NTSB Safety Recommendation P-12-018

NTSB safety recommendation P-12-018.

TO THE PIPELINE RESEARCH COUNCIL INTERNATIONAL: Conduct a review of various in-line inspection tools and technologies--including, but not limited to, tool tolerance, the probability of detection, and the probability of identification--and provide a model with detailed step-by-step procedures to pipeline operators for evaluating the effect of interacting corrosion and crack threats on the integrity of pipelines.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2012-07-25

Adopted Date: 2012-07-10

Overall Date Closed: 2018-01-19

Synopsis: On Sunday, July 25, 2010, about 5:58 p.m., eastern daylight time, a segment of a 30-inch-diameter pipeline (Line 6B), owned and operated by Enbridge Incorporated (Enbridge) ruptured in a wetland in Marshall, Michigan. The rupture occurred during the last stages of a planned shutdown and was not discovered or addressed for 17 hours. During the time lapse, Enbridge twice pumped additional oil (81 percent of the total release) into Line 6B during two startups; the total release was estimated to be 843,444 gallons of crude oil. The oil saturated the surrounding wetlands and flowed into the Talmadge Creek and the Kalamazoo River. Local residents self-evacuated from their houses, and the environment was negatively affected. Cleanup efforts continue as of the adoption date of this report, with continuing costs exceeding $767 million. About 320 people reported symptoms consistent with benzene exposure. No fatalities were reported.

Probable Cause: The National Transportation Safety Board (NTSB) determines that the probable cause of the pipeline rupture was corrosion fatigue cracks that grew and coalesced from crack and corrosion defects under disbonded polyethylene tape coating, producing a substantial crude oil release that went undetected by the control center for over 17 hours. The rupture and prolonged release were made possible by pervasive organizational failures at Enbridge Incorporated (Enbridge) that included the following: Deficient integrity management procedures, which allowed well-documented crack defects in corroded areas to propagate until the pipeline failed. Inadequate training of control center personnel, which allowed the rupture to remain undetected for 17 hours and through two startups of the pipeline. Insufficient public awareness and education, which allowed the release to continue for nearly 14 hours after the first notification of an odor to local emergency response agencies. Contributing to the accident was the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) weak regulation for assessing and repairing crack indications, as well as PHMSA’s ineffective oversight of pipeline integrity management programs, control center procedures, and public awareness. Contributing to the severity of the environmental consequences were (1) Enbridge’s failure to identify and ensure the availability of well-trained emergency responders with sufficient response resources, (2) PHMSA’s lack of regulatory guidance for pipeline facility response planning, and (3) PHMSA’s limited oversight of pipeline emergency preparedness that led to the approval of a deficient facility response plan.

Ntsbnumber: DCA10MP007

Report Number: PAR-12-01

Addressee Name: Pipeline Research Council International

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2018-01-19

Addressee Acronym: PRCI

Addressee Organization Type: A-Associations

Communication Date: 2017-10-04

Communication Type: Official Correspondence

Communication Contents: -From Clifford M. Johnson, President: As was noted in our prior correspondence to address the recommendation, PRCI undertook two critical research projects that have been completed. The first project was to establish an industry-wide database to serve as a compendium of industry crack management experience, enabling researchers to examine many facets of inspection tools and technologies, including the ability to detect and measure interacting corrosion and crack threats. The framework developed is the model for information sharing and industry learnings as we continue to work to enhance the key ILI and NDE technologies and processes to ensure pipeline safety and integrity. The second project was to construct a state of the art pull test facility to enable various on-site testing that will provide further examination of tools and technologies. The opportunity to validate tools and process against their stated capabilities is key part of the process of continuous improvement. These two efforts will be a cornerstone for tool and process assessment, development, and enhancement. Industry Data-Mining A great source of data and information exists in our industry and this project established the technical means and the collaborative forum for coordinating the collation and assessment of the information. The primary objective of the first report generated by this compendium was to conduct a reliability analysis of crack in-line inspection (ILI) technology. The report, “In-Line Inspection Crack Tool Performance Evaluation” (NDE-4E, Catalog No. PR-244-133731-R01). This report discusses the findings of a detailed analysis and evaluation of the performance capabilities of various in-line inspection (ILI) technologies for managing pipeline cracking threats, including crack colonies, isolated cracks and cracks in pipe seam welds. The foundation for the study was the development of an extensive database of crack inspection data collected from pipeline operators through an industry data mining exercise. Equally important, the project established a framework for coordinating industry participation and overcame the administrative challenges associated with large, broad data sharing exercises. The study resulted in the collection and analysis of over 50,000 crack features that were identified through crack detection ILI technologies and then compared against in the ditch non-destructive examination (NDE) results. The data were analyzed using a number of approaches and techniques to establish the current performance specifications for crack ILI tools and to enable operators to understand the bandwidth of precision under a variety of operational circumstances. The probability of detection (POD), probability of identification (POI) and, probability of sizing (POS) were all quantified relative to various technologies. Specifically, the key results are summarized as follows: • The database architecture and storage design are robust and user-friendly. The data structure has the ability to serve in the analysis of all types of ILI instruments and can also serve to evaluate field NDE. • While several crack ILI technologies were examined, Ultrasonic (UT) crack ILI tools were the primary source of data for this inaugural study. There was sufficient data gathered regarding UT to enable a statistically relevant reliability analysis (related to POD, POI POS). It is for the operator now to interpret the results for applicability for their operations. • The reliability analysis showed that POD was strong in most of the circumstances evaluated. It was also shown that ILI to field sizing correlations were best conducted using failure strength calculations as compared to depth readings alone. The study represents the first known exercise to establish an industry-wide database for ILI technologies and has set a new standard for data mining as a basis for establishing ILI performance metrics. This important first use of the data collation successfully accomplished three key outcomes. First, a framework for industry data mining was created. This framework will enable ongoing data sharing and hence a very powerful mechanism for examining many other technologies. Second, the first project is arguably the most comprehensive, and updated review of crack ILI performance. Third, the study set the roadmap for the next projects including additional examination of crack ILI, in the ditch non-destructive testing (NDE), and the accuracy of pipe strength formulae, all highly important areas for advancement. The data mining exercise has provided, as far as we are aware, the most advanced industry analysis of crack ILI. And, the work has established the means for industry collaboration on all other ILI technologies. The resulting database and data mining is now being used to assess other threats and examine other evaluation tools. PRCI has committed to establish the industry database for this effort and to enable future development and enhancement of our current and future tools and process for ILI and NDE. PRCI encourages the NTSB to support the establishment of this industry database. This tool addresses some of the questions in the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016. It provides the forum and architecture needed to enabling an industry sharing effort. PRCI Technology Development Center The second project that we undertook was to construct a state of the art pull test facility. The concept was to construct a site that will enable the pipeline industry and the ILI vendors to validate and enhance the capabilities of the ILI tools. This project was co-funded by the Pipeline and Hazardous Materials Safety Administration (PHMSA). As a complement to the data mining project described above which is focused on actual in-service conditions, this effort provides researchers an opportunity to compare the ILI tools in a “bench scale” environment to provide an additional approach to technology analysis. The pull test facility is housed at the PRCI Technology Development Center (TDC). The TDC sits on 8.5 acres and also houses 1500 pipe samples with real world defects from our members from around the world and 30,000 sq. ft. workshop, training, and office space. The site will be a key piece of the future of PRCI and for setting the direction of pipeline research. The facility has three pull lines (24, 16, and 12 inch) with lengths up to 500 feet and this allows the tools to reach field speeds. We have completed the research and the report is attached for your reference (“Development of an Industry Test Facility and Qualification Process for ILI Technology”). We have recently added to parallel flow loops to the assets on campus. These new items will enable testing development for tools to address difficult to inspect pipelines and to leak detection. This is an ever evolving site and the potential benefits to the industry, government, and the public is unlimited. The TDC is the result of a major commitment by the energy pipeline industry to address the key issues that it is facing to ensure the safety and integrity of the vital national and international pipeline infrastructure. Much like the development of the industry data mining framework, the pull test facility will draw together a coordinated international approach for advancing technology and will be in support of the NTSB Recommendation. Summary The projects described are novel and have provided significant advancement on the understanding of ILI technologies. Importantly, the projects lay the groundwork for a focused approach on additional scope in this area. PRCI has produced a number of prior ILI related research results and a variety of current secondary projects (ie. sensor technologies) are presently occurring and will contribute to fundamental ILI advancement. The efforts noted above have strongly aligned with the

Addressee Acronym: PRCI

Addressee Organization Type: A-Associations

Communication Date: 2012-10-24

Communication Type: Official Correspondence

Communication Contents: -From Cliff Johnson, President: Pipeline Research Council International, Inc. (PRCI) has completed its review of the July 25, 2012, letter from the National Transportation Safety Board (NTSB) that includes recommendations for pipeline research on two separate topics. The recommendations are part of NTSB's study of the July 2010 pipeline failure that occurred in Marshall, Michigan, PRCI has prepared this response to address the items raised in the NTSB letter and to request a meeting with NTSB to more fully review, discuss, and understand the recommendations directed to PRCI. For convenience and ease of reference, the specific recommendations presented by NTSB are as follows: 1) Conduct a review of various in-line inspection tools and technologies-including, but not limited to, tool tolerance, the probability of detection, and the probability of identification; and 2) Provide a model with detailed step-by-step procedures to pipeline operators for evaluating the effect of interacting corrosion and crack threats on the integrity of pipelines. PRCI has a broad research and development program with a significant portion of that program focused on inspection technologies for pipelines and related systems, including inline inspection (ILl) technology and other methods of non-destructive examination (NDE) and inspection. The energy pipeline industry has previously acknowledged the need for further understanding and improved technology relative to NTSB recommendation Number 1) above and has commissioned research projects through PRCI. The deliverables will provide data and information to the industry on technology performance relative to the detection, identification, and assessment of features, flaws, anomalies, and defects that affect pipeline integrity. A summary of PRCI's programs and several key research projects being conducted that address inspection technology development is provided in Appendix A to this letter. Relative to recommendation Number 2) above, PRCI (and other industry stakeholders) routinely reviews incident data and conducts root cause analysis of transmission pipeline failures, including the interaction of threats that lead to failures. These reviews are performed to determine where research may be needed to continually reduced the number of incidents and further improve pipeline safety. Based on these reviews, PRCI has identified interacting threats as an area requiring research and has allocated funding to support several research projects to evaluate interacting threats, including the interaction of secondary features with mechanical damage, the interactions between seam welds and corrosion (i.e., selective seam corrosion), and the interaction of girth weld flaws and strains induced by ground movement. Other research organizations are also addressing interacting threats through related projects, including the European Pipeline Research Group (EPRG) and Operations Technology Development (OTD). However, prior to the Marshall, MI incident, review of the existing databases showed no substantial record where the cause of a failure was related to the interaction of corrosion and cracking. With the recent findings of the NTSB study on the Marshall, MI incident, PRCI is re-evaluating the historical records on pipeline incidents and assessing the extent to which corrosion and cracking was a factor in those incidents and may require the level of focused attention and separate procedure as recommended in the NTSB's July 25 letter. PRCI will share the findings of this evaluation with the NTSB when completed. The recommendations issued to PRCI, while limited in number, are broad in their scope and reach across many aspects of the pipeline integrity process and PRCI's research programs. Considering the large volume of pipeline research that has been previously completed and currently underway and the breadth of the issues covered in the recommendations, PRCI is requesting a meeting with the NTSB Board to more fully understand the specific concerns with regard to the recommendations and to present the current body of knowledge associated with the recommendations. At the meeting, PRCI will present its current projects and programs that are addressing Recommendation P-12-18 and PRCI and NTSB representatives can speak directly on the findings from the investigation of the Marshall, MI incident and assess the additional research that may be appropriate to address some of the items identified through the investigation. PRCI will then be in a position to coordinate with our membership on identifying additional research that may be needed to address the gaps that exist, and best apply the resources and energies needed to address the recommendations. PRCI will contact you to discuss available dates for meeting with you and your staff at NTSB. PRCI is continuing to advance the development of improved methods, processes, and technologies for pipeline inspection to ensure reliable and safe delivery of energy products. We look forward to meeting with you and your staff to share information pertaining to our programs and our successes in support of our member companies and, more broadly, the entire energy pipeline industry. PRCI is a collaborative organization that manages the implementation of pipeline research and development projects and programs on behalf of its member companies and, more broadly, the energy pipeline industry. An overview of PRCI, including structure and organization, sources of funding for our research programs, and our membership base, is presented in the article PRCI in Brief, which is included as Attachment A.1. PRCI has an established and defined process for development and implementation of R&D projects that works on an annual cycle. This process is shown graphically in Figure A-I. The process includes the development of the technical program by a set of six (6) Technical Committees and approval of the research program through a ballot voting process where member companies allocate funds (i.e., vote) for the projects recommended by the Technical Committees that they support. Through this process, PRCI's membership has approved funding over the past five years amounting to over $8.5 million for R&D related to pipeline inspection technologies, including development, testing and qualification, validation, and deployment. The projects and programs being conducted range from developing new sensors and platforms for pipeline inspection to improving our understanding of existing technology capabilities and applications. PRCI is also studying new and innovative approaches to applying existing technologies to solve pipeline inspection challenges. A number of the recently completed and current funded research projects and programs directly address the NTSB recommendation. PRCI has a number of active projects that are focused on measuring and evaluating ILI technology performance relative to the parameters identified in the NTSB letter, such as Probability of detection (POD), Probability of Identification (POI), and probability of false call (POFC). Some of the current work being conducted includes the following: • Program on the Detection and Discrimination of Mechanical Damage (PRCI Program reference - MD-l) • ILI Characterization for External Corrosion (EC-4 Program) • Evaluation of inspection technology for longitudinal seams on ERW pipe and other long seam features (IM-3 Program) and girth weld inspection studies • Improving ILI technologies for characterizing cracks and crack colonies, including Electromagnetic Acoustic Technology (EMA T) and Ultrasonic Crack Detection (USCD) technology In addition to the evaluation and improvements to current technologies, PRCI is also sponsoring the development of new technologies for ILl inspection. The new developments include the following: • Support for the development of new ILI technologies for detecting and characterizing mechanical damage and secondary features

Addressee Acronym: PRCI

Addressee Organization Type: A-Associations

Communication Date: 2016-03-15

Communication Type: Official Correspondence

Communication Contents: -From Cliff Johnson, President: As a result of the investigation of the liquid pipeline accident in the wetland of Marshall, Michigan, the National Transportation Safety Board (NTSB) issued a series of recommendations, one of which was directed to the Pipeline Research Council International (PRCI). It stated the following: Conduct a review of various in-line inspection tools and technologies including, but not limited to, tool tolerance, the probability of detection, and the probability of identification - and provide a model with detailed step-by step procedures to pipeline operators for evaluating the effect of interacting corrosion and crack threats on the integrity of pipelines. To address the recommendation, PRCI undertook two critical research projects, to date, and further work is ongoing. The first project was to establish an industry-wide database to serve as a compendium of industry crack management experience, enabling researchers to examine many facets of inspection tools and technologies, including the ability to detect and measure interacting corrosion and crack threats. The second project was to construct a state of the art pull test facility to enable various on-site testing that will provide further examination of tools and technologies. Industry Data-Mining A great source of data and information exists in our industry and this project established the technical means and the collaborative forum for coordinating the collation and assessment of the information. The primary objective of the first report generated by this compendium was to conduct a reliability analysis of crack in-line inspection (ILI) technology. The report, "In-Line Inspection Crack Tool Performance Evaluation" (NDE-4E, Catalog No. PR-244-133731-R01) is attached to this letter for your reference. This report discusses the findings of a detailed analysis and evaluation of the performance capabilities of various in-line inspection (ILI) technologies for managing pipeline cracking threats, including crack colonies, isolated cracks and cracks in pipe seam welds. The foundation for the study was the development of an extensive database of crack inspection data collected from pipeline operators through an industry data mining exercise. Equally important, the project established a framework for coordinating industry participation and overcame the administrative challenges associated with large, broad data sharing exercises. The study resulted in the collection and analysis of over 50,000 crack features that were identified through crack detection ILI technologies and then compared against in the ditch non-destructive examination (NDE) results. The data were analyzed using a number of approaches and techniques to establish the current performance specifications for crack ILI tools and to enable operators to understand the bandwidth of precision under a variety of operational circumstances. The probability of detection (POD), probability of identification (POI) and, probability of sizing (POS) were all quantified relative to various technologies. Specifically, the key results are summarized as follows: • The database architecture and storage design are robust and user-friendly. The data structure has the ability to serve in the analysis of all types of ILI instruments and can also serve to evaluate field NDE. • While several crack ILI technologies were examined, Ultrasonic (UT) crack ILI tools were the primary source of data for this inaugural study. There was sufficient data gathered regarding UT to enable a statistically relevant reliability analysis (related to POD, POI POS). It is for the operator now to interpret the results for applicability for their operations. • The reliability analysis showed that POD was strong in most of the circumstances evaluated. It was also shown that ILI to field sizing correlations were best conducted using failure strength calculations as compared to depth readings alone. The study represents the first known exercise to establish an industry-wide database for ILI technologies and has set a new standard for data mining as a basis for establishing ILI performance metrics. This important first use of the data collation successfully accomplished three key outcomes. First, a framework for industry data mining was created. This framework will enable ongoing data sharing and hence a very powerful mechanism for examining many other technologies. Second, the first project is arguably the most comprehensive, and updated review of crack ILI performance. Third, the study set the roadmap for the next projects including additional examination of crack ILI, in the ditch non-destructive testing (NDE), and the accuracy of pipe strength formulae, all highly important areas for advancement. Already, next projects are stemming from this initiative and will delve more deeply into the following: • A user's manual that will streamline and simplify the highly technical reliability analysis results of the first study. • Additional data to further examine other types of crack inspection ILI including electromagnetic acoustic transducer (EMA T) and magnetic flux leakage (MFL). • UT data gathered under a wider array of operators' experiences including a wider range of pipe diameters, wall thicknesses, pipe manufacturers, etc. and, importantly, additional data where cracking has been found coincident to corrosion. • The effect of NDE methods, the effect of field data gathering protocols, and also the behavior of fitness-for-purpose formulae. The data mining exercise has provided, as far as we are aware, the most advanced industry analysis of crack ILI And, the work has established the means for industry collaboration on all other ILI technologies. PRCI Technology Development Center The second project that we undertook was to construct a state of the art pull test facility. The concept was to construct a site that will enable the pipeline industry and the ILI vendors to validate and enhance the capabilities of the ILI tools. This project was co-funded by the Pipeline and Hazardous Materials Safety Administration (PHMSA). As a complement to the data mining project described above which is focused on actual in-service conditions, this effort provides researchers an opportunity to compare the ILI tools in a "bench scale" environment to provide an additional approach to technology analysis. The pull test facility is housed at the PRCI Technology Development Center (TDC). The TDC sits on 8.5 acres and also houses 1500 pipe samples with real world defects from our members from around the world and 30,000 sq. ft. workshop, training, and office space. The site will be a key piece of the future of PRCI and for setting the direction of pipeline research. The facility has three pull lines (24, 16, and 12 inch) with lengths up to 500 feet and this allows the tools to reach field speeds. We are completing the first round of ILI tool testing at the site and are planning for a second run of the tools in Q2 2016. The results will be an additional component in support of the NTSB directive to PRCI and we will be sure to share the results with NTSB. The TDC is the result of a major commitment by the energy pipeline industry to address the key issues that it is facing to ensure the safety and integrity of the vital national and international pipeline infrastructure. Much like the development of the industry data mining framework, the pull test facility will draw together a coordinated international approach for advancing technology and will be in support of the NTSB Recommendation. Summary The projects described in this update are novel and have provided significant advancement on the understanding of ILI technologies. Importantly, the projects lay the groundwork for a focused approach on additional scope in this area. PRCI has produced a number of prior ILI related research results and a variety of current secondary projects (ie. s

Addressee Acronym: PRCI

Addressee Organization Type: A-Associations

Communication Date: 2017-04-07

Communication Type: Official Correspondence

Communication Contents: On March 15, 2016, you informed us that you had established an industrywide database to serve as a compendium of industry experience in managing cracks to enable researchers to examine many facets of inspection tools and technologies, including the ability to detect and measure interacting corrosion and crack threats. You also wrote that you had constructed a state-of-the-art pull-test facility to enable on-site tool and technology testing. We noted your efforts and your significant contribution to ILIs with the development of the In-line Inspection Crack Tool Performance Evaluation (NDE 4E), and your efforts with the American Petroleum Institute (API) to develop the much-needed recommended practices RP 1176, Assessment and Management of Pipeline Cracking. We further recognized that, because many API members are also PRCI members, you will be able to monitor API’s progress, ensure PRCI’s support, and, if needed, initiate additional actions to develop a model with detailed, step by-step procedures that pipeline operators will be able to use when evaluating the effect of interacting corrosion and crack threats. It was expected that the results of your efforts would immediately impact pipeline safety, and we were encouraged that they have already spawned plans for continued advancements. We further noted that you planned to use the Technology Development Center and the pull-test facility to engage the pipeline industry and ILI vendors to support the ongoing development of new tools and techniques. On May 16, 2016, pending completion of work that satisfies Safety Recommendation P 12-18, the recommendation was classified OPEN--ACCEPTABLE RESPONSE. It has been a year since your March 15, 2016, communication concerning P-12-18. We would appreciate receiving an update on the status of your recent actions concerning this recommendation. We are interested in knowing whether and how our recommendations are implemented, both to ensure the public the highest level of safety and to identify creative solutions that can be shared with others.

Addressee Acronym: PRCI

Addressee Organization Type: A-Associations

Communication Date: 2018-01-19

Communication Type: Official Correspondence

Communication Contents: We note that, to satisfy this recommendation, you have completed two research projects. First, you have established an industrywide database of crack management experience, enabling researchers to examine many facets of inspection tools and technologies, including the ability to detect and measure interacting corrosion and crack threats. Second, you have constructed a state-of-the-art pull test facility so tools and technologies can be tested onsite. We note that you used the database of industry crack management experience to conduct a reliability analysis of crack ILI technology, as described in your report, In-Line Inspection Crack Tool Performance Evaluation. This report discusses the performance capabilities of various ILI technologies to manage pipeline cracking threats. We note that you are currently using the database to assess other threats and examine other evaluation tools. We further note that the pull test facility you built at your Technology Development Center (TDC) is described in your report, Development of an Industry Test Facility and Qualification Process for ILI Technology. The facility enables the pipeline industry and ILI vendors to validate ILI tools and enhance their capabilities, providing an opportunity to compare ILI tools in a “bench scale” environment. The facility has three pull lines (24, 16, and 12 inch), with lengths up to 500 feet, which allows the tools to reach field speeds. Further, the TDC recently added the capability to test and develop tools to address difficult-to-inspect pipelines and leak detection. We are pleased by the development of the database and the testing and evaluation capabilities of your TDC. We believe these will be valuable tools for understanding safety issues associated with pipelines, and will be useful for mitigating those risks. These actions satisfy Safety Recommendation P-12-18, which is classified CLOSED--ACCEPTABLE ACTION.

Addressee Acronym: PRCI

Addressee Organization Type: A-Associations

Communication Date: 2012-12-18

Communication Type: Official Correspondence

Communication Contents: We note that PRCI believes Safety Recommendation P-12-18 to be very broad in scope and would therefore like to meet with NTSB staff to discuss this recommendation. To schedule such a meeting, please have a member of your staff contact Mr. Michael Brown, NTSB Safety Recommendations Specialist, at (202) 314-6174. Pending receipt of a substantive response from PRCI, Safety Recommendation P-12-18 remains classified OPEN—AWAIT RESPONSE.

Addressee Acronym: PRCI

Addressee Organization Type: A-Associations

Communication Date: 2015-06-11

Communication Type: Official Correspondence

Communication Contents: You informed us in your October 24, 2012, letter that you believed Safety Recommendation P-12-18 to be very broad in scope, and you asked to meet with NTSB staff to discuss the recommendation. On December 18, 2012, we provided staff contacts for scheduling such a meeting; however, we received no reply to our letter and, to date, no one has contacted NTSB staff to arrange the meeting you requested. Recipients of our safety recommendations usually complete actions to address them within 3 to 5 years, and this recommendation is nearly 3 years old with no progress being made on it so far as we know. We are interested in knowing whether and how our recommendations are implemented, both to ensure the public the highest level of safety and to identify creative solutions that can be shared with others. Because we have received no information regarding your actions to address Safety Recommendation P-12-18, we would appreciate receiving a prompt reply regarding your progress. Pending our timely receipt of a substantive response from you, Safety Recommendation P-12-18 remains classified OPEN—AWAIT RESPONSE. A copy of our July 25, 2012, letter issuing Safety Recommendation P-12-18; your October 24, 2012, response; and our December 18, 2012, reply are enclosed. The full report of our investigation of the July 25, 2010, pipeline accident at Marshall, Michigan, is available at http://www.ntsb.gov/investigations/AccidentReports/Pages/PAR1201.aspx.

Addressee Acronym: PRCI

Addressee Organization Type: A-Associations

Communication Date: 2016-05-16

Communication Type: Official Correspondence

Communication Contents: We note that, to address this issue, you (1) established an industry-wide database of industry crack management experience, enabling researchers to examine many facets of inspection tools and technologies, including the ability to detect and measure interacting corrosion and crack threats and (2) constructed a state-of-the-art pull test facility to enable various on-site testing of tools and technologies. We recognize your efforts and your significant contribution to ILI with the development of the In-line Inspection Crack Tool Performance Evaluation (NDE-4E), and your efforts with the American Petroleum Institute (API) to develop the much-needed recommended practices RP-1176, Assessment and Management of Pipeline Cracking. We also recognize that, because many API members are also PRCI members, you will be able to monitor API’s progress, ensure PRCI’s support and, if need be, initiate additional actions to develop a model with detailed, step-by-step procedures that pipeline operators will be able to use in evaluating the effect of interacting corrosion and crack threats. We recognize that your results will immediately impact pipeline safety, and we are encouraged that they have already spawned plans for continued advancements. We note that you plan to use the Technology Development Center (TDC) and the Pull-Test Facility to engage the pipeline industry and ILI vendors to support the ongoing development of new tools and techniques. We appreciate your commitment to communicate to us your continued progress in this effort. Pending completion of work that satisfies Safety Recommendation P 12-18, the recommendation is classified OPEN—ACCEPTABLE RESPONSE.