NTSB Safety Recommendation P-14-001

NTSB safety recommendation P-14-001.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Revise Title 49 Code of Federal Regulations Section 903, Subpart O, Gas Transmission Pipeline Integrity Management, to add principal arterial roadways including interstates, other freeways and expressways, and other principal arterial roadways as defined in the Federal Highway Administration’s Highway Functional Classification Concepts, Criteria and Procedures to the list of “identified sites” that establish a high consequence area.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2014-03-05

Adopted Date: 2014-02-19

Overall Date Closed: 2020-01-23

Synopsis: On December 11, 2012, at 12:41 p.m. eastern standard time, a buried 20-inch-diameter interstate natural gas transmission pipeline, owned and operated by Columbia Gas Transmission Corporation, ruptured in a sparsely populated area, about 106 feet west of Interstate 77 near Route 21 and Derricks Creek Road, in Sissonville, West Virginia. About 20 feet of pipe was separated and ejected from the underground pipeline and landed more than 40 feet from its original location. The escaping high-pressure natural gas ignited immediately. An area of fire damage about 820 feet wide extended nearly 1,100 feet along the pipeline right-of-way. Three houses were destroyed by the fire, and several other houses were damaged. There were no fatalities or serious injuries. About 76 million standard cubic feet of natural gas was released and burned. Columbia Gas Transmission Corporation reported the cost of pipeline repair was $2.9 million, the cost of system upgrades to accommodate in-line inspection was $5.5 million, and the cost of gas loss was $285,000. Major safety issues identified in this investigation were external corrosion mitigation of the ruptured pipeline, supervisory control and data acquisition alert setpoint configuration, use of automatic shutoff valves and remote control valves to improve isolation of high-pressure pipelines, and exclusion of pipelines in the vicinity of highways from integrity management regulation. The National Transportation Safety Board makes safety recommendations to Columbia Gas Transmission Corporation and the Pipeline and Hazardous Materials Safety Administration.

Ntsbnumber: DCA13MP003

Report Number: PAR-14-01

Addressee Name: PHMSA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2020-01-23

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 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). This topic area also discusses an alternate approach PHMSA proposes to address the NTSB Safety Recommendation P-14-1, which was issued as a result of the December 11, 2012, Sissonville, West Virginia, pipeline rupture. NTSB Safety Recommendation P-14-1 reads as follows: Revise Title 49 Code of Federal Regulations Section 903, Subpart O, Gas Transmission Pipeline Integrity Management, to add principal arterial roadways including interstates, other freeways and expressways, and other principal arterial roadways as defined in the Federal Highway Administration’s Highway Functional Classification Concepts, Criteria and Procedures to the list of “identified sites” that establish a high consequence area. (P-14-1) In the MCA definition, PHMSA proposes interstate highways, freeways and expressways, and other principal four-lane arterial roadways located within the potential impact radius would be designated as MCA, rather than as HCA, which was recommended by the NTSB. Further, PHMSA proposes to apply only three IM program elements (assessment, periodic reassessment, and remediation of discovered defects), rather than the entire list of IM program elements required for pipelines located in an HCA. In this NPRM, PHMSA states, “There would be additional significant costs to apply all other integrity management program elements (most notably the risk analysis and preventive/mitigative measures program elements) to additional segments currently not designated as HCA.” Response In 2002, PHMSA promulgated regulations defining an HCA, requiring the pipeline operators to “determine likely threats to the pipeline within the HCA, evaluating the physical integrity of the pipe within the HCA, and repairing or remediating any pipeline defects found.” The intent of these regulations is to improve pipeline integrity, thus reducing the likelihood of a catastrophic failure in or adjacent to areas where larger numbers of people might live or congregate. The December, 11, 2012, Sissonville, West Virginia, natural gas pipeline rupture resulted in an intense and prolonged fire burning directly across the interstate highway. In our report, we stated, “had the accident occurred during commuting hours, when traffic would have been significant, severe or fatal injuries could have occurred.” The resulting NTSB Safety Recommendation P-14-1 is intended to include within the scope of an HCA those highways where heavy traffic routinely occurs. This inclusion of highways would require the pipeline operator to augment its IM practices on the affected pipeline, thus “affording [those using the highway] extra safety protections.” The PHMSA proposal to create an MCA category and include a highway size threshold in the definition of an MCA accomplishes part of what the NTSB intended in Safety Recommendation P-14-1. However, we disagree with the PHMSA proposal to limit the highway coverage to only four-lane configurations. The proposed language would exclude the category of other principal arterial roadways wider than four lanes when, in fact, the wider roadways clearly should be included. Although most wider divided highways are likely coincident with the existing HCA criteria, there could be some that are not. We urge PHMSA to ensure that the wider arterial roadways are included in the MCA scope. The NTSB notes that the PHMSA proposal to include certain highways in the new proposed MCA category does not accomplish the same level of protection as was intended in Safety Recommendation P-14-1 because PHMSA proposes to limit the IM program requirements to only three IM elements. The safety recommendation intended that pipeline segments in the vicinity of such items should be subject to all IM program elements, as are required for pipeline segments in an HCA. We urge PHMSA to reconsider its decision to place such highways in the proposed MCA category having an abbreviated IM program, and instead, classify these highways as HCAs that require a comprehensive IM program, as the NTSB recommendation intended.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: On June 6, 2016, we commented on your NPRM, “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines,” which discusses an alternate approach to address P-14-1, whereby you propose creating a “moderate consequence area (MCA)” category that includes a highway size threshold. We continue to disagree with the proposal to limit highway coverage to only four-lane configurations because doing so would exclude other principal arterial roadways wider than four lanes. Although most wider divided highways likely coincide with the existing HCA criteria, some may not. We urge you to ensure that the wider arterial roadways are included in the MCA scope, and pending resolution of this issue in the final rule, Safety Recommendation P-14-1 is classified OPEN—UNACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-01-23

Communication Type: Official Correspondence

Communication Contents: We note that, on April 8, 2016, you published an NPRM, “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines,” known as the “Gas Rule,” which proposed an alternate approach to addressing Safety Recommendation P-14-1 by creating a moderate-consequence area (MCA) category that included a highway-size threshold. In our June 6, 2016, comments on this NPRM, we disagreed with your proposal because it limited highway coverage to only four lane configurations, which would exclude principal arterial roadways wider than four lanes. Although many wider divided highways may coincide with the existing HCA criteria, we were concerned that some wider highways may not. In our December 5, 2016, letter about this recommendation, we urged you to ensure that the wider arterial roadways were included in the MCA scope, and, pending resolution of this issue in the final rule, we classified the recommendation “Open—Unacceptable Response.” On October 1, 2019, you published a new rule, “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines,” which revises the definition of an MCA to include locations where interstate highways, freeways, expressways, and other principal four- or more-lane arterial roadways are located within the potential impact radius. This revision meets the intent of Safety Recommendation P-14-1, which is classified CLOSED--ACCEPTABLE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: On April 8, 2016, you published an NPRM, “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines,” which proposed an alternate approach to addressing Safety Recommendation P-14-1 by creating a “moderate consequence area (MCA)” category that included a highway-size threshold. In our June 6, 2016, comments on this NPRM, we said that we disagreed with this proposal because it limited highway coverage to only four-lane configurations, which would exclude principal arterial roadways wider than four lanes. Although most wider divided highways likely coincide with the existing HCA criteria, we were concerned that some wider highways may not. In our December 5, 2016, letter about this recommendation, we urged you to ensure that the wider arterial roadways were included in the MCA scope, and pending resolution of this issue in the final rule, we classified the recommendation “Open—Unacceptable Response.” We note that you are considering revising the definition in the final rule to more closely align with Safety Recommendation P-14-1, and you requested that we classify the recommendation “Open—Acceptable Response.” We further note that, although you originally expected to issue the final rule during 2017, issuance has been delayed because of several meetings on the rule that you held with your Gas Pipeline Advisory Committee as well as by the ongoing regulatory review required by the executive order. Although we are pleased that you are considering revising the final rule to address our concern, it is premature to change the classification of the recommendation until you either issue a final rule with the revision or publish a supplemental NPRM containing the revision. Pending issuance of a final rule that includes highways that are four lanes or wider as “identified sites” for HCAs or MCAs, Safety Recommendation P-14-1 remains classified OPEN--UNACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2015-04-08

Communication Type: Official Correspondence

Communication Contents: We note that, to address Safety Recommendation P 14-1, you have drafted an NPRM titled Safety of Gas Transmission and Gathering Pipelines, which you expect to publish later this year. Pending timely completion of the recommended action, the recommendation is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2014-07-29

Communication Type: Official Correspondence

Communication Contents: We note that you have drafted a notice of proposed rulemaking, titled Safety of Gas Transmission and Gathering Pipelines (Regulatory Identification Number 2137-AE72), which addresses several congressional mandates and several of our open recommendations, including Safety Recommendation P-14-1. Accordingly, this recommendation is classified OPEN—ACCEPTABLE RESPONSE, pending issuance of a final rule that also satisfies the recommendation.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2019-12-03

Communication Type: Official Correspondence

Communication Contents: -From Howard R. Elliott, Administrator: PHMSA proposes closure of this recommendation. On October 1, 2019, PHMSA published the "Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments" final rule. Section 192.3 of the final rule defines a "moderate consequence area" as an onshore area that is within a potential impact circle that contains any portion of the paved surface, including shoulders, of a designated interstate, other freeway, or expressway, as well as any other principal arterial roadway with 4 or more lanes, as defined in the Federal Highway Administration's "Highway Functional Classification Concepts, Criteria and Procedures."

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2019-04-01

Communication Type: Official Correspondence

Communication Contents: -From Howard R. Elliott, Administrator: PHMSA understands that the NTSB will continue to classify this recommendation as "Open-Unacceptable Response" until after its review of the associated rulemaking efforts. PHMSA is working to publish a final rule that will satisfy the intent of this recommendation. As discussed in our response to Recommendation P-11-14, PHMSA separated the Gas Rule into three rulemaking actions. PHMSA plans to address this recommendation in the "Pipeline Safety: Safety of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments" final rule, which is expected to be published in August 2019, according to the DOT's March 2019 Significant Rulemakings Report.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2017-11-13

Communication Type: Official Correspondence

Communication Contents: -From Howard R. Elliott, Administrator: PHMSA requests a status of" Open-Acceptable Response." PHMSA notes that the NTSB disagrees with PHMSA's proposal to limit highway coverage to only four lane configurations. PHMSA is considering revising the definition to more closely align with the NTSB' s recommendation. Aspects of this recommendation were proposed in PHMSA's NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines" (81 FR 20721), published on April 8, 2016 (https://www.federalregister.gov I documents/2016/04/08/2016-063 82/pipeline-safetysafety-of-gas-transmission-and-gathering-pipelines). PHMSA held Gas Pipeline Advisory Committee (GPAC) meetings on the rule on January 12, 2017, and on June 6-7, 2017. PHMSA plans to hold additional meetings in December 2017 to continue discussing the proposed rule. The final rule was initially expected to publish by the end of 2017. Due to the continued process of gathering GPAC recommendations, we are expecting delays and currently assessing impacts. Like many other issues before us, this is part of an ongoing regulatory review pursuant to the executive order issued by the President.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2014-05-29

Communication Type: Official Correspondence

Communication Contents: -From Cynthia L. Quarterman, Administrator: The PHMSA has submitted to the Office of the Secretary of Transportation a draft of a Notice of Proposed Rulemaking (NPRM) titled "Safety of Gas Transmission and Gathering Pipelines," regulatory identification number 213 7 -AE72, that will address several congressional mandates and NTSB recommendations, including P-14-1. Since the rulemaking has been designated as a significant rule, it will also be submitted for review to the Office of Management and Budget. Once the NPRM is published and the comment period expires, PHMSA will assess the comments and begin developing the final rule following which, a timeline will be established and added to the unified agenda that is available online at www.reginfo.gov.

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: Aspects of this recommendation will be addressed in PHMSA' s NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines." The NPRM is currently under agency review, and we expect to publish it in 2015. PHMSA's initial response to NTSB on this recommendation was completed on May 29, 2014.

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: Aspects of this recommendation were proposed in PHMSA 's NPRM titled ''Pipeline Safety: Safety of Gas Transmission Pipelines," published on April 8, 2016. The comment period closed on July 7, 2016. Specifically, PHMSA proposed to incorporate designated interstates, freeways, expressways, and other principal 4-lane arterial roadways within the new definition of "moderate consequence areas."

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence