NTSB Safety Recommendation P-11-010

NTSB safety recommendation P-11-010.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: 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.

Priority: CLASS II

Overall Status: Open Acceptable Alternate Response

Issued Date: 2011-09-26

Adopted Date: 2011-09-12

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: Open Acceptable Alternate Response

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: 2023-07-06

Communication Type: NPRM Response

Communication Contents: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration’s (PHMSA’s) notice of proposed rulemaking (NPRM) titled, “Pipeline Safety: Gas Pipeline Leak Detection and Repair,” published at 88 Federal Register 31890 on May 18, 2023. The NPRM proposes to amend portions of Title 49 Code of Federal Regulations (CFR) Parts 191, 192, and 193 to implement congressional mandates in the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2020 to reduce methane emissions from new and existing gas transmission pipelines, gas distribution pipelines, regulated gas gathering pipelines, underground natural gas storage facilities, and liquefied natural gas facilities. In its NPRM, PHMSA documented a detailed evaluation of several of its regulations and proposed amendments to: • strengthen leakage survey and patrolling requirements; • establish performance standards for advanced leak detection programs; • clarify leakage survey, investigation, and repair personnel qualification requirements; and • codify congressional mandates in federal regulation. Some of PHMSA’s proposed amendments, if implemented, will help improve pipeline leak detection and mitigation, an item on the NTSB’s Most Wanted List for 2021–2023. Footnote: https://www.ntsb.gov/Advocacy/mwl/Pages/default.aspx The NTSB first identified the need for leak detection and mitigation methods about 50 years ago and is encouraged by proposals in the NPRM that may enhance the industry’s performance in detecting and safely responding to pipeline leaks. We offer comments in the following topic areas: leakage survey requirements and advanced leak detection programs, in-home methane detectors, leak-prone materials, and leak detection systems. Leak Detection Systems In September 2010, the NTSB investigated a natural gas transmission pipeline rupture and fire in San Bruno, California, that destroyed 38 homes and damaged 70 others, killing 8 people and injuring 58. Footnote: For more information, see Pacific Gas and Electric Company Natural Gas Transmission Pipeline Rupture and Fire, San Bruno, California, September 9, 2010. NTSB/PAR-11/01. Washington, DC: NTSB. The pipeline operator’s excessively long response time—it took 95 minutes to stop the flow of gas and isolate the rupture—contributed to the extent and severity of property damage and increased the life threatening risks to residents and emergency responders. As a result of the investigation, we made the following safety recommendation to PHMSA: Require that all operators of natural gas transmission and distribution pipelines equip their supervisory control and data acquisition [SCADA] 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) Footnote: This recommendation is currently classified Open—Acceptable Alternate Response based in part on pending publication of this NPRM. PHMSA previously indicated that the leak detection provisions of this recommendation, specifically requiring operators to add leak detection tools to SCADA systems, would be best addressed in this NPRM. Footnote: Letter from PHMSA Deputy Administrator to NTSB Chair, dated January 14, 2022. However, the NPRM does not propose to require operators to equip their SCADA systems with tools to assist in recognizing and pinpointing the location of leaks, including line breaks in transmission lines. By decreasing the amount of time it takes to isolate a leak or rupture and thus the volume of gas released, such tools can help reduce risks to the public and the environment. The NTSB encourages PHMSA to revisit this topic to satisfy the intent of Safety Recommendation P-11-10 in its final rule. The NTSB is pleased to see PHMSA publish this NPRM, and we look forward to the issuance of the final rule. We believe that the modifications to the NPRM suggested above will increase safety and be responsive to several of our recommendations. We commend the agency for initiating a rulemaking that may improve pipeline leak detection and mitigation. Thank you for the opportunity to comment on this notice.

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 B—Strengthening Requirements to Implement Preventive and Mitigative Measures for Pipeline Segments in HCAs Summary PHMSA is proposing to amend the IM rule to add requirements for selected preventive and mitigative measures for pipeline segments in HCAs, specifically internal and external corrosion control. Section 8 of the Act requires PHMSA to report to Congress on leak detection technology, and refers to Safety Recommendation P-11-10 from the NTSB report on the September 9, 2010, pipeline rupture in San Bruno, California. 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) In this NPRM, PHMSA notes that leak detection devices mitigate rather than prevent accidents and states that it has deferred action on Safety Recommendation P-11-10 until after it completes its ongoing research and analysis as part of its greater leak detection study. However, PHMSA does address the valve upgrade issues in topic H.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2022-05-02

Communication Type: Official Correspondence

Communication Contents: We pointed out in our comments about your February 6, 2020, NPRM that gas distribution systems are excluded entirely, as are existing transmission lines, newly constructed or entirely replaced transmission lines that are less than 6 inches in diameter, and offshore transmission lines. Furthermore, the basis for the spacing intervals proposed in the NPRM is unclear and may not provide sufficient mitigation for the systems that it does cover. The final rule based on the NPRM, published in the Federal Register on April 8, 2022, did not address these shortcomings. However, we note that you have taken or plan to take the following additional actions: • On June 10, 2021, you issued an advisory bulletin (ADB) to remind pipeline operators that the PIPES Act of 2020 contains a self-executing mandate requiring operators to update their operations and maintenance plans to address eliminating hazardous leaks and minimizing releases. • You plan to publish another NPRM, “Pipeline Safety: Gas Pipeline Leak Detection and Repair,” which may address the leak detection provisions of our recommendation. Issuance of this NPRM and final rule are required by the PIPES Act of 2020. • You plan to update your special permit conditions to include use of automatic shut-off valves (ASVs) and remote-control valves (RCVs), leak detection surveys, and leak remediation when new class location special permits are granted. Additionally, conditions for new class location special permits will include surveys at valves, lateral tie-ins, pipeline in line inspection launchers and receivers, and relief valves that discharge gas along the special permit area. • You have sponsored two research and development projects on new and improved leak detection technology for locating, quantifying, and reducing the volume of pipeline leaks. The Gas Pipeline Leak Detection and Repair NPRM and final rule, and the additional alternate actions that you described, may satisfy our recommendation provided you can supply data showing that they are achieving results similar to the recommended requirement. Pending the publication and our review of the NPRM, completion of the additional planned actions, and submission of data showing that the alternative actions are achieving similar results to a requirement, Safety Recommendation P-11-10 is 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 plan to address these two recommendations in a notice of proposed rulemaking (NPRM), “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 understand that, although you continue to work on this NPRM, its issuance has been delayed by the governmentwide regulatory review required by executive order. Pending publication of the NPRM and the final rule, Safety Recommendations P-11-10 and -11 remain classified OPEN--ACCEPTABLE 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: In our June 6, 2016, comments on your April 8, 2016, NPRM, “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines,” we addressed your statement that “leak detection devices mitigate rather than prevent accidents,” and your deferring action on Safety Recommendation P-11-10 until after you complete ongoing research and analysis as part of your greater leak-detection study. We further noted that you have not addressed the valve upgrade issues in topic H of the NPRM. We now understand that you plan to incorporate aspects of this recommendation into your future NPRM, “Pipeline Safety: Amendments to Parts 192 and 195 to Require Valve Installation and Minimum Rupture Detection Standards,” with an expected publication of the proposed rule by late spring 2017. We look forward to reviewing the proposed NPRM in hope that it addresses this issue. Pending publication of the final rule, Safety Recommendation P-11-10 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 note that, in March 2012, PHMSA held a public workshop to discuss expanding the use of pipeline leak detection systems and enhancing the effectiveness of automatic and remote controlled valves on the nation’s natural gas and liquid pipelines, and that, in October 2012, it issued a study assessing leak detection system effectiveness for gas transmission and distribution lines as well as hazardous liquids facilities and related flow lines (http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=80). We also note that PHMSA is working with the regulated community to address these issues and is considering possible rulemaking for both liquid and gas lines in light of the study’s results. Pending the recommended rulemaking, Safety Recommendation P-11-10 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 note that you will address aspects of this recommendation in an NPRM titled Pipeline Safety: Amendments to Parts 192 and 195 to Require Valve Installation and Minimum Rupture Detection Standards, which you expect to publish this spring. Pending timely issuance of rulemaking that incorporates the recommended requirement, Safety Recommendation P-11-10 is classified OPEN—ACCEPTABLE RESPONSE.

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 has already accelerated our new Control Room Management rule’s effective date from February 1, 2013 to October 1, 2011. That new rule addresses human factors and other aspects of control room management for pipelines where pipelines use supervisory control and data acquisition (SCADA) systems. Under this rule, affected pipeline operators must define the roles and responsibilities of controllers and provide controllers with the necessary information, training and processes to fulfill these responsibilities. Operators must also implement methods to prevent controller fatigue. The rule further requires operators to manage SCADA alarms, assure control room considerations are taken into account when changing pipeline equipment or configurations and review reportable incidents or accidents to determine whether control room actions contributed to the event. In addition, on August 25, 2011, PHMSA published an Advance Notice of Proposed Rulemaking (ANPRM), which requests comments regarding leak detection systems on natural gas pipelines. As part of a larger study on pipeline leak detection technology, PHMSA will conduct a public workshop in early 2012. This study will, among other things, examine how enhancements to SCADA systems can improve recognition of pipeline leak locations. Additionally, in early 2012 PHMSA plans to hold a pipeline research forum to identify technological gaps, potentially including the advancement of leak detection methodologies. We anticipate advancing rulemaking to address this recommendation following these actions.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2012-04-24

Communication Type: Official Correspondence

Communication Contents: The NTSB notes that, in late 2011, PHMSA issued an Advanced Notice of Proposed Rulemaking (ANPRM), and in 2012, as part of a study to examine how enhancements to SCADA systems can improve recognition of pipeline leak locations, will hold a public workshop as well as a public forum on leak detection. Because PHMSA intends to initiate rulemaking once these actions are complete, Safety Recommendation P-11-10 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 believes it can address this recommendation through a host of actions described below. PHMSA notes that NTSB expressed concerns2 that the criteria proposed in the Notice of Proposed Rulemaking (NPRM), Pipeline Safety: Valve Installation and Minimum Rupture Detection Standards, published on February 6, 2020, will not meet fully the safety intent of P-11-10. PHMSA acknowledges that the NPRM does not fully meet this recommendation in its entirety and believes the safety intent of this recommendation can be met through the following actions: • Regulatory Actions: o Future rulemaking: Section 113 of the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2020 requires that PHMSA issue regulations requiring certain classes of operators to conduct leak detection and repair programs in order to “(a) meet the need for gas pipeline safety and (b) protect the environment.” The leak detection provisions of NTSB’s recommendation will be best addressed in a future NPRM titled Pipeline Safety: Gas Pipeline Leak Detection and Repair, which implements Section 113. In May 2021, PHMSA held a two-day public meeting to discuss leak detection, leak repair, and existing and emerging technologies to detect and repair leaks. The purpose of the meeting was to gather information to inform the NPRM. According to PHMSA’s December 2021 PIPES 2020 Act Web Chart, 3 PHMSA plans to publish the NPRM by the end of May 2022. o Ongoing rulemaking: PHMSA’s Pipeline Safety: Valve Installation and Minimum Rupture Detection Standards proposed rule will strengthen leak detection requirements to reduce the consequences of natural gas and hazardous liquid pipeline ruptures. PHMSA appreciates NTSB’s acknowledgement that this rule addresses some aspects of the safety recommendation. According to PHMSA’s December 2021 PIPES 2020 Act Web Chart, PHMSA plans to publish this rule by the end of March 2022. o Special permits: PHMSA will update our special permit conditions to include usage of automatic shut-off valves (ASV)/remote control valves (RCV), leak detection surveys, and remediation of leaks when new class location special permits are granted. Additionally, conditions for new class location special permits will include surveys at valves, lateral tie-ins, pipeline in-line inspection launchers and receivers, and relief valves that discharge gas along the special permit area. o Advisory bulletin: On June 10, 2021, PHMSA issued an advisory bulletin (ADB) in the Federal Register to remind each owner and operator of a pipeline facility that Section 114(a) of the PIPES Act of 2020 contains a self-executing mandate requiring operators to update their operations and maintenance plans to address eliminating hazardous leaks and minimizing releases. Additionally, in early 2022, PHMSA plans to host a public informational webinar on PHMSA and states’ plans to inspect pipeline facility operators’ inspection and maintenance procedures to eliminate hazardous leaks, minimize releases of natural gas, and remediate or replace leak-prone pipes • Research and Development Activities: o Ongoing: PHMSA is investing in research and development (R&D) on new or improved leak detection technology solutions for locating, quantifying, and reducing the volume of pipeline leaks, including small leaks, before these leaks lead to catastrophic ruptures. In 2019, PHMSA funded artificial intelligence research for hazardous liquid pipelines that seeks to identify very small leaks which are normally not identified in the operational data collected by operators.4 In 2020, PHMSA awarded a second project for modeling of pipeline cracking defects that will support improved leak rate estimation.5 PHMSA also funded a methane leak detection project to validate and pinpoint locations and estimate leak sizes in pipeline systems using drones under varying operational conditions across urban and rural sites.6 These research projects are underway and expected to be completed by mid-2022. o Future: PHMSA held the Pipeline Transportation: Hydrogen and Emerging Fuels R&D Public Meeting and Forum, from November 30 through December 2, 2021. This event provided an opportunity for the public, government, and industry pipeline stakeholders to develop recommendations on the technical gaps and challenges for future pipeline safety research. Based on the safety gaps identified and the recommendations made during the R&D Forum, PHMSA plans to fund research to advance best technologies and practices for preventing or mitigating leaks on pipeline systems. PHMSA would like to provide NTSB with additional information on these alternative actions and requests a meeting with NTSB to discuss.

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 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." According to the Department of Transportation's (DOT) March 2019 Significant Rulemakings Report, PHMSA currently plans to publish the proposed rule in August 2019 and looks forward to the NTSB's comments.

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 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," which is expected to be published in December 2019. PHMSA looks forward to the NTSB's comments on the NPRM.

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 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 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 January 14, 2022, PHMSA proposed to address Safety Recommendation P-11-10 through alternative actions, including publication of the Valve Rule and research and development (R&D) activities. By correspondence dated May 2, 2022, NTSB classified this Safety Recommendation as “Open – Acceptable Alternate Response.” PHMSA is pleased to inform NTSB of the following completed actions: Valve Rule On April 8, 2022 (with editorial and technical corrections dated August 1, 2023 and June 28, 2024), PHMSA issued the Valve Rule. The Valve Rule requires operators of certain newly constructed and “entirely replaced” gas and hazardous liquid (including carbon dioxide) pipelines to install rupture-mitigation valves (RMVs) or alternative equivalent technologies, and establishes minimum performance standards for the operation of the same. It also establishes minimum safety performance standards for the identification of ruptures, pipeline segment isolation, and other mitigative actions for pipelines on which RMVs or alternative equivalent technology are installed. Specifically, the Valve Rule requires that RMVs or alternative equivalent technologies must be capable of being monitored or controlled either remotely or by on-site personnel. For RMVs or equivalent technologies connected to SCADA systems, the valve status, flow, and pressure monitoring helps controllers pinpoint potential indications of a leak or the location of a leak. 49 CFR §§ 192.636(d) and 195.419(d). Leak Detection Research and Development PHMSA sponsored several R&D projects focused on new or improved technologies for locating, quantifying, and reducing the volume of pipeline leaks. Examples of those projects include: • Improving the Reliability, Detection, and Accuracy Capabilities of Existing Leak Detection Systems (CPMs) Using Machine Learning: Completed in 2021, this project addressed: 1) finding smaller leaks; 2) finding leaks faster; and 3) finding leaks more reliably with fewer false alarms than legacy computational pipeline monitoring (CPM) leak detection systems. This project provided a machine learning framework that pipeline operators may use to “train models used to monitor a pipeline instrumented with flow sensors and pressure sensors in real-time using an anomaly detection autoencoder.” The researcher concluded that “[it] is anticipated that operators will be able to use the [artificial intelligence] framework developed in this project in accordance with the guidelines provided to generate models which can be integrated with [the operator’s] leak detection systems to increase [its] sensitivity and decrease false alarms.” • Validation of Remote Sensing and Leak Detection Technologies Under Realistic Differing Conditions: Completed in 2022, this project advanced unmanned aerial system mounted remote sensing technologies for identification of integrity threats and detection of natural gas leaks. The project results established a validation testing framework that was proven during field testing. It also documented an understanding of uncertainties for each technology tested. • Modeling Slow Crack Growth Under Thermal and Chemical Effects and Accurate NDT of Cracks for Fitness Predictions of Polyethylene Pipes: Completed in 2023, this project provided: 1) a new model for slow crack growth (SCG), which incorporates thermal and chemical effects; 2) confirmation of significant impact of chemical exposure for SCG; and 3) application of machine learning in non-destruction evaluation of embedded cracks to predict accurately and quickly both crack length and crack positions. Overall, PHMSA and its predecessor, the Research and Special Programs Administration, have provided approximately $18.1 million in R&D funding for leak detection and related technologies to advance the Nation’s pipeline transportation system and to improve safety since 2001. Details of additional leak detection R&D projects and examples of successful knowledge/technologies transfer can be found on PHMSA’s website. PHMSA understands the importance of quickly recognizing and pinpointing the location of leaks and the role SCADA systems can play to assist in leak detection. The publication of the Valve Rule and R&D dedicated to improved leak detection technology demonstrate that PHMSA has achieved the safety intent of NTSB Safety Recommendation P-11-10. 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: 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: In October 2012, PHMSA published a leak detection study assessing leak detection system effectiveness for gas transmission and distribution lines as well as hazardous liquids facilities and related flow lines on its website at: http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=80. In March 2012, PHMSA held a public workshop to discuss expanding the use of pipeline leak detection systems and enhancing the effectiveness of automatic and remote controlled valves on the Nation’s natural gas and liquid pipelines. Furthermore, a Regulatory Support Paper for rulemaking considerations for both liquid and gas lines that considers the results of the study has been developed and is under agency review. PHMSA continues to work with the regulated community to address this issue.

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 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," which would establish performance-based meaningful metrics for rupture detection, focused on large, unsafe, uncontrolled release events. The NPRM is currently being drafted, and we expect to publish it by Spring 2015.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence