inspectors will use to assess if operators have adequate procedures to promptly contact emergency responders in the event of an incident. • Incorporating the FAQs and IA questions into PHMSA inspector training courses. Your alternate approach may satisfy the intent of our recommendation, provided you make it clear that control-room operators must immediately and directly notify 911 emergency call centers. Pending the completion and our review of these actions, Safety Recommendation P-11-9 remains classified OPEN-- ACCEPTABLE ALTERNATE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-01-23

Communication Type: Official Correspondence

Communication Contents: We note that you have proposed an alternative approach to meet the intent of this recommendation. Rather than establishing a requirement, through rulemaking, that 911 call centers be notified immediately when a pipeline ruptures, you propose implementing a multistep approach that builds on the current requirements in Title 49 Code of Federal Regulations (CFR) Part 192, which requires that operations manuals include “prompt and effective response to emergencies, including notifying and coordinating with emergency response officials.” To satisfy the intent of Safety Recommendation P-11-9, you intend to take the following actions: • Modify or develop frequently asked questions that more specifically address promptly notifying emergency responders. • Develop or modify inspection assistant questions to assess whether appropriate procedures are in place. If not, inspectors may take action to correct deficiencies. • Improve inspector training to address this issue. • Discuss the issue at industry conferences and during a proposed PHMSA-initiated operator forum. After reviewing the regulations you cited, we agree that the current guidance in 49 CFR 192 may be applicable, specifically Part 195.402, Procedural Manual for Operations, Maintenance and Emergencies, and Part 192.615, Emergency Plans, which contain guidance on emergency response notification. Although these requirements, combined with your proposed additional actions, may meet the intent of this recommendation, we point out that Safety Recommendation P-11-9 specifically asks for a requirement that control-room operators immediately and directly notify 911 emergency call centers. We also emphasized this detail in our April 8, 2015, letter to you regarding this recommendation. The current regulatory requirements cited above do not contain this exact wording, and may not be precise enough to address the primary safety issue identified in our San Bruno accident investigation. Please inform us once you have made your proposed changes and send us any revised documentation so we can assess the adequacy of your actions toward meeting the intent of this recommendation. Pending our receipt and review of that information, Safety Recommendation P 11-9 is classified OPEN--ACCEPTABLE ALTERNATE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: We note that you plan to address these recommendations in a notice of proposed rulemaking (NPRM) titled “Pipeline Safety: Amendments to Parts 192 and 195 to Require Valve Installation and Minimum Rupture Detection Standards,” which you had planned to publish during the spring of 2017. We further note that, although you continue to work on this NPRM, its issuance has been delayed by the governmentwide regulatory review required by executive order. Pending completion of the review and publication of the NPRM, followed by publication of the final rule, Safety Recommendations P-11-9 through -11 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: We are aware of your Advisory Bulletin (AB)-12-09, “Communication During Emergency Situations,” published in October 2012, and understand that you plan to incorporate aspects of this recommendation into a future notice of proposed rulemaking (NPRM), titled “Pipeline Safety: Amendments to Parts 192 and 195 to Require Valve Installation and Minimum Rupture Detection Standards,” which is expected to be published by late spring 2017. Pending completion of these efforts and publication of the final rules, Safety Recommendation P-11-9 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, in October 2012, PHMSA published ADB-12-09, Communication During Emergency Situations, in the Federal Register, that the National Emergency Number Association (NENA) developed Standard 56-507, Pipeline Emergency Operations (http://www.nena.org/?page=PipelineEmergStnd), and that NENA launched the Public Safety Answering Points Information for Pipeline Emergencies (PIPE) database (http://www.nena.org/news/110798/) for pipeline operators. However, although the NENA standard and PIPE database should lessen problems associated with pipeline emergency calls to 911 centers, they are not substitutes for a federal requirement for control room operators to immediately and directly notify the 911 emergency call center(s) in the event of a possible pipeline rupture. At a September 24, 2013, meeting between PHMSA and NTSB staff, we learned that PHMSA is currently considering regulations that would address this issue. Accordingly, pending issuance of the requested requirement, Safety Recommendation P 11-9 remains 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 that you published Advisory Bulletin (ADB)-12-09, “Communication During Emergency Situations,” in October 2012. Because your staff advised us that you were considering issuing regulations to address this recommendation, on January 3, 2014, we classified Safety Recommendation P 11-9 “Open—Acceptable Response.” Although we understand that you are still considering additional steps that you may take, we remind you that only a requirement will satisfy the recommendation, and we encourage you to expedite your efforts to initiate rulemaking. Pending our receipt of your reply, Safety Recommendation P-11-9 remains classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2012-04-24

Communication Type: Official Correspondence

Communication Contents: The NTSB notes that PHMSA plans to issue an ADB to all pipeline operators, reiterating the importance of immediately notifying emergency responders when a pipeline ruptures or other emergency condition exists. However, the pending ADB, which does not constitute a regulation, will not require operators to directly notify emergency responders, as recommended. Accordingly, we ask that PHMSA reconsider its planned action to address Safety Recommendation P-11-9. Pending receipt of further information from PHMSA regarding our request, Safety Recommendation P-11-9 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2022-01-14

Communication Type: Official Correspondence

Communication Contents: -From Tristan H. Brown, Deputy Administrator: PHMSA appreciates NTSB's reclassification of P-11-9 as Open—Acceptable Alternate Response based on PHMSA’s proposal to implement alternative actions. On February 25, 2020, PHMSA held a meeting with pipeline and liquefied natural gas operators to enhance communications between PHMSA and the regulated community. Various topics were discussed, including the importance of operators having and following manuals that include requirements for prompt and effective responses to emergencies and for immediately and directly notifying the appropriate Public Safety Access Points if indications of a pipeline facility emergency exist. PHMSA also discussed this topic during an April 2019 presentation at the American Petroleum Institute (API) Pipeline Conference and Control Room Forum. PHMSA has developed new guidance to operators in the form of frequently asked questions (FAQs) that more explicitly state requirements for controllers or other assigned operator personnel to promptly contact emergency responders. These FAQs highlight the need for operators to properly train employees to contact emergency responders more expediently. On July 8, 2021, PHMSA published a Federal Register notice to solicit comments on the FAQs.1 Once the comments are reviewed, PHMSA will make any appropriate amendments to the FAQs, and publish them on the Agency’s website. PHMSA has also developed new Inspection Assistant (IA) questions that PHMSA’s inspectors utilize to assess if operators have adequate procedures to promptly contact emergency responders in the event of an incident. PHMSA plans to integrate the IA questions into our inspections by February 2022. PHMSA plans to incorporate the FAQs and IA questions into inspector training courses at the PHMSA Training and Qualifications (T&Q) Training Center. This incorporation will highlight the importance of inspecting operators’ procedures for contacting emergency responders, including 911 Emergency Call Centers, in a timely manner during pipeline emergencies. PHMSA plans to finalize these course changes after the FAQs are published and IA questions are integrated in our inspections.

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: I am writing to update you on the status of actions taken to date to address 24 open National Transportation Safety Board (NTSB) recommendations. The Pipeline and Hazardous Materials Safety Administration (PHMSA) completed actions on Recommendations P-15-18 and P-15-21 and is requesting closure. We also request that the NTSB change the status of Recommendation P-12-3 from "Open - Unacceptable Response" to "Open -Acceptable Response" and consider alternative actions for Recommendations P-11-9 and P-15-22. On August 31, 2018, PHMSA sent a letter to the NTSB in response to the NTSB' s safety recommendation report, "Installation of PermaLock Mechanical Tapping Tee Assemblies," and related Recommendations P-18-1 and P-18-2. On February 4, 2019, the NTSB sent its response, classifying Recommendation P-18-1 as "Open - Acceptable Response" pending completion of our proposed actions, and classifying Recommendation P-18-2 as "Closed – Acceptable Response" as a result of PHMSA meeting the NTSB' s intent of ensuring that operators consult external sources for information in their threat identification process, through our current frequently asked questions (FAQs) and by publicly posting a reference of the NTSB's safety recommendation report. Furthermore, on April 5, 2018, after the NTSB categorized PHMSA's initial response to Recommendation P-17-2 as "Open - Unacceptable," PHMSA sent the NTSB a response that included alternative actions. On October 18, 2018, we received NTSB's response to our proposed alternative actions, which stated that the recommendation remains "Open -Unacceptable." We look forward to continuing discussions on how to meet the intent of this important safety recommendation. As you know, PHMSA's highest priority is safety, and we have a long history of cooperating and collaborating with the NTSB to advance that priority. We take our responsibility to address all NTSB recommendations seriously and will continue to work diligently to address all open recommendations. PHMSA proposes that the NTSB consider alternative actions to address this recommendation. PHMSA previously proposed to address this recommendation by incorporating aspects of it into a future notice of proposed rulemaking (NPRM) titled "Pipeline Safety: Amendments to Parts 192 and 195 to Require Valve Installation and Minimum Rupture Detection Standards." Further analysis of Recommendation P-11-9 revealed that PHMSA's current regulations include requirements for operators to maintain manuals that include prompt and effective response to emergencies, including notifying and coordinating with appropriate emergency response officials (See 49 Code of Federal Regulations (CFR) §§ 192.12, 192.605, 192.615, 192.616, 193.2509, and 195.402). PHMSA believes we can efficiently achieve the intent of the recommendation by clarifying these current regulatory requirements for operators to contact emergency responders. PHMSA appreciates the NTSB's awareness of our advisory bulletin (ADB) reminding operators of gas, hazardous liquid, and liquefied natural gas pipeline facilities that they should immediately and directly notify the appropriate Public Safety Access Point (PSAP) if there are indications of a pipeline facility emergency. 1 In August 2018, PHMSA met with pipeline trade associations and several operators to review the intent of this recommendation. Industry representatives indicated that they have taken steps to improve performance in this area and credited PHMSA's ADB for their progress. PHMSA believes there is still more that can be done to further achieve the intent of Recommendation P-11-9 and proposes the following multi-step approach to clarify current regulatory requirements: • Modify existing or develop new frequently asked questions (FAQs) that more explicitly state a requirement for controllers or other assigned operator personnel to promptly contact emergency responders. These FAQs would highlight the need for operators to properly train employees to contact emergency responders more expediently. • Develop new or modify existing Inspection Assistant (IA) questions. PHMSA's IA program is used by all Federal and some state pipeline safety programs to conduct inspections. The IA questions would assess if operators have adequate procedures and have promptly contacted emergency responders in the event of an incident. An inspector can then take action to correct any deficiencies noted. • Incorporate updated FAQs and IA questions into inspector training courses at the PHMSA Training & Qualifications (TQ) Training Center to highlight the importance of operators contacting emergency responders, including 911 Emergency Call Centers, in a timely manner in times of pipeline emergencies. • Discuss the topic at industry conferences and during a proposed PHMSA-initiated operator forum slated for 2019. PHMSA believes this multi-step approach will help to satisfy the NTSB's intended safety requirement by ensuring pipeline operators understand the need to quickly notify emergency responders when responding to a pipeline emergency. PHMSA will complete the proposed actions by January 2020.

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 proposed an alternative approach for this recommendation on April 1, 2019, and looks forward to NTSB's response.

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 notes that the NTSB is aware of PHMSA's October 11, 2012, Advisory Bulletin ADB-12-09, "Communication During Emergency Situations" (77 FR 61826, https://www.federalregister.gov/documents/2012/10/11/2012-24975/pipelinesafety-communication-during-emergency-situations ), which reminded operators of gas, hazardous liquid, and liquefied natural gas pipeline facilities that, if there are indications of a pipeline facility emergency, operators should immediately and directly notify the Public Safety Access Point (PSAP) that serves the communities in which those pipelines are located. PHMSA continues to work to incorporate aspects of this recommendation into a future NPRM titled "Pipeline Safety: Amendments to Parts 192 and 195 to Require Valve Installation and Minimum Rupture Detection Standards." The NPRM was initially expected to publish in spring 2017. 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: 2025-06-04

Communication Type: Official Correspondence

Communication Contents: From Ben Kochman, Acting Administrator, PHMSA: On April 8, 2022, PHMSA issued a final rule, Pipeline Safety: Requirement of Valve Installation and Minimum Rupture Detection Standards (87 FR 20940; Apr. 8, 2022) (Valve Rule). The Valve Rule went into effect on October 5, 2022 and requires, among other things, that pipeline operators “immediately and directly notify the appropriate public safety answering point [i.e., 911 emergency call center] or other coordinating agency for the communities and jurisdictions in which the pipeline is located after notification of potential rupture...” 49 CFR §§ 192.615(a)(8), 195.402(e)(7). In lieu of communicating with individual fire, police, or other public entities, operators may also establish liaison with appropriate local emergency coordinating agencies, such as 911 emergency call centers or county emergency managers. PHMSA also developed new Inspection Assistant (IA) questions, modified existing IA questions, and developed new considerations to assist inspectors’ assessment of operators’ regulatory compliance with the Valve Rule. PHMSA added the new questions and considerations to IA on December 21, 2021 and implementation began in January 2022. PHMSA started to train its inspectors on the new requirements in the Valve Rule in January 2023. PHMSA recognizes the importance of operators establishing and maintaining communication with communities to provide information about their pipeline systems when a possible pipeline rupture is indicated. PHMSA believes publication of the Valve Rule, improved oversight of operator written procedures through the updated IA questions, and inspector training on the new requirements address Safety Recommendation P-11-9. PHMSA takes its responsibility to address all NTSB recommendations seriously. Based on PHMSA’s actions as discussed above, PHMSA requests that Safety Recommendations P-11-9 and P-11-10 be classified as “Closed-Acceptable Action.” PHMSA looks forward to working with NTSB as it continues to strive to ensure the safe and reliable operation of the Nation’s pipeline transportation system in support of the Administration’s priorities.

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: On October 11 ,2012, PHMSA published Advisory Bulletin ADB-12-09, "Communication During Emergency Situations" (77 FR 61826) in the Federal Register. This ADB reminded operators of gas, hazardous liquid, and liquefied natural gas pipeline facilities that, if there are indications of a pipeline facility emergency, operators should immediately and directly notify the Public Safety Access Point (PSAP) that serves the communities in which those pipelines are located. Pipeline operators must include provisions in their emergency plans for coordination with appropriate fire, law enforcement, emergency management, and other public safety officials. Further, PHMSA plans to incorporate aspects of this recommendation into a future NPRM titled "Pipeline Safety: Amendments to Parts 192 and 195 to Require Valve Installation and Minimum Rupture Detection Standards." Publication of the proposed rule is anticipated by late spring 2017.

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 recommends closing this recommendation as acceptable. On October 11, 2012, PHMSA published Advisory Bulletin "ADB-12-09: Communication During Emergency Situations" (77 FR 61826) in the Federal Register. Furthermore, National Emergency Number Association (NENA) has developed a Standard 56-507, “Pipeline Emergency Operations,” which is available at http://www.nena.org/?page=PipelineEmergStnd and “is intended to aid Public Safety Answering Points (PSAP) in the development and implementation of emergency communications protocols pertaining to pipeline emergencies. It addresses common situations involving pipelines carrying non-toxic natural gas and hazardous liquid petroleum products.” On December 6, 2012, NENA launched the PSAP Information for Pipeline Emergencies (PIPE) Database. According to a NENA press release at http://www.nena.org/news/110798/, the PIPE Database was developed specifically for pipeline operators. The NENA PIPE Database provides direct-inbound, ten-digit numbers to be used for specific 9-1-1 centers. The database is being offered on an annual subscription that includes the initial set-up and three free updates per year to ensure that companies have the most up-to-date and dependable information. Subscription rates vary according to the number of jurisdictions being served.

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: On October 11, 2012, PHMSA published Advisory Bulletin ADB-12-09, "Communication During Emergency Situations" (77 FR 61826) in the Federal Register. This ADB reminds operators of gas, hazardous liquid, and liquefied natural gas pipeline facilities that, if there are indications of a pipeline facility emergency, operators should immediately and directly notify the Public Safety Access Point (PSAP) that serves the communities in which those pipelines are located. Pipeline operators must include provisions in their emergency plans for coordination with appropriate fire, law enforcement, emergency management, and other public safety officials. PHMSA is considering additional steps to further address this recommendation.

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: PHMSA will soon publish an advisory bulletin to all pipeline operators reiterating the importance of immediate dialogue between the operator and emergency responders when any indication of a pipeline rupture or other emergency condition that may have an adverse impact on people or the environment arises.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence