# NTSB Safety Recommendation P-11-011

- **operation:** document
- **citation:** P-11-011
- **title:** NTSB Safety Recommendation P-11-011
- **source type:** guidance
- **agency:** National Transportation Safety Board
- **status:** guidance
- **official:** true
- **published on:** 2011-09-26
- **effective on:** 2011-09-26
- **summary:** TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: 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.
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**body:**

NTSB safety recommendation P-11-011.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: 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.

Priority: CLASS II

Overall Status: Closed - Unacceptable 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.

Keywords: Remote Operated Valves

Ntsbnumber: DCA10MP008

Report Number: PAR-11-01

Addressee Name: PHMSA

Addressee Status: Closed - Unacceptable 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: 2020-12-10

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: Class Location Change Requirements, published on October 14, 2020. In this notice, PHMSA is proposing, “to add an alternative set of requirements within the Pipeline Safety Regulations (PSR) that operators could use, based on implementing integrity management principles and pipe eligibility criteria, to manage certain pipeline segments where the class location has changed from a Class 1 location to a Class 3 location.” This NPRM references NTSB Safety Recommendation P-11-11 which is associated with the current NTSB Most Wanted List of Transportation Safety Improvements (MWL), under the issue area “Ensure the Safe Transportation of Hazardous Materials.” Safety Recommendation P-11-11 is currently classified “Open—Acceptable Response.” The NTSB’s MWL identifies the top safety improvements that should be made across all transportation modes to prevent accidents, minimize injuries, and save lives. The NTSB encourages PHMSA to address the shortcomings in the NPRM and satisfy the relevant NTSB safety recommendation. PHMSA’s proposed revisions to its rules include the following: • Amend the required actions on gas transmission pipeline segments that experience a change in class location from Class 1 to Class 3. o Under the existing regulations, pipeline segments located in areas where the population density has significantly increased, must perform one of the following actions: 1. reduce the pressure of the pipeline segment, 2. pressure test the pipeline segment to higher standards, or 3. replace the pipeline segment. o The proposed rule would offer a fourth option for locations that have gone from Class 1 to Class 3. This new option would require operators to implement the integrity management practices within Subpart O of Title 49 Code of Federal Regulations (CFR) Part 192, including periodic assessments and remediation activities. o In addition, in segments where operators exercise this fourth option, operators would be required to perform other preventive and mitigative measures, including monitoring, through the use of supervisory control and data acquisition, increased frequency of leak surveys, and installation of remote-control valves (RCV) and automatic-shutoff valves (ASV). o A number of specifications are listed that a pipeline segment must meet to be able to select the fourth option; if the segment does not meet these more stringent requirements, the operator cannot choose the new option. The NPRM references three NTSB investigations and Safety Recommendation P-11-11: • Reports supporting the 2003 integrity management final rule: o On March 23, 1994, eight buildings were destroyed and about 1,500 residents were evacuated when a 36-inch diameter natural gas transmission pipeline in Ellison Township, New Jersey, ruptured (PAR-95-01). Ninety-three individuals were treated at hospitals for injuries sustained during the accident. o On August 19, 2000, a 30-inch diameter natural gas transmission pipeline ruptured adjacent to the Pecos River, near Carlsbad, New Mexico (PAR-03-01). Twelve individuals were fatally injured, and the released gas burned for 55 minutes. • Report and recommendation supporting the current proposed rulemaking: o On September 9, 2010, the rupture of a natural gas pipeline and resulting fire in San Bruno, California, caused eight fatalities and numerous injuries (PAR-11-01). The NTSB’s investigation found weaknesses in the operator’s integrity management program and demonstrated that the consequences resulting from the incident spread far beyond the expected potential impact radius. o Safety Recommendation P-11-11 addresses the installation of ASVs and RCVs 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 since. In its 2011 report on the natural gas explosion in San Bruno, the NTSB concluded the use of ASVs or RCVs would have significantly reduced the amount of time needed to isolate the rupture. As a result, the NTSB issued Safety Recommendation P-11-11 which recommended that PHMSA amend 49 CFR 192.935(c) to require ASVs or RCVs in high consequence areas (HCA) and in Class 3 and 4 locations, be installed and spaced at intervals that consider the factors listed in that regulation. In this NPRM, PHMSA proposes changes that are consistent with Safety Recommendation P-11-11. In addition to the noted safety recommendations, the NTSB is also concerned about the special permit process, outlined in 49 CFR 190.341. The special permit process is used by operators to request waivers of any portion of the PSR. In this process, “PHMSA waives or otherwise modifies compliance with regulatory requirements if the operator requesting the special permit demonstrates a need and PHMSA determines that granting the special permit would be consistent with pipeline safety.” This proposed rulemaking acts to replace the special permit process, by which operators can apply to be exempted from the requirements of 49 CFR 192.611 under special circumstances. However, 49 CFR 190.341 remains valid and can be used by operators to request PHMSA waive any other portion of the PSR. The special permit process is rigorous by design. It requires operators to submit “a list of the proposed sites, pipeline attributes, prior assessment results and assessment schedules, incident and leak history, prior repairs, damage prevention initiatives, prior safety-related condition reports, a summary of integrity threats, and the operator’s risk-control activities.” After reviewing this documentation, if PHMSA deems a special permit is consistent with pipeline safety, PHMSA approves the special permit, “on the condition that operators implement integrity assessments and other [preventive and mitigative] measures, which go beyond the regulatory requirements.” PHMSA has denied approximately half of the special permit applications for waivers of class location change requirements. PHMSA notes that there have been no leaks or failures on the approximate “100 miles of current class location change special permit pipeline segments” to date, in justification for this NPRM; however, this mileage represents about 0.3 percent of the 32,883 miles of Class 3 natural gas transmission pipelines currently in operation. The NTSB is concerned that the additional monitoring and remediation required by the NPRM, while highly beneficial, may be less effective than the current requirements for class changes, due to the small supportive data set. While the NTSB commends PHMSA on the expansion of the applicability of Subpart O, the NTSB also notes that the special permit process in place allows for a highly detailed analysis when waivers are requested on Class 1 to Class 3 change requirements. The NTSB urges PHMSA to consider how they will provide the same level of scrutiny and attention to detail on the larger scale of locations impacted by this regulation, and if necessary, make changes to the NPRM and PHMSA’s inspection procedures accordingly. The NTSB supports the designation of an HCA for these Class 1 to Class 3 locations when they meet the requirements of proposed 49 CFR 192.618(a). The majority of the restrictions outlined under proposed 49 CFR 192.618(a)(4) concur with the NTSB’s historical knowledge of higher risk pipelines. The NTSB strongly urges PHMSA to consider how it will ensure implementation of these restrictions, including full document review, without the more extensive special permit process. Under 49 CFR 192.618(a)(4)(vii), PHMSA proposes to exclude pipelines where certain pipeline characteristics or failure history are present within 5 miles of the class change. The NTSB urges PHMSA t

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2024-05-20

Communication Type: NPRM Response

Communication Contents: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) notice and request for comments, titled “Information Collection Activities: Mitigation of Ruptures on Onshore Gas Transmission and Gathering, Hazardous Liquid, and Carbon Dioxide Pipeline Segments Using Rupture-Mitigation Valves or Alternative Equivalent Technologies and Blending of Hydrogen Gas and Natural Gas within Gas Pipelines,” published on March 25, 2024. The notice invites public comments on proposed changes to existing PHMSA information collections. PHMSA indicated that the changes are needed, in part, to demonstrate an alternative approach to the implementation of NTSB Safety Recommendation P-11-11. Our response focuses on PHMSA’s proposed changes that relate to Safety Recommendation P-11-11. Safety Recommendation P-11-11 was 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.1 In our San Bruno investigation, we concluded that the use of automatic shutoff valves or remote-control valves would have significantly reduced the amount of time needed to isolate the rupture and recommended that PHMSA: 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) In an effort to address recommendation P-11-11, PHMSA said in a January 14, 2022, letter to the NTSB that it planned to take several actions that together may collect data to show that the measures they are taking satisfy the intent.3 One of those actions is to add a question to Form F7100.2-1, Gas Transmission and Gathering Annual Report Form, requiring operators to inform PHMSA of the number of valves installed on their systems to protect high consequence areas and class 3 and 4 segments and how they are monitored and operated for emergency closure. PHMSA’s proposed information-collection changes include collecting data on the number of miles of pipeline segments that have rupture-mitigation valves or alternative equivalent technology to mitigate the consequences of a potential rupture.4 These proposed changes do not appear to be consistent with the approach previously proposed by PHMSA in its January 14, 2022, letter to the NTSB. Having the sufficient number of valves and appropriate operating methods is important for rapid pipeline shutdown to facilitate the swift isolation of ruptured pipe segments, reducing the release of hazardous materials and mitigating severe consequences. Without additional information from PHMSA, it is not possible for us to determine whether this change in the information they requested would satisfy the intent of our recommendation or would result in similar safety benefit. Therefore, NTSB encourages PHMSA to request the necessary data in its revised annual report form. The NTSB encourages PHMSA to address the comments detailed in this letter and modify the information-collection activities as needed to address our safety recommendation. 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 H—Valve Spacing and the Need for Remotely or Automatically Controlled Valves Summary The installation of remote and automatic controlled valves was addressed in the NTSB accident report on the September 9, 2010, pipeline rupture in San Bruno, California. As a result of this investigation, the NTSB issued the following safety recommendation. 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) The NTSB recommendation P-11-11 called for PHMSA to improve the requirements for installing such valves in HCAs and in class 3 and 4 locations. PHMSA completed a valve study and submitted it to Congress in December 2012. Additionally, under the terms of the Act, the US Comptroller General is conducting a study on the ability of pipeline operators to respond to a hazardous material release. Response Although the NTSB is disappointed in the continued delay in completing the recommended action, we acknowledge that PHMSA is deferring action on this topic until the results of the US Comptroller General’s report addressing hazardous materials release response can be evaluated.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2026-07-13

Communication Type: Official Correspondence

Communication Contents: We have long been concerned about the rapid shutdown of compromised pipelines and the lack of requirements for ASVs or RCVs in HCAs. As far back as 1971, we recommended that the Department of Transportation’s Office of Pipeline Safety develop standards for rapidly shutting down failed natural gas pipelines (Safety Recommendation P-71-1). We understand that PHMSA followed a limited mandate in the 2011 Pipeline Safety Act to update regulations to require ASVs or RCVs for new transmission lines. However, in our response to your February 6, 2020, notice of advance rulemaking, we pointed out that the proposed changes to 49 CFR 192.935(c) were inconsistent with this safety recommendation. Because the final rule’s additional requirements are only applicable to newly constructed or entirely replaced onshore gas transmission pipelines that have nominal diameters greater than or equal to 6 inches, they exclude most of the pipelines that are subject to 49 CFR 192.935(c). Although we acknowledge that PHMSA has taken many actions to address safety concerns raised in our San Bruno report, including enacting new regulations, updating guidance for operators, and improving inspector training, because the ASV and RCV requirements in the Valve Rule only apply to newly constructed or entirely replaced pipelines and no further action is expected, the Board has voted to classify Safety Recommendation P-11-11 CLOSED-- UNACCEPTABLE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2022-05-02

Communication Type: Official Correspondence

Communication Contents: In our comments about your February 6, 2020, NPRM, we pointed out that the proposed changes to 49 CFR 192.935(c) were not consistent with Safety Recommendation P-11-11. Instead of directly requiring ASVs or RCVs in HCAs and class 3 and 4 locations, the proposed changes would add further requirements that must be met once an operator determines that ASVs or RCVs would be an efficient means of adding protection for an HCA. Because the NPRM’s additional requirements are only applicable to newly constructed or entirely replaced onshore gas transmission pipelines that have nominal diameters greater than or equal to 6 inches, they exclude most of the pipelines that are subject to 49 CFR 192.935(c). One of the additional requirements proposed would be to install rupture mitigation valves within specified maximum spacing intervals of 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, type of gas being transported, operating pressure, rate of potential release, pipeline profile, potential for ignition, and location of nearest response personnel. The basis for the maximum rupture-mitigation valve spacing intervals may not be sufficient to mitigate the consequence of a pipe failure. The final rule based on the NPRM, published in the Federal Register on April 8, 2022, does not address these shortcomings. In our comments about another PHMSA NPRM published on October 14, 2020, “Pipeline Safety: Class Location Change Requirements,” we similarly concluded that this NRPM also did not fully satisfy Safety Recommendation P-11-11 because the proposed requirement would not address the majority of the piping systems covered by the recommendation. We note that in addition to these rulemakings, you plan to take several additional actions to address the gaps in your rulemaking and, collectively, satisfy the intent of this recommendation. You plan to do the following: • Update PHMSA’s special permit conditions to require ASVs or RCVs on all new special permits for class location changes and renewal of old special permits. • Issue an ADB addressing existing pipelines in HCAs by highlighting installation of ASVs and RSVs as a compliance strategy under the preventative and mitigative measures in 49 CFR Part 192 Subpart O. • Create a new IA directive on valves that links relevant questions on class location, valve spacing, and Subpart O requirements to emphasize requirements for operators to consider the addition of rupture mitigation valves in HCAs. • Add a question to Form F7100.2-1, Gas Transmission and Gathering Annual Report Form, requiring operators to inform PHMSA of the number of valves installed on their systems to protect HCAs and class 3 and 4 segments and how they are monitored and operated for emergency closure. We note that you have offered to meet with our staff to discuss your proposed actions to address Safety Recommendations P-11-9 thru -11 in more detail. We agree that a conversation would be beneficial; please contact Scott Rainey, Pipeline Safety Recommendation Specialist, at 202-314-6013 to arrange a meeting. The planned actions that you describe may represent an alternative approach that satisfies the intent of this recommendation, provided you can supply data showing that the alternative is achieving results similar to the recommended requirement. Pending the completion of your proposed alternate actions, and submission of data showing that your actions are achieving similar results to a requirement for the installation and appropriate spacing of ASVs or RCVs in HCAs and in class 3 and 4 locations, Safety Recommendation P-11-11 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: We 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 date in late spring 2017. Pending our review of this NPRM and the final rules as requested, Safety Recommendation P-11-11 is classified OPEN—ACCEPTABLE REPSONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date
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