NTSB Safety Recommendation P-11-015

NTSB safety recommendation P-11-015.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Amend Title 49 Code of Federal Regulations Part 192 of the Federal pipeline safety regulations so that manufacturing- and construction-related defects can only be considered stable if a gas pipeline has been subjected to a postconstruction hydrostatic pressure test of at least 1.25 times the maximum allowable operating pressure.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2011-09-26

Adopted Date: 2011-09-12

Overall Date Closed: 2020-01-23

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 Action

Addressee Date Closed: 2020-01-23

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: 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 J—Pipe Manufactured Using Longitudinal Weld Seams Summary As a result of the September 9, 2010, pipeline rupture in San Bruno, California, the NTSB issued the following safety recommendation. Amend Title 49 Code of Federal Regulations Part 192 of the federal pipeline safety regulations so that manufacturing- and construction-related defects can only be considered stable if a gas pipeline has been subjected to a postconstruction hydrostatic pressure test of at least 1.25 times the maximum allowable operating pressure. (P-11-15) Safety Recommendation P-11-15 asked PHMSA to amend the pipeline safety regulations so that manufacturing- and construction-related defects can be considered stable only when a gas pipeline has been subjected to a postconstruction hydrostatic pressure test of at least 1.25 times the MAOP. PHMSA also noted in the NPRM that the NTSB recommendation includes the pressure testing of all longitudinal seam welds in an HCA to determine if the seam weld is “stable.” PHMSA proposes to revise the IM requirements in 49 CFR 192.917(e)(3) to specify that longitudinal seams may not be treated as stable defects unless the segment has been pressure tested. Response The NTSB appreciates the PHMSA proposal to require postconstruction pressure testing to 1.25 times the MAOP to demonstrate the stability of manufacturing- and construction-related defects.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-01-23

Communication Type: Official Correspondence

Communication Contents: We note that, on April 8, 2016, you published an NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” to address these recommendations, and in our June 6, 2016, comments about the NPRM, we said the proposed rule was likely to satisfy Safety Recommendations P 11 14 and 15. The final rule, however, published on October 1, 2019, and effective July 1, 2020, does not completely eliminate the grandfather clause in certain low-risk situations, as recommended. Further, you did not include a requirement for spike testing, as recommended, because you believe such a requirement should be discussed in the context of integrity management (IM). However, you have implemented a new regulatory section, 192.624, to address Safety Recommendation P 11 14, which also addresses mandates specified in the 2011 Pipeline Safety Act. The new section specifies that the following methods can be used to reconfirm the MAOP: • Pressure test. • Pressure reduction. • Engineering critical assessment. • Pipe replacement. • Pressure reduction. • Alternative technology. These actions are an alternative that meets the intent of Safety Recommendation P 11 14, which is classified “Closed—Acceptable Alternate Action.” We further note that revisions to section 192.917(e) (3) in the final rule satisfy Safety Recommendation P 11 15, which is classified CLOSED--ACCEPTABLE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: We note that, on April 8, 2016, you published an NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” to address these recommendations, and in our June 6, 2016, comments about the NPRM, we said it was likely to satisfy them. We further note that, although you expected to publish the final rule by the end of 2017, publication has been delayed by the governmentwide regulatory review required by executive order. Pending publication of the final rule, Safety Recommendations P-11-14 and -15 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: On June 6, 2016, in our comments to your NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” we expressed our approval of the proposal to remove the grandfather clauses. Pending publication of the final rules, Safety Recommendation P-11-15 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, on August 7, 2013, PHMSA conducted a public workshop to present its proposed Integrity Verification Process (IVP) for ensuring that pipeline operators address testing requirements to demonstrate seam stability and confirm the material strength of untested gas transmission pipelines. We note that PHMSA will formalize the IVP in upcoming rulemaking and is considering the recommended removal of the grandfather clause. Pending publication of the final rule as recommended, Safety Recommendations P-11-14 and -15 remain 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 from your August 29, 2013, update that you conducted a public workshop on the integrity verification, planned to formalize the process in rulemaking, and were considering the recommended removal of the grandfather clause. We are disappointed that you still have not initiated the expected rulemaking; however, we are encouraged that you plan to do so. We encourage you to expedite this action. Pending timely publication of a final rule that satisfies these recommendations, Safety Recommendations P-11-14 and -15 remain classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2012-04-24

Communication Type: Official Correspondence

Communication Contents: Because PHMSA initiated regulatory action to address these issues, with the August 2011 issuance of an ANPRM, Pipeline Safety: Safety of Gas Transmission Pipelines, Safety Recommendations P-11-11, -14, and -15 are classified OPEN—ACCEPTABLE RESPONSE, pending publication of the recommended final rule.

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: PHMSA appreciates the NTSB's comments on the Gas Rule NPRM noting that PHMSA's proposal to require post-construction pressure testing to 1.25 times the maximum allowable operating pressure (MAOP) is in line with this recommendation. This testing would demonstrate the stability of manufacturing and construction-related defects. As discussed in our response to Recommendation P-11-14, PHMSA separated the Gas rule into three rulemaking actions. PHMSA plans to address this recommendation in the "Pipeline Safety: Safety of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments" final rule, which is expected to be published in August 2019, according to the DOT's March 2019 Significant Rulemakings Report.

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 proposes closure of this recommendation. On October 1, 2019, PHMSA published the "Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments" final rule.2 Section 192.917(e)(3) of the final rule states that an operator may consider manufacturing- and construction-related defects to be stable defects only if the covered segment has been subjected to hydrostatic pressure testing satisfying the criteria of subpart J of at least 1.25 times MAOP, and the covered segment has not experienced a reportable incident attributed to a manufacturing or construction defect since the date of the most recent subpart J pressure test.

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 appreciates NTSB's comments on the Gas Transmission NPRM expressing approval on PHMSA's proposal to require post construction pressure testing to 1.25 times the MAOP to demonstrate the stability of manufacturing- and construction related defects actions towards implementing this recommendation. On August 7, 2013, PHMSA held a workshop to present and allow public comment on its IVP proposal to address issues regarding testing requirements to demonstrate seam stability and to confirm the material strength of untested gas transmission pipelines. This change was proposed in PHMSA's NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines" (81FR20721), published on April 8, 2016 (https://www.federalregister.gov I documents/2016/04/08/2016-063 82/pipeline-safetysafety-of-gas-transmission-and-gathering-pipelines ). PHMSA held Gas Pipeline Advisory Committee (GPAC) meetings on the rule on January 12, 2017, and on June 6-7, 2017. PHMSA plans to hold additional meetings in December 2017 to continue discussing the proposed rule. The final rule was initially expected to publish by the end of 201 7. Due to the continued process of gathering GP AC recommendations, we are expecting delays and currently assessing impacts. 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: 2016-08-17

Communication Type: Official Correspondence

Communication Contents: -From Marie Therese Dominguez, Administrator: On August 7, 2013, PHMSA held a workshop to present and allow public comment on its IVP proposal to address issues regarding testing requirements to demonstrate seam stability and to confirm the material strength of untested gas transmission pipelines. Under IVP, pipelines that might be susceptible to cracks or crack-like defects due to manufacturing or construction defects and that need to reestablish MAOP would be required to perform a spike hydrostatic pressure test. Spike pressure tests help ensure that hydrostatic pressure tests are not allowing cracks to grow that could fail in service after the test is completed. The IVP was proposed in PHMSA's NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines," published on April 8, 2016. The comment period closed on July 7, 2016.

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: On August 7, 2013, PHMSA held a workshop to present and allow public comment on its IVP proposal to address issues regarding testing requirements to demonstrate seam stability and to confirm the material strength of untested gas transmission pipelines operating under the Grandfather Clause. PHMSA will formalize the IVP in an upcoming rulemaking.

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 August 7, 2013, PHMSA held a workshop to present and allow public comment on its IVP proposal to address issues regarding testing requirements to demonstrate seam stability and to confirm the material strength of untested pre-code legacy gas transmission pipelines. PHMSA will formalize the IVP in the "Pipeline Safety: Safety of Gas Transmission Pipelines" NPRM. The NPRM is currently under agency review, and we expect to publish it in 2015.

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’s August 2011 rulemaking also began the regulatory process needed to implement rulemaking to strengthen the Integrity Management requirements relating to manufacturing and construction defects. We plan to advance this rulemaking during 2012.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence