NTSB Safety Recommendation P-11-019

NTSB safety recommendation P-11-019.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: (1) Develop and implement standards for integrity management and other performance-based safety programs that require operators of all types of pipeline systems to regularly assess the effectiveness of their programs using clear and meaningful metrics, and to identify and then correct deficiencies; and (2) make those metrics available in a centralized database.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2011-09-26

Adopted Date: 2011-09-12

Overall Date Closed: 2015-04-08

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: 2015-04-08

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 D—Improving Requirements for Collecting, Validating, and Integrating Pipeline Data Summary PHMSA proposes to amend the requirements for collecting, validating, and integrating pipeline data by adding specificity to the data integration language in the IM rule to establish pipeline attributes that must be included in the MAOP analysis, by explicitly requiring that operators integrate analyzed information, and by requiring that data be verified and validated. In addition, PHMSA has determined that additional rules are needed to ensure that records used to establish the MAOP are reliable, traceable, verifiable, and complete. The proposed rule would add a new paragraph (e) to 49 CFR 192.619 to codify this requirement and to require that such records be retained throughout the lifecycle of the pipeline. These proposed changes address NTSB Safety Recommendation P-11-19, which resulted from the investigation of the September 9, 2010, pipeline rupture in San Bruno, California. (1) Develop and implement standards for integrity management and other performance-based safety programs that require operators of all types of pipeline systems to regularly assess the effectiveness of their programs using clear and meaningful metrics, and to identify and then correct deficiencies; and (2) make those metrics available in a centralized database. (P-11-19) Response The NTSB believes that adding specificity, as proposed in this NPRM, is a favorable addition to IM analysis requirements. We further concur that expanding pipeline records requirements is a significant improvement in the management of pipelines through their service lifecycle.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2014-01-03

Communication Type: Official Correspondence

Communication Contents: At the September 2013 joint staff meeting, we learned that PHMSA has made great progress in addressing these issues that include near-completion of a two-pronged approach to enhance oversight of current requirements for performance evaluation and associated measures, and to develop and improve guidance for operators to develop more meaningful metrics. We are aware that PHMSA created gas and liquid data and metrics teams and, in December 2012, issued an ADB reminding operators of gas transmission and hazardous liquid pipeline facilities of their responsibilities, under federal integrity management regulations, to evaluate their integrity management programs using meaningful performance metrics. We are also aware of PHMSA’s January, 2013 data workshop, its database of metrics available on the PHMSA website, and the agency’s other efforts in support of these recommendations. Pending completion of the recommended actions, Safety Recommendations P-11-18 and -19 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 pleased to learn that you developed Guidance for Strengthening Pipeline Safety through Rigorous Program Evaluation and Meaningful Metrics, which was incorporated into ADB-2014-05. We note that this document provides a better description of the steps involved in program evaluations and expands and clarifies your expectations for operator processes for measuring IM program effectiveness. Finally, we note that you have posted this guidance for public viewing at https://www.federalregister.gov/articles/2014/10/15/2014-24439. Your actions satisfy Safety Recommendation P-11-19, which is classified CLOSED—ACCEPTABLE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2012-04-24

Communication Type: Official Correspondence

Communication Contents: The NTSB understands that PHMSA’s IMP contains some of the recommended metrics, and we are encouraged that PHMSA plans to continue working with applicable stakeholders to improve those metrics and to ensure that operators regularly assess the effectiveness of their programs and correct identified deficiencies. We are also encouraged that PHMSA plans to advance the goals of this recommendation in a spring 2012 pipeline safety data workshop. Pending completion of PHMSA’s efforts to satisfy this recommendation, Safety Recommendation P-11-19 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2013-08-29

Communication Type: Official Correspondence

Communication Contents: -From Cynthia L. Quarterman, Administrator: PHMSA currently maintains a centralized and publically available database of metrics on its website. Operators mandatorily submit many of these metrics to PHMSA. Available metrics include, but are not limited to: number of Serious Incidents by year, causes of Serious Incidents, number of Significant Incidents by year, consequences of Significant Incidents, and number of incidents reported by year. PHMSA also posts the complete data sets. To sharpen PHMSA’s focus on key performance indicators, PHMSA established the gas and liquid data teams described in P-11-18. Further, as part of the API 1173 Standard Development team that is working on Pipeline Safety Management Systems, PHMSA, State partners, and industry members are identifying key performance indicators to help identify measures to support meaningful metrics.

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 proposes closure of this recommendation. PHMSA collects annual reports and incident reports from pipeline operators in a centralized database and continuously seeks to modify data collection activities to improve this collected information. PHMSA has made significant progress in posting this information to our website that summarize and display trends in key performance metrics based on the data from these reports. Our website provides a view of the trend and access to the operator-specific data comprising the overall trend. This operator-specific data is used extensively to compare pipeline operators as discussed in the response to P-11-18-4. Performance metrics displayed on the PHMSA website include, but are not limited to, data on incidents, IM performance, and pipeline materials. Data available to stakeholders in PHMSA's centralized databases allows operators to review their specific metrics as well as Industry-wide metrics to support the identification of areas of concern where the implementation of additional meaningful metrics would support program and system integrity improvements. Additionally, on October 15, 2014, PHMSA issued ADB-2014-05, "Pipeline Safety: Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics," available online at https://www.federalregister.gov/articles/20 14110/ 15/2014-24439/pipeline-safety-guidance-for-strengthening-pipeline-safcty-through-rigorous-programevaluation-and, to inform owners and operators of natural gas and hazardous liquid pipelines of our expectations. The advisory provides more extensive guidance on the elements and characteristics of a mature IM program evaluation process using meaningful metrics. PHMSA also developed a supporting guidance document, "Guidance for Strengthening Pipeline Safety through Rigorous Program Evaluation and Meaningful Metrics," which is incorporated into ADB-2014-05. The guidance builds on existing standards and regulations to provide a more detailed and comprehensive description of the steps involved in program evaluations, as well as the selection of meaningful performance metrics to support these evaluations. The guidance expands and clarifies PHMSA's expectations for operator processes when measuring IM program effectiveness. The guidance is posted on the public website at https://www.federalregistcr.gov/articlcs/2014/10/15/2014-24439/pipclinc-safcty-guidance-forstrengthening-pipeline-safety-through-rigorous-program -evaluation-and.

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 agrees that clear, meaningful, and readily available metrics are important. PHMSA’s integrity management program has many metrics in place. However, PHMSA will continue to meet with representatives of the NTSB and States to evaluate ways to improve those metrics to ensure that operators regularly assess the effectiveness of their programs and correct identified deficiencies. As mentioned above, PHMSA will also advance the goals of this recommendation in a Spring 2012 pipeline safety data workshop.