NTSB Safety Recommendation P-81-008

NTSB safety recommendation P-81-008.

THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION OF THE U.S. DEPARTMENT OF TRANSPORTATION: EXPEDITE FINAL RULEMAKING ON DOCKET NO. PS-61 REGARDING THE MAINTENANCE OF MAPS AND RECORDS.

Priority: CLASS II

Overall Status: Closed - Unacceptable Action

Issued Date: 1981-05-13

Adopted Date: 1981-04-28

Overall Date Closed: 1988-09-29

Synopsis: ON OCTOBER 9, 1980, A 2-INCH-DIAMETER COMPRESSION COUPLING LOCATED ON THE UPSTREAM SIDE OF A GAS METER SET ASSEMBLY IN THE BOILERROOM OF THE SIMON KENTON HIGH SCHOOL IN INDEPENDENCE, KENTUCKY, PULLED OUT OF ITS CONNECTION WITH A 2-INCH-DIAMETER GAS SERVICE LINE. NATURAL GAS AT 165-PSIG PRESSURE ESCAPED THROUGH THE 2-INCH-DIAMETER OPENING AND, SECONDS LATER, EXPLODED AND BURNED. A BASEMENT WALL WAS BLOWN DOWN, AN ADJACENT CLASSROOM WAS DAMAGED, AND ONE STUDENT WAS KILLED. ABOUT 30 MINUTES LATER, A SECOND EXPLOSION OCCURED, WHICH INJURED 37 PERSONS AND EXTENSIVELY DAMAGED THE SHCOOL. THE GAS SERVICE LINE WAS CONNECTED TO A 4-INCH-DIAMETER GAS MAIN OWNED BY THE UNION LIGHT, HEAT AND POWER COMPANY (GAS COMPANY), WHICH WAS UPRATING THE GAS MAIN BY CONTROLLED PRESSURE INCREASES AT THE TIME OF THE ACCIDENT.

Ntsbnumber: DCA81AP001

Report Number: PAR-81-01

Addressee Name: RSPA

Addressee Status: Closed - Unacceptable Action

Addressee Date Closed: 1988-09-29

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1983-03-21

Communication Type: Official Correspondence

Communication Contents: IN RESPONDING TO THE SAFETY OBJECTIVE EMBODIED BY THESE RECOMMENDATIONS, THE MTB PUBLISHED AN ADVANCE NOTICE OF PROPOSED RULEMAKING (ANPRM) IN NOVEMBER 1978 (44 FR 68493, DOCKET PS-61), REQUESTING COMMENTS ON THE POSSIBLE NEED TO REVISE 49 CFR, PART 192, TO REQUIRE THAT GAS COMPANY SYSTEM MAPS AND RECORDS BE MAINTAINED TO ACCURATELY IDENTIFY THE LOCATION, SIZE, AND OPERATING PRESSURE OF GAS PIPELINES. BASED ON THE PUBLIC RESPONSES TO THE ANPRM, THE MTB CONDUCTED A COST-BENEFIT ANALYSIS OF THE PROPOSED REQUIREMENT THAT GAS COMPANIES ACCURATELY IDENTIFY THE LOCATION, SIZE, AND OPERATING PRESSURE OF THEIR GAS PIPELINES. THIS STUDY WAS ALSO IN PARTIAL FULFILLMENT OF SECTION 110(B)(1) OF THE PIPELINE SAFETY ACT OF 1979, WHICH CALLED FOR AN ANALYSIS OF WHETHER PIPELINE SAFETY COULD BE SIGNIFICANTLY ENHANCED IN A COST-EFFECTIVE MANNER BY REGULATIONS REQUIRING PIPELINE FACILITY OPERATORS TO PREPARE AND MAINTAIN COMPREHENSIVE DESCRIPTIONS OF THEIR PIPELINE FACILITIES. THE STUDY, ENTITLED "COST BENEFIT ANALYSIS OF INCREASED NATURAL GAS PIPELINE SAFEY REGULATIONS," FOUND AMONG OTHER THINGS, THAT: MANY OF THE DATA ELEMENTS THAT MIGHT BE REQUIRED FOR THE DESCRIPTION OF PIPELINES AND FACILITIES, INCLUDING LOCATIONS, SIZE, AND PIPE OPERATING PRESSURES, ARE CURRENTLY MAINTAINED BY OPERATORS EITHER BECAUSE OF THEIR OWN NEEDS OR BECAUSE THE EXISTING REGULATIONS ALREADY REQUIRE KNOWLEDGE OF THIS INFORMATION. FOR EXAMPLE, SECTION 192.491, CORROSION CONTROL RECORDS, STATES THAT EACH "OPERATOR SHALL MAINTAIN RECORD OR MAPS TO SHOW THE LOCATION OF CATHODICALLY PROTECTED PIPING, CATHODIC PROTECTION FACILITIES... AND NEIGHBORING STRUCTURES BONDED TO THE CATHODIC PROTECTION SYSTEM." AND THE ABSENCE OF SUCH MAPS OR RECORDS IS, PER SE, FAILURE TO BE IN COMPLIANCE WITH THE REGULATIONS. OF COURSE, SOME PIPELINES ARE "PLASTIC" AND DO NOT FALL UNDER THE REQUIREMENTS OF SECTION 192.491 (IN 1979, 18 PERCENT OF SERVICE PIPELINES AND 12 PERCENT OF DISTRIBUTION MAINS WERE "PLASTIC"); AND SOME PIPELINES ARE NOT UNDER CATHODIC PROTECTION DUE TO THE ABSENCE OF ACTIVE CORROSION. BUT WITHOUT THE EXISTENCE OF MAPS OR RECORDS, IT IS DIFFICULT TO SEE HOW AN OPERATOR COULD EFFECTIVELY AND ECONOMICALLY PERFORM THE EXISTING REQUIREMENTS FOR MONITORING FOR ACTIVE CORROSION (SECTION 192.465), OR THE LEAK SURVEY REQUIREMENTS OF SECTION 192.723. IN MARCH 1982, THE MTB ISSUED A FINAL RULE (DOCKET PS-59) REQUIRING GAS PIPELINE OPERATORS TO HAVE OR PARTICIPATE IN A DAMAGE PREVENTION PROGRAM TO REDUCE THE RISK OF EXCAVATION DAMAGE TO BURIED PIPELINES IN CLASS 3 AND 4 LOCATIONS. EXCAVATION DAMAGE IS, BY FAR, THE LEADING CAUSE OF GAS PIPELINE ACCIDENTS, AND THE DAMAGE PREVENTION PROGRAM REQUIRED BY THIS RULEMAKING IS A BROADER, MORE COST-EFFECTIVE, APPROACH TO ADDRESSING THE SAFETY OBJECTIVES ASSOCIATED WITH THE FOREGOING NTSB RECOMMENDATIONS. SOME OF THE KEY PROVISIONS OF THIS DAMAGE PREVENTION PROGRAM ARE: SECTION 192.614(B)(1) AND (2): PROVISION FOR NOTIFICATION OF THE PUBLIC IN THE VICINITY OF THE PIPELINE, AND ACTUAL NOTIFICATION OF PERSONS FORMALLY ENGAGED IN EXCAVATION ACTIVITIES OF THE PROGRAM'S EXISTENCE AND PURPOSE, AND HOW TO LEARN TO LOCATE UNDERGROUND PIPELINES BEFORE EXCAVATION ACTIVITIES ARE BEGUN. SECTION 192.614(B)(4): PROVIDE FOR ACTUAL NOTIFICATION OF PERSONS WHO GIVE NOTICE OF THEIR INTENT TO EXCAVATE OF WHETHER THERE ARE BURIED PIPELINES IN THE AREA OF EXCAVATION ACTIVITY AND, IF SO, THE TYPE OF TEMPORARY MARKINGS TO BE PROVIDED AND HOW TO IDENTIFY THE MARKINGS. SECTION 192.614(B)(5): PROVISION FOR TEMPORARY MARKING OF BURIED PIPELINES IN THE AREAS OF EXCAVATION ACTIVITY BEFORE, AS FAR AS PRACTICAL, THE ACTIVITY BEGINS.EF THAT THE PIPELINE OPERATOR KNOWS THE LOCATION OF THE PIPE. UNDER SECTION 192.614(B)(4), FOR EXAMPLE, THE OPERATOR CANNOT "PROVIDE ACTUAL NOTIFICATION OF PERSONS WHO GIVE NOTICE OF THEIR INTENT TO EXCAVATE OF WHETHER THERE ARE BURIED PIPELINES IN THE AREA OF EXCAVATION ACTIVITY," UNLESS THE OPERATOR KNOWS THE LOCATIONS OF THE PIPELINE. SIMILARLY, THE OPERATOR CANNOT PROVIDE THE "TEMPORARY MARKINGS" FOR THE PIPE, UNLESS THE LOCATION OF THE PIPE IS KNOWN. THE CHOICE OF THE BASIS OF THE INFORMATION THAT IS TO BE PROVIDED TO EXCAVATORS--WHETHER MAPS, A SOPHISTICATED COORDINATE SYSTEM, COMPREHENSIVE RECORDS, OR IN COMBINATION IS AT THE DISCRETION OF THE OPERATORS. IT SHOULD BE NOTED THAT THESE REQUIREMENTS APPLY TO GATHERING, TRANSMISSION, AND DISTRIBUTION PIPELINES IN CLASS 3 AND 4 LOCATIONS. FOR THESE REASONS, THE MTB IS WITHDRAWING THE RULEMAKING IN DOCKET PS-61. THERE ARE SEVERAL ONGOING RESEARCH PROJECTS RELATED TO PIPE LOCATION TECHNIQUES AND EXCAVATION AND BACKFILL METHODOLOGIES. FOR EXAMPLE, A RECENTLY COMPLETED STUDY SPONSORED BY THE GAS RESEARCH INSTITUTE (GRI), ENTITLED "PREVENTION OF THIRD PARTY DAMAGE TO GAS PIPELINES (DRAFT FINAL REPORT, OCTOBER 1980) DESCRIBES A METHOD OF KEEPING TRACK OF WHERE THE ACTUAL ELEMENT OF AN EXCAVATOR IS RELATIVE TO ESTABLISHED SPACE COORDINATES FOR THE PIPE THAT IS BEING EXCAVATED. THE METHOD, ALTHOUGH APPARENTLY THEORETICALLY SOUND, HAS NOT YET BEEN REDUCED TO PRACTICE. HOWEVER, THE MTB WILL CONTINUE TO MONITOR THESE AND OTHER RESEARCH PROJECTS THAT SHOW PROMISE OF RESULTING IN BENEFITS THROUGH MORE EFFECTIVE PIPE-LOCATING DEVICES AND METHODS TO IMPROVE THE ACCURACY AND APPLICABILITY OF SENSING DEVICES WHEN EXCAVATION EQUIPMENT, LIKE BACKHOES AND TRENCHERS, APPROACH BURIED PIPELINES. FOR THESE REASONS, IT IS REQUESTED THAT SAFETY RECOMMENDATIONS P-80-47, P-81-8, AND P-83-1 BE CLASSIFIED AS CLOSED--ACCEPTABLE ALTERNATE ACTION.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1988-09-29

Communication Type: Official Correspondence

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1989-05-23

Communication Type: Official Correspondence