NTSB Safety Recommendation P-11-032

NTSB safety recommendation P-11-032.

TO THE AMERICAN GAS ASSOCIATION AND THE INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA: Report to the National Transportation Safety Board on your progress to develop and introduce advanced in-line inspection platforms for use in gas transmission pipelines not currently accessible to existing in-line inspection platforms, including a timeline for implementation of these advanced platforms.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2011-09-26

Adopted Date: 2011-09-12

Overall Date Closed: 2013-07-09

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: American Gas Association

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2013-07-09

Addressee Acronym: AGA

Addressee Organization Type: A-Associations

Communication Date: 2012-03-26

Communication Type: Official Correspondence

Communication Contents: -From Dave McCurdy, President and CEO, American Gas Association and Donald F. Santa, Jr., President and CEO, Interstate Natural Gas Association of America: AGA and INGAA have included with this letter a report that addresses the NTSB recommendation. In creating this report, AGA and INGAA collaborated with the American Petroleum Institute, Association of Oil Pipelines, American Public Gas Association, and the key pipeline research and development organizations in the United States – NYSEARCH, Operations Technology Development, and Pipeline Research Council International. The Report to the National Transportation Safety Board on Historical and Future Developments of Advanced In-Line Inspection Platforms for Use in Gas Transmission Pipelines includes a history of in-line inspection (ILI) development and assessment technology, how ILI technology has been incorporated into the management of integrity of natural gas transmission pipelines, the current state of technology and projected timeframes for enhancement of existing technology and the development of new technology. The report also includes background information on natural gas transmission pipelines and the challenges of integrity management, an overview of integrity management and the role of integrity assessments, the configuration of transmission pipelines and their ability to utilize ILI devices, and future ILI R&D focus. While AGA and INGAA believe the attached report primarily covers NTSB recommendation P-11-32, we intend to provide additional supporting material within the next few months that will show our expectation of when advanced platforms will become available. We look forward to your feedback on the report and to answering any questions you may have.

Addressee Acronym: AGA

Addressee Organization Type: A-Associations

Communication Date: 2013-04-26

Communication Type: Official Correspondence

Communication Contents: -From Dave McCurdy, President and CEO, American Gas Association and from Donald F. Santa, Jr. President and CEO, Interstate Natural Gas Association of America: As a result of the investigation of the natural gas transmission pipeline accident in the town of San Bruno California, the National Transportation Safety Board (NTSB) issued a series of recommendations, one of which was directed to the American Gas Association (AGA) and the Interstate Natural Gas Association of America (INGAA). It stated: Report to the National Transportation Safety Board on your progress to develop and introduce advanced in-line inspection platforms for use in gas transmission pipelines not currently accessible to existing in-line inspection platforms, including a timeline for implementation of these advanced platforms." (P-11-32) (emphasis added.) AGA and INGAA agree that it is critical for the pipeline industry to learn from this tragic accident. We have, and will continue to, work to demonstrate this through our actions and ultimately the industry's safety performance. AGA and INGAA worked with other stakeholders and submitted to the NTSB a report entitled Report to the National Transportation Safety Board on Historical and Future Development of Advanced In-Line Inspection Platforms for Use in Gas Transmission Pipelines on March 26, 2012. The report described traditional and non-traditional in-line inspection (ILI) platforms, also referred to as "pigs," that are used to inspect gas transmission pipelines. Traditional ILI platforms use the flow of gas to provide the motive force to propel the tool through the pipeline. These are referred to as free-swimming tools. The report also described the circumstances that render a pipeline inaccessible (or "unpiggable") to the use of ILL A pipeline can be unpiggable due to its physical configuration or flow constraints and, in some instances, may be unpiggable due to both factors. Finally, the report included details on platforms and sensor technologies currently available as well as those under development, including a time line for such development. After reviewing the report, the NTSB responded with a correspondence dated June 20, 2012, stating that the response by AGA and INGAA concerning recommendation to P-11-32 had been classified Open-Acceptable Response. The NTSB requested that AGA and INGAA provide additional information about when advanced platforms were expected to be available. Research, development and commercialization of such platforms have continued at a rapid pace. The objective of this letter is to report on that progress and demonstrate that there is commitment and market demand for the commercialization of technology for unpiggable pipelines. Recognizing the urgency of the need to address unpiggable pipelines, organizations have commercialized technology solutions in two ways: 1. Fundamental research, development and demonstration; and 2. Technology transfer (from other industrial applications) Fundamental research, development and demonstration Some of the most noteworthy advances in technology solutions for unpiggable pipelines have been made by NYSEARCH, a research consortium of natural gas distribution companies focused on natural gas research, development, demonstration and commercialization. NYSEARCH, working with the Pipeline & Hazardous Materials Safety Administration (PHMSA), has mobilized research, development, demonstration and commercialization of robotic ILI platforms and sensors. Its work has resulted in commercially available tools that are offered by PipeTel Technologies in 6-to-26 inch tools. A second research consortium, Operations Technology Development (OTD), has advanced research to improve pipeline assessments. OTD is a not-for-profit research consortium made up of natural gas distribution operators that was formed to develop, test and implement new technologies. OTD is supporting technology transfer of inspection platforms from the offshore industry to on-shore unpiggable pipe. OTD is also developing a tethered magnetic flux leakage (MFL) tool to inspect short segments of un pig gable pipe such as casings and crossings and is partnering with others to develop an electromagnetic acoustic transducer (EMAT) sensor for unpiggable pipe. Equally noteworthy is a complementary program managed by the Pipeline Research Council International (PRCI). PRCI's programs are focused primarily on developing sensor technology and demonstrating sensor capabilities via extensive pull testing and other controlled studies using pipe removed from operating transmission systems. The premise of this approach is that platforms to carry these improved sensors will be developed concurrently by entities such as NYSEARCH and others described below. PRCI also is working to develop complete systems for new inspection technologies that can be used on difficult-to-inspect pipelines. These include an integrated cleaning and inspection tool (i.e., a tool that gathers data using sensors mounted on standard cleaning pigs) and a tethered inspection technology that uses an electromagnetic impedance technology (EMIT) sensor. Providers of traditional free-swimming ILI technologies have developed platforms for unpiggable pipelines in response to market demand for these tools and platforms. For example, Rosen, which has one of the largest fleets of free-swimming tools, has commercialized robotic platforms and now offers them in a variety of sizes. Rosen also has developed bi-directional tools with a selfadapting tractor drive and a high-resolution MFL inspection unit to enable operators to inspect short unpiggable segments. Technology transfer Transfer or adaptation oftechnology from other industrial applications has been essential to meet the growing needs for inspecting unpiggable natural gas transmission pipeline segments. One example is the transfer of technology from offshore applications. Oceaneering International, Inc. has brought forth robotic platforms, bi-directional tools and pump in-pump out tools in the range of 6-to-52 inches in diameter. A second example of technology transfer is from the nuclear and electric power generation industries, where inspection of piping and pressure vessels is often difficult. Diakont has adapted technology developed in these industries based on its identification of the need for pipeline tools. In 2012, Diakont began offering robotic platforms for 20-to-60 inch applications in North America. Progress on advanced in-line inspection platforms Attached to this letter are two tables that demonstrate the progress achieved in designing and manufacturing pipeline inspection platforms and the full breadth of technology that can be applied to natural gas transmission pipelines that cannot accommodate traditional free-swimming ILI tools. Table 1 shows the state of technology as of 2010, while Table 2 shows the current state of technology and the vast improvement that has been made in just three years in the development and availability of non-piggable platforms. While manufacturers have the ability to build devices for the pipeline sizes listed on the table, they will build only the size and number required by the market. The service providers are listed in the first column and the platform options are organized into technology groups of platform designs in the columns that follow. The last columns list the kinds of sensors that can be mounted on these platforms. Green indicates that particular sensors can be mounted on these platforms. Yellow indicates that the technology is very close to market. Red indicates that a sensor is not available. The number of red fields reflects the fact that certain technologies (e.g., Remote Field Eddy Current) either are intended for very specific, focused applications or are tailored to the physics of the particular sensing system and other factors. As research has progressed and technologies have entered the market, there hav

Addressee Acronym: AGA

Addressee Organization Type: A-Associations

Communication Date: 2012-06-19

Communication Type: Official Correspondence

Communication Contents: The NTSB is encouraged that AGA and INGAA collaborated with the American Petroleum Institute, Association of Oil Pipelines, American Public Gas Association, and the key pipeline research and development organizations in the United States (NYSEARCH, Operations Technology Development, and Pipeline Research Council International) in producing the AGA and INGAA Report to the National Transportation Safety Board on Historical and Future Developments of Advanced In-Line Inspection Platforms for Use in Gas Transmission Pipelines. This document includes the following: • An overview of natural gas transmission pipelines and their operation • A history of in-line inspection (ILI) development and assessment technology • An overview of the integrity management (IM) of natural gas transmission pipelines and the role of integrity assessments • The challenges of IM and ways in which ILI technology has been incorporated into IM • The current state of technology • Projected timeframes for the enhancement of existing technology and the development of new technology • The future expectations of ILI research and development The NTSB understands that AGA and INGAA will be providing additional information within the next few months regarding when advanced platforms are expected to become available. Accordingly, pending receipt of this additional information, Safety Recommendation P-11-32 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: AGA

Addressee Organization Type: A-Associations

Communication Date: 2013-07-09

Communication Type: Official Correspondence

Communication Contents: We are pleased with your associations’ collaboration with industry associations and key pipeline research and development organizations in the United States to produce your Report to the National Transportation Safety Board on Historical and Future Developments of Advanced In-Line Inspection Platforms for Use in Gas Transmission Pipelines. We are also pleased with the conferences, workshops, and webinars sponsored by the AGA, INGAA, and your partner organizations; your plans to work with these organizations to better identify industry needs and technology options available for operators; and your plans to continue to provide opportunities for operators to learn about advances in, and commercialization of, new inspection technologies. We understand that advanced platforms are currently available and that the pipeline industry, its research partners, and its contractors will continue to support technology advances in traditional in-line inspection pigs and technologies that will make currently unpiggable pipeline segments piggable. The actions taken and planned by the AGA and INGAA fully satisfy Safety Recommendation P-11-32; accordingly, the recommendation is classified CLOSED—ACCEPTABLE ACTION. Thank you for your cooperation and commitment to pipeline safety.

Addressee Name: Interstate Natural Gas Association of America

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2013-07-09

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2012-03-26

Communication Type: Official Correspondence

Communication Contents: -From Dave McCurdy, President and CEO, American Gas Association and Donald F. Santa, Jr., President and CEO, Interstate Natural Gas Association of America: AGA and INGAA have included with this letter a report that addresses the NTSB recommendation. In creating this report, AGA and INGAA collaborated with the American Petroleum Institute, Association of Oil Pipelines, American Public Gas Association, and the key pipeline research and development organizations in the United States – NYSEARCH, Operations Technology Development, and Pipeline Research Council International. The Report to the National Transportation Safety Board on Historical and Future Developments of Advanced In-Line Inspection Platforms for Use in Gas Transmission Pipelines includes a history of in-line inspection (ILI) development and assessment technology, how ILI technology has been incorporated into the management of integrity of natural gas transmission pipelines, the current state of technology and projected timeframes for enhancement of existing technology and the development of new technology. The report also includes background information on natural gas transmission pipelines and the challenges of integrity management, an overview of integrity management and the role of integrity assessments, the configuration of transmission pipelines and their ability to utilize ILI devices, and future ILI R&D focus. While AGA and INGAA believe the attached report primarily covers NTSB recommendation P-11-32, we intend to provide additional supporting material within the next few months that will show our expectation of when advanced platforms will become available. We look forward to your feedback on the report and to answering any questions you may have.

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2013-04-26

Communication Type: Official Correspondence

Communication Contents: -From Dave McCurdy, President and CEO, American Gas Association and from Donald F. Santa, Jr. President and CEO, Interstate Natural Gas Association of America: As a result of the investigation of the natural gas transmission pipeline accident in the town of San Bruno California, the National Transportation Safety Board (NTSB) issued a series of recommendations, one of which was directed to the American Gas Association (AGA) and the Interstate Natural Gas Association of America (INGAA). It stated: Report to the National Transportation Safety Board on your progress to develop and introduce advanced in-line inspection platforms for use in gas transmission pipelines not currently accessible to existing in-line inspection platforms, including a timeline for implementation of these advanced platforms." (P-11-32) (emphasis added.) AGA and INGAA agree that it is critical for the pipeline industry to learn from this tragic accident. We have, and will continue to, work to demonstrate this through our actions and ultimately the industry's safety performance. AGA and INGAA worked with other stakeholders and submitted to the NTSB a report entitled Report to the National Transportation Safety Board on Historical and Future Development of Advanced In-Line Inspection Platforms for Use in Gas Transmission Pipelines on March 26, 2012. The report described traditional and non-traditional in-line inspection (ILI) platforms, also referred to as "pigs," that are used to inspect gas transmission pipelines. Traditional ILI platforms use the flow of gas to provide the motive force to propel the tool through the pipeline. These are referred to as free-swimming tools. The report also described the circumstances that render a pipeline inaccessible (or "unpiggable") to the use of ILL A pipeline can be unpiggable due to its physical configuration or flow constraints and, in some instances, may be unpiggable due to both factors. Finally, the report included details on platforms and sensor technologies currently available as well as those under development, including a time line for such development. After reviewing the report, the NTSB responded with a correspondence dated June 20, 2012, stating that the response by AGA and INGAA concerning recommendation to P-11-32 had been classified Open-Acceptable Response. The NTSB requested that AGA and INGAA provide additional information about when advanced platforms were expected to be available. Research, development and commercialization of such platforms have continued at a rapid pace. The objective of this letter is to report on that progress and demonstrate that there is commitment and market demand for the commercialization of technology for unpiggable pipelines. Recognizing the urgency of the need to address unpiggable pipelines, organizations have commercialized technology solutions in two ways: 1. Fundamental research, development and demonstration; and 2. Technology transfer (from other industrial applications) Fundamental research, development and demonstration Some of the most noteworthy advances in technology solutions for unpiggable pipelines have been made by NYSEARCH, a research consortium of natural gas distribution companies focused on natural gas research, development, demonstration and commercialization. NYSEARCH, working with the Pipeline & Hazardous Materials Safety Administration (PHMSA), has mobilized research, development, demonstration and commercialization of robotic ILI platforms and sensors. Its work has resulted in commercially available tools that are offered by PipeTel Technologies in 6-to-26 inch tools. A second research consortium, Operations Technology Development (OTD), has advanced research to improve pipeline assessments. OTD is a not-for-profit research consortium made up of natural gas distribution operators that was formed to develop, test and implement new technologies. OTD is supporting technology transfer of inspection platforms from the offshore industry to on-shore unpiggable pipe. OTD is also developing a tethered magnetic flux leakage (MFL) tool to inspect short segments of un pig gable pipe such as casings and crossings and is partnering with others to develop an electromagnetic acoustic transducer (EMAT) sensor for unpiggable pipe. Equally noteworthy is a complementary program managed by the Pipeline Research Council International (PRCI). PRCI's programs are focused primarily on developing sensor technology and demonstrating sensor capabilities via extensive pull testing and other controlled studies using pipe removed from operating transmission systems. The premise of this approach is that platforms to carry these improved sensors will be developed concurrently by entities such as NYSEARCH and others described below. PRCI also is working to develop complete systems for new inspection technologies that can be used on difficult-to-inspect pipelines. These include an integrated cleaning and inspection tool (i.e., a tool that gathers data using sensors mounted on standard cleaning pigs) and a tethered inspection technology that uses an electromagnetic impedance technology (EMIT) sensor. Providers of traditional free-swimming ILI technologies have developed platforms for unpiggable pipelines in response to market demand for these tools and platforms. For example, Rosen, which has one of the largest fleets of free-swimming tools, has commercialized robotic platforms and now offers them in a variety of sizes. Rosen also has developed bi-directional tools with a selfadapting tractor drive and a high-resolution MFL inspection unit to enable operators to inspect short unpiggable segments. Technology transfer Transfer or adaptation oftechnology from other industrial applications has been essential to meet the growing needs for inspecting unpiggable natural gas transmission pipeline segments. One example is the transfer of technology from offshore applications. Oceaneering International, Inc. has brought forth robotic platforms, bi-directional tools and pump in-pump out tools in the range of 6-to-52 inches in diameter. A second example of technology transfer is from the nuclear and electric power generation industries, where inspection of piping and pressure vessels is often difficult. Diakont has adapted technology developed in these industries based on its identification of the need for pipeline tools. In 2012, Diakont began offering robotic platforms for 20-to-60 inch applications in North America. Progress on advanced in-line inspection platforms Attached to this letter are two tables that demonstrate the progress achieved in designing and manufacturing pipeline inspection platforms and the full breadth of technology that can be applied to natural gas transmission pipelines that cannot accommodate traditional free-swimming ILI tools. Table 1 shows the state of technology as of 2010, while Table 2 shows the current state of technology and the vast improvement that has been made in just three years in the development and availability of non-piggable platforms. While manufacturers have the ability to build devices for the pipeline sizes listed on the table, they will build only the size and number required by the market. The service providers are listed in the first column and the platform options are organized into technology groups of platform designs in the columns that follow. The last columns list the kinds of sensors that can be mounted on these platforms. Green indicates that particular sensors can be mounted on these platforms. Yellow indicates that the technology is very close to market. Red indicates that a sensor is not available. The number of red fields reflects the fact that certain technologies (e.g., Remote Field Eddy Current) either are intended for very specific, focused applications or are tailored to the physics of the particular sensing system and other factors. As research has progressed and technologies have entered the market, there hav

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2012-05-21

Communication Type: Official Correspondence

Communication Contents: Correspondence control #201200177 was closed administratively. No response was sent using correspondence control #201200177. This correspondence control was combined with correspondence control #201200167. The response will be sent to the American Gas Association and the Interstate Natural Gas Association of America using correspondence control #201200167.

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2012-06-19

Communication Type: Official Correspondence

Communication Contents: The NTSB is encouraged that INGAA and the AGA collaborated with the American Petroleum Institute, Association of Oil Pipelines, American Public Gas Association, and the key pipeline research and development organizations in the United States (NYSEARCH, Operations Technology Development, and Pipeline Research Council International) in producing the AGA and INGAA Report to the National Transportation Safety Board on Historical and Future Developments of Advanced In-Line Inspection Platforms for Use in Gas Transmission Pipelines (the Report). This document includes the following: • An overview of natural gas transmission pipelines and their operation • A history of in-line inspection (ILI) development and assessment technology • An overview of the integrity management (IM) of natural gas transmission pipelines and the role of integrity assessments • The challenges of IM and ways in which ILI technology has been incorporated into IM • The current state of technology • Projected timeframes for the enhancement of existing technology and the development of new technology • The future expectations of ILI research and development The NTSB understands that INGAA and the AGA will be providing additional information within the next few months regarding when advanced platforms are expected to become available. Accordingly, pending receipt of this additional information, Safety Recommendation P-11-32 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2013-07-09

Communication Type: Official Correspondence

Communication Contents: We are pleased with your associations’ collaboration with industry associations and key pipeline research and development organizations in the United States to produce your Report to the National Transportation Safety Board on Historical and Future Developments of Advanced In-Line Inspection Platforms for Use in Gas Transmission Pipelines. We are also pleased with the conferences, workshops, and webinars sponsored by the AGA, INGAA, and your partner organizations; your plans to work with these organizations to better identify industry needs and technology options available for operators; and your plans to continue to provide opportunities for operators to learn about advances in, and commercialization of, new inspection technologies. We understand that advanced platforms are currently available and that the pipeline industry, its research partners, and its contractors will continue to support technology advances in traditional in-line inspection pigs and technologies that will make currently unpiggable pipeline segments piggable. The actions taken and planned by the AGA and INGAA fully satisfy Safety Recommendation P-11-32; accordingly, the recommendation is classified CLOSED—ACCEPTABLE ACTION. Thank you for your cooperation and commitment to pipeline safety.