NTSB Safety Recommendation P-15-018

NTSB safety recommendation P-15-018.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Require that all natural gas transmission pipelines be capable of being in-line inspected by either reconfiguring the pipeline to accommodate in line inspection tools or by the use of new technology that permits the inspection of previously uninspectable pipelines; priority should be given to the highest risk transmission pipelines that considers age, internal pressure, pipe diameter, and class location. (Safety Recommendation P-15-018 superseded Safety Recommendation P-11-017)

Priority: CLASS II

Overall Status: Closed - Acceptable Alternate Action

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

Overall Date Closed: 2020-01-23

Synopsis: There are approximately 298,000 miles of onshore natural gas transmission pipelines in the United States. Since 2004, the operators of these pipelines have been required by the Pipeline and Hazardous Materials Safety Administration (PHMSA) to develop and implement integrity management (IM) programs to ensure the integrity of their pipelines in populated areas (defined as high consequence areas [HCAs]) to reduce the risk of injuries and property damage from pipeline failures. An operator’s IM program is a management system designed and implemented by pipeline operators to ensure their pipeline system is safe and reliable. An IM program consists of multiple components, including procedures and processes for identifying HCAs, determining 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. These procedures and processes are complex and interconnected. Effective implementation of an IM program relies on continual evaluation and data integration. The IM program is an ongoing program that is periodically inspected by PHMSA and/or state regulatory agencies to ensure compliance with regulatory requirements.

Ntsbnumber: DCA14SS002

Report Number: SS-15-01

Addressee Name: PHMSA

Addressee Status: Closed - Acceptable Alternate 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). PHMSA proposes to incorporate by reference the American Petroleum Institute In-line Inspection Systems Qualification Standard (API STD 1163); the National Association of Corrosion Engineers (NACE) In-line Inspection of Pipelines (SP0102-2010); and the American Society for Nondestructive Testing In-line Inspection Personnel Qualification and Certification (ANSI/ASNT ILI PQ 2010). These proposed actions address two recommendations from our January 27, 2015, study Integrity Management of Gas Transmission Pipelines in High Consequence Areas. The recommendations are as follows: Require that all natural gas transmission pipelines be capable of being in-line inspected by either reconfiguring the pipeline to accommodate in line inspection tools or by the use of new technology that permits the inspection of previously uninspectable pipelines; priority should be given to the highest risk transmission pipelines that considers age, internal pressure, pipe diameter, and class location. (Supersedes Safety Recommendation P-11-17, which is now classified “Closed?Superseded”) (P-15-18) Identify all operational complications that limit the use of in-line inspection tools in piggable pipelines, develop methods to eliminate the operational complications, and require operators to use these methods to increase the use of in-line inspection tools. (P-15-20) Response The NTSB understands that the PHMSA proposed actions are intended to address Safety Recommendations P-15-18 and P-15-20. It is not clear, however, if the proposed actions will require operators to modify previously uninspectable pipelines to accommodate ILI tools or alternatively, require operators to use new technologies to perform the inspections. Furthermore, it is not clear if PHMSA will establish any requirements to prioritize new ILIs based on pipeline age, operating pressure, or other relevant criteria. We urge PHMSA to ensure the regulations that result from this NPRM address all elements contained in Safety Recommendations P-15-18 and P-15-20.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: We note your contention that the NPRM, “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines,” published at the Federal Register on April 8, 2016, will enhance and expand the minimum requirements for the selection and use of integrity assessment methods. In so doing, you proposed that direct assessment be allowed only if the line cannot be inspected with internal tools and if it is impractical to assess it using other methods within the IM requirements. Further, you have proposed revised or new language in several areas of the NPRM to restrict the use of direct assessment as an integrity assessment method. On June 6, 2016, we submitted comments on the NPRM, as follows: The NTSB understands that the PHMSA proposed actions are intended to address Safety Recommendations P-15-18 and P-15-20. It is not clear, however, if the proposed actions will require operators to modify previously uninspectable pipelines to accommodate ILI tools or alternatively, require operators to use new technologies to perform the inspections. Furthermore, it is not clear if PHMSA will establish any requirements to prioritize new ILIs based on pipeline age, operating pressure, or other relevant criteria. We urge PHMSA to ensure the regulations that result from this NPRM address all elements contained in Safety Recommendations P-15-18 and P-15-20. We again urge you to ensure the regulations that result from this NPRM will address all elements contained in Safety Recommendations P-15-18 and P-15-20, as stated in our comments. Pending completion of these efforts, and with the understanding that they will lead to the eventual use of ILI tools on all gas transmission lines, Safety Recommendation P-15-18 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-01-23

Communication Type: Official Correspondence

Communication Contents: We note that you believe Safety Recommendation P-15-18 should be classified “Closed—Acceptable Action” because you already require all new or replaced gas transmission pipes to accommodate internal inspection devices, per 49 CFR 192.150. You also contend that the economic incentives for using ILI—which is considerably less expensive than other methods of inspection—will continue to facilitate its use for gas transmission lines that were in existence when 49 CFR 192.150 was adopted, and are therefore not required to be inspected using ILI techniques. Although we agree that current regulations require new or replaced gas transmission pipeline to be ILI capable, they do not address those pipelines that existed when the rule was enacted. As you point out in your April 1, 2019, letter, 25 percent of onshore gas transmission assessment miles are not currently inspectable by ILI methods. We note that you believe your IM regulations are a suitable alternative to address this recommendation because they establish and require assessment criteria based on pipeline risk. Under the current regulations, operators are required to prioritize repairs if they discover certain high-risk pipeline conditions in HCAs, which ensures they prioritize repairs to the highest-risk HCA gas transmission pipelines. You argue that this satisfies our recommendation to give priority to the highest-risk transmission pipelines considering age, internal pressure, pipe diameter, and class location. Further, although you do require new and replaced pipe to be ILI capable, you do not have the authority to require operators to replace non-ILI–compliant pipe. We agree that the economic incentives associated with current, and future, ILI techniques will continue to encourage operators to use ILI wherever possible, and we believe your actions represent a suitable alternative approach to satisfying this recommendation. Accordingly, Safety Recommendation P-15-18 is classified CLOSED--ACCEPTABLE ALTERNATE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: Your August 17, 2016, letter said this recommendation was addressed in your April 8, 2016, NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” which proposed that direct assessment be allowed only if the line cannot be inspected with ILI tools and if it is impractical to assess it using other methods within the IM requirements. The NPRM also proposed revised or new language to restrict the use of direct assessment as an integrity assessment method. In our June 6, 2016, comments on the NPRM, we said that, although the NPRM stated that the proposed actions were intended to address Safety Recommendations P-15-18 and P-15-20, it was unclear whether they would require operators to modify previously uninspectable pipelines to accommodate ILI tools or to use new technologies to perform the inspections. Furthermore, it was unclear if PHMSA would establish requirements to prioritize new ILIs based on pipeline age, operating pressure, or other relevant criteria. In our December 5, 2016, letter about these recommendations, we asked how you would ensure that the regulations resulting from the NPRM would address all the elements contained in Safety Recommendations P-15-18 and P-15-20, as stated in our comments. Your current letter addresses our concerns. With regard to the first part of Safety Recommendation P-15-18 (that all natural gas transmission pipelines be capable of being in-line inspected by either reconfiguring the pipeline to accommodate ILI tools or by the use of new technology that permits previously uninspectable pipelines to be inspected), you said that section 60102(f) of the Pipeline Safety Statute states that the secretary shall prescribe standards requiring that new and replaced pipelines must be designed and constructed to accommodate ILI tools, but section 60104(b) states that design or construction standards do not apply to pipeline facilities that exist when the standard is adopted. As a result, you do not have authority to retroactively require that existing pipelines accommodate ILI tools. However, the NPRM proposed requiring that new and replaced line pipe and line components be constructed and designed to accommodate ILI devices. Regarding the second part of Safety Recommendation P-15-18 (that priority be given to the highest risk transmission pipelines considering age, internal pressure, pipe diameter, and class location), you said that the NPRM has detailed requirements for pipeline assessments and repairs based on pipeline age, operating pressure, and other relevant criteria, which would lead to the highest risk pipelines being prioritized for modifications. We agree that the NPRM addresses the second part of Safety Recommendation P-15-18, and we acknowledge that section 60104(b) limits your authority to require that an existing pipeline be modified solely to allow the use of ILI tools. We emphasize, however, that the recommendation also allows for the use of new technology that permits previously uninspectable pipelines to be inspected. As discussed in our special study, this is an area where the technology is improving, and pipelines that are not suitable for ILI today may be suitable at some point in the future as ILI technology improves. In such a situation, will you have the authority, regulations, and procedures to start requiring that the new ILI technology be used? We note that, although you expected to publish the final rule by the end of 2017, publication has been delayed due to the governmentwide moratorium on new regulations and the required review of all proposed regulations. Pending an acceptable answer to the question of how you will revise the requirements as new ILI technologies become available, and the publication of a final rule that satisfies Safety Recommendation P-15-18, it 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 appreciate receiving your update regarding actions to address Safety Recommendation P 11-17. However, please note that Safety Recommendation P-11-17 was classified “Closed?Superseded” by Safety Recommendation P 15-18 on January 27, 2015, in our safety study titled Integrity Management of Gas Transmission Pipelines in High Consequence Areas. We look forward to learning of your plans for addressing Safety Recommendation P-15-18, which is classified OPEN—AWAIT RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2015-07-15

Communication Type: Official Correspondence

Communication Contents: We note your belief that your pending gas transmission safety NPRM will achieve the intention of this recommendation by maximizing the safety achievable given cost-benefit and technology constraints. We are also aware that some pipelines might not be easily inspected with in line inspection (ILI) tools if they contain tight radius bends, have low product flow conditions, have valves that do not fully open, are small diameter pipes, have some telescoping configurations, or have other issues. However, we maintain that this is predominately a problem with smaller distribution lines, and we expect that you can and will require ILI on all natural gas transmission lines. We further note that you have commissioned a study to provide estimates of costs and benefits of regulatory scenarios for implementing this recommendation, and we understand that the results of the preliminary analysis are expected soon. In addition, we note that you expect your proposed gas transmission safety rule to result in the upgrade of many miles of pipe and the assessment of this pipe with ILI tools, even though the rule does not mandate ILI for all segments. We acknowledge your support for the development of new technology and are encouraged that you plan to consider future rulemaking mandating the use of new technologies as their capabilities and reliability are demonstrated. Pending the completion of these efforts, with the understanding they will lead towards the required use of ILI tools on all gas transmission lines, Safety Recommendation P 15 18 is classified OPEN—ACCEPTABLE RESPONSE.

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 proposed closure of this recommendation to the NTSB on April 1, 2019, and looks forward to NTSB' s response.

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 requests closure of this recommendation. PHMSA's current regulations require that all new and replaced pipes, valves, fittings, and other components are designed and constructed to accommodate internal inspection devices, per 49 CFR § 192.150. Additionally, PHMSA believes that the economic and technological benefits of in line inspection (ILI) over other assessment methods will continue to encourage operators to use this technology whenever possible. PHMSA's current regulations require new and replacement natural gas transmission facilities to be designed and constructed to accommodate ILI tools. In addition, PHMSA's Integrity Management (IM) regulations establish assessment criteria based on pipeline risk. Under the IM regulations, operators are required to prioritize repairs if they discover certain high-risk pipeline conditions in HCAs, thereby helping ensure that operators prioritize the repair of the highest-risk HCA gas transmission pipelines. Per § 192.150, if these pipelines are replaced, they must be modified to accommodate ILI tools. The NTSB asked if PHMSA has the authority, regulations, and procedures to require operators to use ILI if ILI technology improves to the extent that currently unpiggable lines would be able to accommodate ILI tools. PHMSA can require operators to use ILI assessment if ILI technology is feasible and the most appropriate tool to assess a pipeline segment's specific threats. PHMSA believes that the economic and technological benefits of ILI will continue to encourage operators to use ILI more effectively than regulations could. The unit cost of an ILI assessment is significantly less than that of alternative assessment methods. This is reflected in the rate operators use ILI (for 75 percent of onshore gas transmission assessment miles).

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: Response: 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 ), proposed to enhance and expand minimum requirements for the selection and use of integrity assessment methods. PHMSA notes that the NTSB had some questions as to whether these changes would require operators to modify previously uninspectable pipelines to accommodate ILI tools or alternatively, require operators to use new technologies to perform the inspections. The NTSB also questioned whether PHMSA would establish requirements to prioritize new ILI is based on pipeline age, operating pressure, or other relevant criteria. The Pipeline Safety Statute, Section 60102(f), Standards as Accommodating "Smart Pigs," states that the Secretary shall prescribe standards requiring that new and replaced pipelines must be designed and constructed to accommodate ILI tools. Section 60104(b ), Nonapplication, states that design or construction standards do not apply to pipeline facilities existing when the standard is adopted. Therefore, PHMSA cannot retroactively require that existing pipelines accommodate ILI tools. However, PHMSA proposed in the NPRM to require that new and replaced line pipe and line components be constructed and designed to accommodate ILI devices (§192.lSO(a)). The NPRM has a detailed set of requirements for pipeline assessments and repairs based on pipeline age, operating pressure, and other relevant criteria, which would lead to the highest risk pipelines being prioritized for modifications. 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 201 7 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 GP AC 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: 2015-05-12

Communication Type: Official Correspondence

Communication Contents: -From Timothy P. Butters, Deputy Administrator: The Pipeline and Hazardous Materials Safety Administration’s (PHMSA) mission is to protect people and the environment from the risks of hazardous materials transportation. We are committed to continual improvements to our oversight program to positively influence the safety performance of pipeline operators. PHMSA has a long history of cooperating and collaborating with the NTSB, and we take our responsibility to address all recommendations seriously. Integrity Management (IM) is a performance-based, process-oriented regulatory program developed by PHMSA in response to the Accountable Pipeline Safety and Partnership Act of 1996 (P.L. 104-304), the Pipeline Safety Improvement Act of 2002 (P.L. 107-355), and PHMSA’s oversight experience. Integrity management regulations supplement PHMSA’s prescriptive safety requirements and set systemic performance requirements for operators. IM is based on practices employed by many safety-oriented organizations, whereby safety is continually improved through an iterative process of collecting data, identifying and prioritizing risks, undertaking corrective actions, and assessing performance. We understand that successful implementation of performance-based systems for pipeline safety requires a significant operator commitment to the approach, a diverse set of skills possessed by the operator and regulator that extend beyond pipeline engineering, detailed information on pipeline system and operating conditions, and an understanding of the causes of incidents and near-incidents. For both operators and regulators, the heart of integrity management is to identify the most serious risks through an evaluation of system and incident data, to take data informed corrective action to address risk, and to evaluate program effectiveness and implement new measures based on ongoing assessments of the results. PHMSA is working to improve pipeline safety and the IM program through regulatory development and other means at our disposal. Our Notice of Proposed Rulemaking (NPRM) titled “Pipeline Safety: Gas Transmission,” updating gas transmission pipeline regulations, was recently sent to the Office of Management and Budget (OMB) for review. This NPRM will address many of the NTSB’s recommendations, and we expect it to help pipeline safety by both setting new requirements for operators to follow, and clarifying existing ones. PHMSA’s National Pipeline Mapping System (NPMS) Information Collection was published in the Federal Register on July 30, 2014. We expect the revised Information Collection to lead to improved positional accuracy and address the need for additional pipeline attribute information to support our internal risk models. We believe both of these efforts will be responsive to the NTSB recommendations made in their respective areas. In parallel with our rulemaking and information collection efforts, PHMSA utilizes a variety of non-regulatory approaches to improve pipeline safety and communications. Our public awareness, emergency response training, research and development (R&D), technical workshops, and enforcement programs have helped to advance pipeline safety. For example, since February 2014, PHMSA has conducted seven workshops and public meetings on technical topics such as R&D, cracking, class location, Safety Management Systems, and the National Pipeline Mapping System. PHMSA is also planning a risk-modelling workshop for the summer of 2015 to address the need for operators to move to more sophisticated risk models. Finally, pipeline operators, as owners of the pipeline infrastructure, are required to know and understand their pipeline system operating environments. PHMSA challenges operators to focus on performance and aim beyond the minimum compliance standards established through pipeline safety regulations, to ensure the safety of the public that lives and works around pipelines. Concur in part. PHMSA believes that the in-process gas transmission safety NPRM will achieve the intention of this recommendation by maximizing the safety achievable given cost-benefit and technology constraints. The NPRM is currently under OMB review, and we expect to publish it in the summer of 2015. Pipelines might not be able to be inspected with in line inspection (ILI) tools if they contain tight radius bends, low product flow conditions, valves that do not fully open, small diameters, some telescoping configurations, or other issues. Though there are some limitations on PHMSA’s ability to apply new design standards to existing infrastructure, we have commissioned a study that provides estimates of costs and benefits of regulatory scenarios for implementing the NTSB’s recommendation (P-11-18 superseded by P-15-18). PHMSA expects the results of the preliminary analysis to be communicated to the NTSB in the near future. In conjunction with the study, PHMSA’s proposed gas transmission safety rule will result in many miles of pipe being upgraded and assessed with ILI tools, even though the rule does not mandate ILI for all segments. PHMSA actively supports the development of new technology in our R&D activities, and will consider future rulemaking mandating the use of new technologies as their capabilities and reliability are demonstrated.

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: The Gas Transmission NPRM published on April 8, 2016. would enhance and expand the minimum requirements for the selection and use of integrity assessment methods. It is proposed that direct assessment be allowed only if the line is not capable of inspection by internal inspection tools and is not practical to assess using other methods within the IM requirements. PHMSA has proposed revised or new language in several areas of the NPRM that restrict the use of direct assessment as an integrity assessment method, as follows: • §192.150(a) would be amended to require, except as provided in paragraphs (b) and (c) of this section, that each new transmission line and each replacement of line pipe, valve, fitting, or other line component in a transmission line must be designed and constructed to accommodate the passage of instrumented internal inspection devices, in accordance with the requirements and recommendations in NACE SP0102-2010, Section 7 (incorporated by reference, see § 192.7); • § 192.624 (c)(3)(i) on in-line inspection would be amended to add language describing that if a pipe segment does not have records for a pressure test in accordance with subpart J and §192.624(c)(l ), where the operator uses engineering critical assessment (ECA), the operator must develop and implement an inline inspection (ILI) program using tools that can detect wall loss, deformation from dents, wrinkle bends, ovalities, expansion, seam defects including cracking and selective seam weld corrosion, longitudinal, circumferential and girth weld cracks, hard spot cracking, and stress corrosion cracking. At a minimum, the operator would have to conduct an assessment using high resolution magnetic flux leakage (MFL) tool, a high resolution deformation tool, and either an electromagnetic acoustic transducer (EMA T) or ultrasonic testing (UT) tool; • §192.710 would be amended to add a requirement that a significant portion of pipelines not covered by subpart 0 be periodically assessed, using integrity assessment techniques similar to those proposed for HCA segments. Specifically, PHMSA proposes to require that all pipeline segments in class 3 and class 4 locations and "Moderate Consequence Areas," as defined in § 192.3, be periodically assessed. The use of direct assessment is proposed to be allowed only if the line is not capable of inspection by internal inspection tools and is not practical to assess (due to low operating pressures and flows, lack of inspection technology, and critical delivery areas such as hospitals and nursing homes); • §§ 192.921 and 192.937 would be revised to: (1) allow direct assessment only if a line is not capable of inspection by internal inspection tools; (2) add a newly defined assessment method: "spike'' hydrostatic test; (3) add excavation and in situ direct examination as an allowed assessment method; and (4) add guided wave ultrasonic testing (GWUT) as an allowed assessment method.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence