NTSB Safety Recommendation P-78-024

NTSB safety recommendation P-78-024.

TO THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: Amend 49 CFR 192.181(a) to specifically define the requirement for location and number of emergency valves.

Priority: CLASS III

Overall Status: Closed - Acceptable Alternate Action

Issued Date: 1978-07-06

Adopted Date: 1978-05-18

Overall Date Closed: 1994-04-22

Synopsis: On December 1, 1977, a 12-inch, cast-iron high-pressure gas main owned by the Atlanta Gas Light Company was ruptured by an 8-inch steel i-beam pile, which was driven through the pipe at a construction site in downtown Atlanta, Georgia. Within minutes, natural gas at 10-psig pressure migrated through the ground, entered sewer lines and electric conduit systems, and spread into nearby buildings. The gas did not ignite, but thousands of people were evacuated from nearby office buildings.

Ntsbnumber: DCA78MP003

Report Number: PAR-78-03

Addressee Name: RSPA

Addressee Status: Closed - Acceptable Alternate Action

Addressee Date Closed: 1994-04-22

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1979-02-14

Communication Type: Official Correspondence

Communication Contents: We have reviewed your response, dated November 17, 1978, to our pipeline safety recommendation P-78-24. We agree with you that the regulation should not be so specific as to state that "there should be x emergency valves and these should be spaced at a maximum of y feet apart on any line.” We firmly believe, however, that the current 49 CFR 192.18l(a) is not at all precise and does not give an operator enough information to determine if his systems are in accordance with the Federal regulations. For discussion purposes we quote from the pertinent section of the CFR: "Each high-pressure distribution system must have valves spaced so as to reduce the time to shut down a section of main in an emergency. The valve spacing is determined by the operating pressure, the size of the main, and the local physical conditions.” The questions that come immediately to mind are (1) Reduce time from what mark, and by how much? (2) Are there required limits on the number of customers that can be closed down or the size of the geographical area that can be affected? and (3) Is there a maximum time for shutdown and relight? What we really see as missing from existing regulation is the definition of a measurable item that will allow the inspector to provide positive enforcement. In November of 1977, the American Society of Mechanical Engineers (ASME) published guide material on this section of the CFR (copy enclosed). This guide material lists a number of parameters to be considered in striving to fulfill 192.181(a) but the ASME cannot be more specific than the regulation. The problem with this regulation, as we observe it, is the lack of quantifiable, measurable items either in specific numbers, ranges, or rates and the lack of a standard or index for comparison.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1994-04-22

Communication Type: Official Correspondence

Communication Contents: The National Transportation Safety Board has reviewed the actions taken by the Research and Special Programs Administration's (RSPA's) Office of Pipeline Safety (OPS) in response to Safety Recommendations P-78-24, P-84-26, P-87-9 and -21, and P-90-21. Safety Recommendation P-78-24 asked RSPA to amend 49 CFR 192.181(a) to specifically define the requirement for location and number of emergency valves. In response to this recommendation, the Associate Administrator for Pipeline Safety issued Advisory Bulletin 94-02 on January 13, 1994. That bulletin provided operators of gas distribution systems with the OPS criteria for selecting emergency valve locations in high-pressure distribution systems. The Safety Board has reviewed those criteria and has determined that their use by OPS and State personnel in compliance assessments will achieve the intended objective. Therefore, Safety Recommendation P-78-24 is classified "Closed--Acceptable Alternate Action." Safety Recommendation P-84-26 asked RSPA to amend Federal regulations governing the pipelines that transport highly volatile liquids (49 CFR Part 195) to require a level of safety for the public comparable to that now required for natural gas pipelines (49 CFR Part 192). The Safety Board considered natural gas pipeline safety requirements superior to those for liquid pipelines. On February 4, 1994, the OPS issued a Final Rule, "Operation and Maintenance Procedures for Pipelines," which requires that operation and maintenance procedures for both natural gas and liquid pipelines be more consistent. Although the action partially satisfies the objective of Safety Recommendation P-84-26, similar measures are needed in many other areas, such as establishing criteria for the performance of systems used to monitor the operation of pipelines. We encourage your continuing efforts on this issue and will maintain Safety Recommendation P-84-26 in an "Open—Acceptable Response" status. Safety Recommendation P-87-9 asked RSPA to amend 49 CFR Part 192 to eliminate the "grandfather clause" that permits operators of pipelines installed before November 12, 1970, to operate at levels of stress that exceed those levels permitted for pipelines installed after the effective date. In its letter of September 2, 1992, RSPA advised the Safety Board that on December 11, 1989, it had issued a rulemaking proposal and invited the public to comment on the action RSPA should take on the "grandfather clause." RSPA noted that at the time it adopted the grandfather exception, it did not have information to justify requiring operators to lower the pressure in the grandfathered lines. RSPA also conducted a study on the causes and frequency of gas accidents in pipelines operating above 72 percent of the specified minimum yield strength (SMYS) of the steel from which the pipes were manufactured. The September 2, 1992, letter advised the Safety Board that RSPA could not conclude, based on the comments to the rulemaking or on the study results, that grandfathered lines require special treatment when they operate above 72 percent of SMYS. Therefore, on September 9, 1992, RSPA withdrew its rulemaking proposal and asked the Safety Board to close this recommendation. After our review of RSPA's actions, the Safety Board agrees that this recommendation should be closed and has classified Safety Recommendation P-87-9 "Closed--Reconsidered." Safety Recommendation P-87-21 asked RSPA to increase its use of sanctions as a means for motivating operator compliance with Federal pipeline safety standards. OPS and Safety Board staffs compiled information on the compliance actions taken by the OPS before and after issuance of this recommendation. The data show that the OPS reduced its reliance on warning letters from about 70 percent in 1985 to only 20 percent in 1991, the latest year for which that information was available. Conversely, reliance on civil penalties increased each year--from 9 in 1987 to 72 in 1992. Based on this 6-year record of stepping up the use of sanctions to improve operator compliance, the Safety Board has classified Safety Recommendation P-87-21 "Closed--Acceptable Action." Safety Recommendation P-90-21 asked RSPA to "assess existing gas industry programs for educating the public on the dangers of gas leaks and on reporting gas leaks to determine the appropriateness of information provided, the effectiveness of educational techniques used and those techniques used in other public education programs, and based on its findings, amend the public education provision of the Federal regulations." Safety Board and RSPA staff discussed this recommendation on October 29, 1992. During that meeting, Safety Board staff noted that gas-industry public education programs appear to receive less than half as much public recognition as other public education programs, such as those that promote the use of seatbelts and child restraints. Safety Board personnel explained that RSPA needs to identify the techniques that make other public education programs more effective, determine which of them would improve gas-industry programs, and incorporate them into the Federal requirements. On April 5, 1993, the OPS issued Advisory Bulletin ADB-93-02, which directed "gas pipeline facility owners and operators to review and assess their continuing education programs as applied to customers and the public." That bulletin included pertinent information on the accidents investigated by the Safety Board, and in part, it cited Safety Recommendation P-90-21. It advised all natural gas owners and operators to review and assess their continuing education programs to "assure that they are in compliance with the provisions of 49 CFR 192.615(d)." Although the bulletin probably prompted most operators to review their programs, the Safety Board does not regard it as responsive to Safety Recommendation P-90-21 or consistent with the discussions on October 29, 1992, between RSPA and Safety Board staff. The Safety Board encourages RSPA to perform the evaluations necessary to accomplish the recommended action and has classified Safety Recommendation P-90-21 "Open--Unacceptable Response." The Safety Board appreciates the steps RSPA has taken to improve pipeline safety, but we also encourage your continuing support for the objectives not yet realized.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-09-02

Communication Type: Official Correspondence

Communication Contents: -From Douglas B. Ham, Acting Administrator, RSPA: The purpose of this letter is to provide a status report on the 39 National Transportation Safety Board (NTSB) recommendations currently classified as "open” that are associated with the Research and Special Programs Administration's Pipeline Safety Program. we are taking steps to close as many of these recommendations as practicable and keep NTSB apprised of our actions on each of the other recommendations: In an April 9, 1992, letter, we updated NTSB on the status of 18 of the 39 recommendations, requesting that 7 be closed. In a June 22, 1992, letter, we requested that 3 of the 5 most recent recommendations made in 1991 be closed. We are currently preparing a letter requesting that another recommendation made in 1991 be closed. This letter transmits an update on actions we have taken on each of the remaining 16 open recommendations. We are proposing that 1 O of these recommendations be closed. A listing of all 39 open recommendations and their status is enclosed. In total, we are requesting that 21 of the 39 be closed as expediently as possible in light of the President's mandate to relieve the regulatory burden on industry. The new emphasis on regulatory reform coupled with the current extensive regulatory requirements (Executive Orders 12291 and 12612, Paperwork Reduction Act of 1980, and DOT Regulatory Policies and Procedures) make it imperative that alternative solutions to safety problems be fully assessed to determine the most expedient, cost· effective, burden-free approach. Regulatory action seems most appropriate for situations where accidents indicate general trends that need to be addressed and where pervasive pipeline safety problems exist. In other situations, regulatory action may not be the best alternative. We urge NTSB to take Into account the formidable constraints to rulemaking and work with us to identify the relative risks of various safety problems as well as to find appropriate solutions commensurate with those risks. We look forward to hearing from NTSB on the recommendations we have asked to be closed in this letter as well as our April 9 and June 22 letters. Enclosure: P-78-024: NTSB Status: OUA No further action contemplated; propose reclassifying "Closed- Reconsidered." Last RSPA Response: 11/17/78 NTSB Classification: Open - Unacceptable Action (dated 2/14/79) Current RSPA Status as of 8/31 /92: RSPA does not agree with NTSB that the pipeline safety regulations should be amended to specifically define the requirement for location and number of emergency valves. RSPA's current valve spacing standard for high-pressure gas distribution systems allows operators discretion in spacing valves, provided their decisions are based on operating pressure, pipe size, and physical conditions. RSPA does not feel that specific requirements concerning the location and number of emergency valves can be developed to apply to all the varying types of existing gas distribution systems. Each of these systems or parts of systems has been designed and constructed to meet a unique distribution need. Consequently, the layout of each system or part is extremely diverse and varied. Many locations in a system, for example, have multiple paths for gas entry while others have only one path. The number and size of valves also vary considerably. As a result of the unique characteristics of each gas system, we do not believe It is possible, nor necessary, to establish a more specific universal requirement to define the requirement and location for emergency valves. Under Section 192.181, operators are required to have valves spaced in such a way to reduce the time needed to shut down a section of main in an emergency. Operators are also required to have each valve on a main, installed for operating or emergency purpose, to be placed in a readily accessible location to facilitate Its operation in an emergency. Under Section 192.615, operators are required to establish a written procedure to minimize the hazard resulting from a pipeline emergency. These procedures require the operators to provide for a prompt and effective response to each emergency. In addition, RSPA has not adopted this recommendation because of uncertainty over the correlation between the prevention of gas explosions after a reported gas leak and the spacing of valves available to stop the flow of gas to the leak. Without a definite correlation, any proposal for a more specific standard would lack a reasonable basis, and could not be shown to contribute to public safety or balance the costs involved. Therefore, we have terminated further consideration of P-78-024 and recommend that it be classified as 'Closed - Reconsidered.'

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1994-02-22

Communication Type: Official Correspondence

Communication Contents: -From Carl W. Vogt, Chairman: The National Transportation Safety Board has reviewed the actions taken by the Research and Special Programs Administration's (RSPA's) Office of Pipeline Safety (OPS) in response to Safety Recommendations P-78-24, P-84-26, P-87-9 and -21, and P-90-21. Safety Recommendations P-78-24 asked RSPA to amend 49 CFR 192.181(a) to specifically define the requirement for location and number of emergency valves. In response to this recommendation, the Associate Administrator for Pipeline Safety issued Advisory Bulletin 94-02 on January 13, 1994. That bulletin provided operators of gas distribution systems with the OPS criteria for selecting emergency valve locations in high-pressure distribution systems. The Safety Board has reviewed those criteria and has determined that their use by OPS and State personnel in compliance assessments will achieve the intended objective. Therefore, Safety Recommendation P-78-24 is classified "Closed--Acceptable Alternate Action." Safety Recommendation P-84-26 asked RSPA to amend Federal regulations governing the pipelines that transport highly volatile liquids (49 CFR Part 195) to require a level of safety for the public comparable to that now required for natural gas pipelines (49 CFR Part 192). The Safety Board considered natural gas pipeline safety requirements superior to those for liquid pipelines. On February 4, 1994, the OPS issued a Final Rule, “Operation and Maintenance Procedures for Pipelines,” which requires that operation and maintenance procedures for both natural gas and liquid pipelines be more consistent. Although the action partially satisfies the objective of Safety Recommendation P-84-26, similar measures are needed in many other areas, such as establishing criteria for the performance of systems used to monitor the operation of pipelines. We encourage your continuing efforts on this issue and will maintain Safety Recommendation P-84-26 in an "Open—Acceptable Response” status. Safety Recommendation P-87-9 asked RSPA to amend 49 CFR Part 192 to eliminate the" grandfather clause" that permits operators of pipelines installed before November 12, 1970, to operate at levels of stress that exceed those levels permitted for pipelines installed after the effective date. In its letter of September 2, 1992, RSPA advised the Safety Board that on December 11, 1989, it had issued a rulemaking proposal and invited the public to comment on the action RSPA should take on the "grandfather clause." RSPA noted that at the time it adopted the grandfather exception, it did not have information to justify requiring operators to lower the pressure in the grandfathered lines. RSPA also conducted a study on the causes and frequency of gas accidents in pipelines operating above 72 percent of the specified minimum yield strength (SMYS) of the steel from which the pipes were manufactured. The September 2, 1992, letter advised the Safety Board that RSPA could not conclude, based on the comments to the rulemaking or on the study results, that grandfathered lines require special treatment when they operate above 72 percent of SMYS. Therefore, on September 9, 1992, RSPA withdrew its rulemaking proposal and asked the Safety Board to close this recommendation. After our review of RSPA's actions, the Safety Board agrees that this recommendation should be closed and has classified Safety Recommendation P-87-9 "Closed--Reconsidered." Safety Recommendation P-87-21 asked RSPA to increase its use of sanctions as a means for motivating operator compliance with Federal pipeline safety standards. OPS and Safety Board staffs compiled information on the compliance actions taken by the OPS before and after issuance of this recommendation. The data show that the OPS reduced its reliance on warning letters from about 70 percent in 1985 to only 20 percent in 1991, the latest year for which that information was available. Conversely, reliance on civil penalties increased each year--from 9 in 1987 to 72 in 1992. Based on this 6-year record of stepping up the use of sanctions to improve operator compliance, the Safety Board has classified Safety Recommendation P-87-21 "Closed--Acceptable Action." Safety Recommendation P-90-21 asked RSPA to "assess existing gas industry programs for educating the public on the dangers of gas leaks and on reporting gas leaks to determine the appropriateness of information provided, the effectiveness of educational techniques used and those techniques used in other public education programs, and based on its findings, amend the public education provision of the Federal regulations. Safety Board and RSPA staff discussed this recommendation on October 29, 1992. During that meeting, Safety Board staff noted that gas-industry public education programs appear to receive less than half as much public recognition as other public education programs, such as those that promote the use of seatbelts and child restraints. Safety Board personnel explained that RSPA needs to identify the techniques that make other public education programs more effective, determine which of them would improve gas-industry programs, and incorporate them into the Federal requirements. On April 5, 1993, the OPS issued Advisory Bulletin ADB-93-02, which directed 11 gas pipeline facility owners and operators to review and assess their continuing education programs as applied to customers and the public." That bulletin included pertinent information on the accidents investigated by the Safety Board, and in part, it cited Safety Recommendation P-90-21. It advised all natural gas owners and operators to review and assess their continuing education programs to "assure that they are in compliance with the provisions of 49 CFR 192.615(d)." Although the bulletin probably prompted most operators to review their programs, the Safety Board does not regard it as responsive to Safety Recommendation P-90-21 or consistent with the discussions on October 29, 1992, between RSPA and Safety Board staff. The Safety Board encourages RSPA to perform the evaluations necessary to accomplish the recommended action and has classified Safety Recommendation P-90-21 “Open--Unacceptable Response.” The Safety Board appreciates the steps RSPA has taken to improve pipeline safety, but we also encourage your continuing support for the objectives not yet realized.