NTSB Safety Recommendation P-11-020

NTSB safety recommendation P-11-020.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Work with state public utility commissions to (1) implement oversight programs that employ meaningful metrics to assess the effectiveness of their oversight programs and make those metrics available in a centralized database, and (2) identify and then correct deficiencies in those programs.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2011-09-26

Adopted Date: 2011-09-12

Overall Date Closed: 2016-12-05

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: 2016-12-05

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: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: We understand that you and the National Association of Pipeline Safety Representatives (NAPSR) have completed action as requested on this issue. We note that, in February and April of 2013, you and NAPSR met to develop draft metrics and preliminary criteria for screening those metrics. The draft states metrics were identified and approved by NAPSR, and these metrics are now available on your new State Program Performance Metrics pages, which can be accessed through the “state pages” directory on the Pipeline Safety Stakeholder Communications website (http://primis.phmsa.dot.gov/comm/States.htm?nocache=7437). Further, new links have been added to the primary stakeholder pages that point to the state pages directory for access to the metrics pages. You and NAPSR have reviewed the metrics with each state pipeline program as part of the states’ annual on-site program evaluation, and have discussed how to improve the metrics, where warranted, with state program managers. Because these combined actions satisfy the intent of Safety Recommendation P-11-20, it is classified CLOSED—ACCEPTABLE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2014-01-03

Communication Type: Official Correspondence

Communication Contents: We note that the National Association of Pipeline Safety Representatives (NAPSR) and PHMSA met in February and April 2013 to develop draft metrics and preliminary criteria for screening those metrics, that PHMSA is coordinating the work of this team with the work of the teams overseeing P-11-18 and P-11-19, and that the agency is communicating the outcome of these efforts with pipeline operators. Pending completion of these efforts, Safety Recommendation P-11-20 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 understand that you and the National Association of Pipeline Safety Representatives (NAPSR) developed draft metrics and preliminary criteria for screening them, and that NAPSR has approved draft state metrics, available on your new State Program Performance Metrics pages and accessible through the State Pages directory on the Stakeholder Communications website at http://primis.phmsa.dot.gov/comm/States.htm?nocache=7437. In addition, we note that you added links to the primary stakeholder pages and, along with NAPSR, plan a thorough review of the metrics with each state pipeline program as part of the state’s annual on-site program evaluation. We further note that states will be asked to correct any deficiencies identified in their programs. Pending completion of your review of state programs, Safety Recommendation P-11-20 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2012-04-24

Communication Type: Official Correspondence

Communication Contents: The NTSB is encouraged that PHMSA plans to work, or already has begun to work, (1) with state pipeline safety programs, (2) with the National Association of Regulatory Utility Commissioners, and (3) with the National Association of Pipeline Safety Representatives to address this recommendation. We are further encouraged that your agency is working to improve the transparency of its data and of state pipeline safety program data. Pending completion of these efforts to implement Safety Recommendation P-11-20, this recommendation is classified OPEN—ACCEPTABLE RESPONSE.

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 proposes closure of this recommendation. The National Association of Pipeline Safety Representatives (NAPSR) and PHMSA met in February and April of 2013 to develop draft metrics and preliminary criteria for screening those metrics. The draft state metrics have been identified and approved by NAPSR. These metrics are available on PHMSA's new State Program Performance Metrics pages, which can be accessed through the State Pages directory on the Stakeholder Communications website at http://primis.phmsa.dot.gov/comm/States.htm?nocache=7437. New links have also been added to the primary stakeholder pages that point to the State Pages directory for access to the metrics pages. A review of the metrics was conducted with each state pipeline program as part of its annual on-site program evaluation, and discussions regarding how to improve the metrics, where warranted, were conducted with State Program Managers. PHMSA does not envision taking further action to close this recommendation.

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: The National Association of Pipeline Safety Representatives (NAPSR) and PHMSA met in February and April of 2013 to develop draft metrics and preliminary criteria for screening those metrics. PHMSA is coordinating the work of this team with the work of the teams overseeing P-11-18 and P-11-19. PHMSA is working to communicate the outcome of these efforts with pipeline operators.

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 met with the National Association of Pipeline Safety Representatives (NAPSR) in February and April of2013 to develop draft metrics and preliminary criteria for screening those metrics. The draft state metrics have been identified and approved by NAPSR. These metrics are available on PHMSA's new State Program Performance Metrics pages, which can be accessed through the State Pages directory on the Stakeholder Communications website at http://primis.phmsa.dot.gov/comm/States.htm?nocache=7437. New links have also been added to the primary stakeholder pages that point to the State Pages directory for access to the metrics pages. A thorough review of the metrics will be conducted with each state pipeline program as part of their annual on-site program evaluation. Each state program will be asked to address and correct any noted deficiencies.

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 will work with State Pipeline Safety programs to evaluate ways to improve the oversight of the State programs and correct identified deficiencies. We have begun dialog on this and other topics relating to the performance of State programs with the National Association of Regulatory Utility Commissioners who, as a general rule, direct the actions of our State pipeline safety program managers. We have also begun parallel discussions with the National Association of Pipeline Safety Representatives. PHMSA has for some years now been committed to increasing the transparency of its own data, and has over the past few years been pushing for greater transparency of State pipeline safety program data. We are engaged with the many States now, and will be using State generated data in the next year to increase the amount of performance data available to the public.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence