NTSB Safety Recommendation P-87-004

NTSB safety recommendation P-87-004.

THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAM ADMINISTRATION, U.S. DEPARTMENT OF TRANSPORTATION: REQUIRE OPERATIONS OF BOTH GAS AND LIQUID TRANSMISSION PIPELINES TO PERIODICALLY DETERMINE THE ADEQUACY OF THEIR PIPELINES TO OPERATE AT ESTABLISHED MAXIMUM ALLOWABLE PRESSURES BY PERFORMING INSPECTIONS OR TESTS CAPABLE OF IDENTIFYING CORROSION-CAUSED AND OTHER TIME-DEPENDENT DAMAGES THAT MAY BE DETRIMENTAL TO THE CONTINUED SAFE OPERATION OF THESE PIPELINES AND REQUIRE NECESSARY REMEDIAL ACTION.

Priority: CLASS III

Overall Status: Closed - Acceptable Action

Issued Date: 1987-03-24

Adopted Date: 1987-02-18

Overall Date Closed: 2004-04-21

Synopsis: ON APRIL 27, 1985, NATURAL GAS UNDER 990 PSIG RUPTURED THE NO. 10 PIPELINE OF THE TEXAS GAS PIPELINE COMPANY SYSTEM. THE RUPTURE WAS IN AN AREA WEAKENED BY ATMOSPHERIC CORROSION THAT WAS LOCATED WITHIN THE PIPELINE'S CASING UNDER KENTUCKY STATE HIGHWAY 90 NEAR BEAUMONT, KENTUCKY. THE ENSUING FIRE KILLED FIVE PERSONS IN A HOUSE LOCATED NORTH OF THE RUPTURE, INJURED THREE PERSONS AS THEY FLED FROM THEIR HOUSE LOCATED SOUTH OF THE RUPTURE, AND DESTROYED SUBSTANTIAL AMOUNTS OF PROPERTY. ON FEBRUARY 21, 1986, NATURAL GAS UNDER 987 PSIG RUPTURED THE NO. 15 PIPELINE OF THE TEXAS EASTERN GAS PIPE LINE SYSTEM. THE RUPTURE WAS IN AN AREA WEAKENED BY GAL VANIC CORROSION AND WAS LOCATED SOUTH OF KENTUCKY STATE HIGHWAY 52 NEAR LANCASTER, KENTUCKY. THE FORCE OF THE ESCAPING GAS AND THE ENSUING FIRE INJURED THREE PERSONS AS THEY FLED FROM THEIR HOUSES, RESULTED IN THE EVACUATION OF 77 OTHER PERSONS, AND DESTROYED SUBSTANTIAL AMOUNTS OF PROPERTY.

Probable Cause: None

Ntsbnumber: DCA85FP011

Report Number: PAR-87-01

Addressee Name: RSPA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2004-04-21

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2000-09-13

Communication Type: NPRM Response

Communication Contents: Notation 7275: The National Transportation Safety Board has reviewed the Notice of Proposed Rulemaking (NPRM). Docket No. RSPA-99-6355 Notice 3 concerning pipeline integrity management. This NPRM would require pipeline operators who operate 500 or more miles of hazardous liquid pipeline to apply risk management principles to and verify the integrity of pipelines in high-consequence locations. The continued operation of pipelines with integrity problems has been a recurring issue in accidents investigated by the Safety Board. On March 24, 1987 as a result of its investigations of an April 27, 1985 natural gas transmission pipeline rupture near Beaumont, Kentucky and of a February 21, 1986 natural gas transmission pipeline rupture near Lancaster. Kentucky. I the Safety Board asked that the Research and Special Programs Administration (RSPA): P-87-4 Require operators of both gas and liquid transmission pipelines to periodically determine the adequacy of their pipelines to operate at established maximum allowable pressures by performing inspections or tests capable of identifying corrosion-caused and other time-dependent damages that may be detrimental to the continued safe operation of these pipelines and require necessary remedial action. P-87-5 Establish criteria for use by operators of pipelines in determining the frequency for performing inspections and tests conducted to determine the appropriateness of established maximum allowable operating pressures. Also, on September 9. 1987. as a result of its investigation of the July 8. 1986. Fire and explosion caused by a ruptured gasoline pipeline at the Williams Pipeline Company in Mounds View. Minnesota." the Safety Board recommended that RSPA: P-87-23 Revise 49 ('ode of Federal Regulations Parts 192 and 195 to include operational based criteria for determining safe service intervals for pipelines between hydrostatic retests. Accidents involving the continued operation of pipelines with time-dependent defects have occurred repeatedly in the 13 years Sll1ce the Board issued these recommendations. For instance, in 1996 nearly a million gallons of fuel oil were released into the Reedy River near Fork Shoals, South Carolina when a section of corroded pipe ruptured. Also in 1996, almost 500,000 gallons of gasoline were released into marshland and the Blind River near Gramercy, Louisiana, when a previously damaged section of pipeline ruptured. The Safety Board is investigating five other pipeline accidents that occurred during 1999 and 2000 that may involve pipeline integrity problems. In the case of the June 10, 1999 Bellingham, Washington, pipeline accident, for example, we found indications of previous external mechanical damage in the vicinity of the rupture. Because of the length of time that had passed without satisfactory RSPA action on Safety Recommendations P-87-4 -5 and -23 on June 18, 1999, the Safety Board classified all three recommendations '"Open--Unacceptable Response." In an April 24, 2000, letter to the Safety Board RSPA stated that it believed that its proposed pipeline integrity management plan would help address these safety recommendations. The NPRM applies only to operators who operate 500 or more miles of hazardous liquid pipeline and who operate their pipelines in high-consequence areas. The NPRM identifies high-consequence areas by their proximity to populated areas, unusually sensitive environmental areas and commercially navigable waterways. The preamble of the NPRM states that RSPA will at a future date issue additional pipeline integrity management rulemakings covering operators who operate less than 500 miles of hazardous liquid pipeline and natural gas transmission pipelines. With respect to the miles of pipeline operated by an operator this restriction is unjustified because the number of miles operated is not related to the consequences of an accident. The Safety Board believes that RSPA should apply the same requirements to all operators of hazardous liquid pipelines. The Board is disappointed that the proposed rule does not include integrity verification requirements for natural gas transmission pipelines as Safety Recommendations P-87-4. -5 and -23 issued 13 years ago urged the Safety Board urges RSPA to expeditiously establish integrity verification requirements for natural gas transmission pipeline systems. Further the Safety Board believes that integrity management requirements should include hazardous liquid pipelines in all locations, not just those in the defined high-consequence areas. Hazardous liquid spills that take place outside designated high-consequence areas can still have very damaging results. The Safety Board recognizes that higher consequence areas may need more protection than lower consequence areas. But by definition, the principles of risk management assign the highest priority to locations subject to the greatest damage. The Safety Board urges RSPA to mandate verification of a pipeline's integrity for all hazardous liquid pipeline locations. The Safety Board has additional concerns regarding specific elements of the NPRM For example. Section 195.452 (d) of the NPRM allows pipeline operators 7 years to complete baseline assessments. The Safety Board could not sufficient data in the rulemaking to justify the 7-year timeframe and therefore urges RSPA to reduce the time period by which operators must complete baseline assessments. The Safety Board pointed out in a previous accident investigation report' that, although the Office of Pipeline Safety considers many of its pipeline safety regulations to be performance-oriented requirements, many arc only general statements of required actions that do not establish criteria against which the adequacy of the actions taken can be evaluated. The Safety Board further stated that when regulations do not contain measurable standards for performance it is difficult to determine compliance. Several parts of this NPRM appear to rely on language that would make it difficult for RSPA to determine whether the regulation's requirements have been met. For example, how would RSPA determine that a particular operator's taking Option 2 (in Section 195.452 [e]) provides an equivalent level of safety and environmental protection as would implementing Option I? Instead, the Safety Board believes that RSPA should identify minimum specific factors that must be included in the assessment such as results from previous inspections, leak history, pipeline and coating conditions, cathodic protection history, type of pipe seam, products transported, and operating pipe stress levels. The Safety Board is also concerned that the NPRM's requirement for operators to use risk-management principles for the various mitigative measures, such as installing emergency flow restricting devices may not be adequately defined. The Safety Board urges RSPA to develop minimum criteria for these mitigative measures, including the installation of emergency flow restricting devices that consider factors such as a pipeline's elevation profile and the volume of product that could be released. Other areas of the proposed rulemaking seem similarly vague. Section 195.452 (b) directs each operator to follow "best industry practices." but the regulation does not indicate what best practices are. How is RSPA to judge which practices are best? Section 195.452 (k) indicates that an operator's program must include methods by which the program' s effectiveness can be measured. The Safety Board urges RSPA to develop measures for these programs that would not only include direct leak parameters such as numbers and volumes of leaks, hut precursors to leaks as well. The Safety Board agrees that risk management principles if properly applied can be powerful tools by which the risks to pipeline integrity may be continually identified, which should lead operators to take action to mitigate these risks. As a result of its invest

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-04-30

Communication Type: NPRM Response

Communication Contents: Notation 7551: The National Transportation Safety Board has reviewed the notice of proposed rulemaking (NPRM), Docket No. RSPA–00–7666, Notice 4, dated January 28, 2003, concerning pipeline integrity management. This proposed rule would require pipeline operators to develop integrity management programs for gas transmission pipelines that, in the event of a failure, could impact high-consequence areas. The operation of pipelines with integrity problems has been a recurring issue in accidents investigated by the Safety Board. On March 24, 1987, as a result of its investigations of an April 27, 1985, natural gas transmission pipeline rupture near Beaumont, Kentucky, and a February 21, 1986, natural gas transmission pipeline rupture near Lancaster, Kentucky, the Safety Board urged that the Research and Special Programs Administration (RSPA): P-87-4 Require operators of both gas and liquid transmission pipelines to periodically determine the adequacy of their pipelines to operate at established maximum allowable pressures by performing inspections or tests capable of identifying corrosion-caused and other time-dependent damages that may be detrimental to the continued safe operation of these pipelines, and require necessary remedial action. P-87-5 Establish criteria for use by operators of pipelines in determining the frequency for performing inspections and tests conducted to determine the appropriateness of established maximum allowable operating pressures. Also, on September 9, 1987, as a result of its investigation of the July 8, 1986, fire and explosion caused by a ruptured gasoline pipeline at the Williams Pipe Line Company in Mounds View, Minnesota, the Safety Board recommended that RSPA: P 87 23 Revise 49 Code of Federal Regulations Parts 192 and 195 to include operational based criteria for determining safe service intervals for pipelines between hydrostatic retests. RSPA now requires integrity management programs for hazardous liquid pipelines in high-consequence areas. This rule requires operators to periodically test hazardous liquid pipelines and demonstrate the integrity of those pipelines. Based on RSPA’s adoption of requirements for assessing the condition of hazardous liquid pipelines and its commitment to require integrity assessment of gas transmission pipelines, the Safety Board’s three 1987 recommendations are currently classified “Open–Acceptable Response.” Additional accidents involving the operation of gas transmission pipelines with time-dependent defects have occurred since the Board issued its recommendations. For example, in 1994 in Edison Township, New Jersey, a natural gas transmission pipeline ruptured. The released gas ignited and destroyed eight buildings. Examination of the ruptured pipe revealed previous mechanical damage to the exterior of the pipe that reduced its wall thickness. A crack in the pipe wall eventually grew to critical size, causing the pipe to rupture. In 2000, a natural gas transmission pipeline ruptured adjacent to the Pecos River near Carlsbad, New Mexico. The gas ignited, resulting in 12 fatalities and extensive damage to two steel suspension bridges used to support gas pipelines crossing the river. Examination of the ruptured pipe revealed severe internal corrosion. Over time, the internal corrosion caused a reduction in pipe wall thickness to a point that the remaining metal could no longer contain the pressure within the pipe. On December 17, 2002, the President signed Public Law 107-355, the Pipeline Safety Improvement Act of 2002. Section 14 of this act requires that within 12 months of its enactment, RSPA is to issue a final rule prescribing integrity management standards for operators of gas transmission pipelines in high-consequence areas. The act requires that within 24 months of its enactment, gas pipeline operators must implement integrity management programs, even if RSPA has not issued a final rule. The act requires these pipeline operators to complete integrity testing of 50 percent of their highest risk pipelines within 5 years and the remainder within 10 years. Reassessment intervals are set at a minimum of once every 7 years. Integrity testing must be done by in-line inspection, pressure testing, or an alternative method approved by RSPA as providing at least an equivalent level of safety. The act requires the integrity programs to have clearly defined criteria for evaluating the results of testing in addition to a description of action to be taken by operators to promptly address any integrity issues raised by the evaluation. The Safety Board generally supports the elements of the proposed gas pipeline integrity management rule, which includes a baseline assessment of the condition of the pipeline, identification and risk assessment of threats, determination of assessment method(s), and provisions for remediation and reassessment. The NPRM contains language specifically excluding gas gathering lines from the regulation. The Safety Board investigated a gas gathering pipeline accident that occurred on May 3, 1994, near Green River, Wyoming, that resulted in three fatalities. While this particular accident involved excavation damage and an immediate failure, the pipeline was operated at a stress level almost 50 percent of yield. Both gas transmission and gathering pipelines can operate at high stress levels and are subject to the same type of integrity issues. Section 192.9 of the existing regulations acknowledges the similarities of many gathering lines to transmission lines by requiring gathering lines in populated areas to comply with the same requirements as transmission lines. However, gas gathering lines in populated areas will not be subject to new integrity testing requirements. The Safety Board urges RSPA to extend the integrity management requirements to include gas gathering lines in populated areas. Section 192.761 of the NPRM adds several new definitions needed to identify high-consequence areas. The proposed rule notes that the effects of a gas pipeline rupture and ignition are highly localized and that the zone of impact around a rupture point is related to the line’s diameter and pressure. The heat-affected zone (potential impact radius) is defined in terms of a radial distance from the rupture point, based on a formula that includes pipeline diameter and pressure. The threshold radius is a bounding radius intended to provide an additional margin of safety beyond the potential impact radius. The proposed rule would round up the potential impact radius distances into fixed 300, 660, and 1,000 foot threshold radius distances. The proposed rule notes that rounding up provides an additional margin of safety. However, there will be little increase in safety margin for pipelines with a diameter and pressure that places them just below one of the fixed threshold radius distances. Therefore, the Safety Board urges RSPA to employ a calculation formula that provides an adequate and uniform safety margin for all combinations of pipeline diameter and pressure. The existing pipeline class location criteria provide enhanced protection for certain pipeline segments. The Edison accident pipeline was built to class 3 location standards. Under the class 3 location criteria, the area up to 660 feet from the pipeline is examined for buildings intended for human occupancy or proximity to areas of public assembly. In the Edison accident, the pipeline diameter was 36 inches and the maximum allowable operating pressure (MAOP) was 975 psig. Therefore, the proposed threshold radius for the Edison accident pipeline would be 1,000 feet, which provides a greater area for safety considerations than the current class 3 pipeline safety regulations. The Board also notes that the distance from the Edison pipeline rupture site to the outermost building that burned was 865 feet, which is within the proposed 1,000-foot threshold radius. With regard to th

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1996-01-23

Communication Type: Recommendation Reiteration

Communication Contents: From the special investigation report: Evaluation of Accident Data and Federal Oversight of Petroleum Product Pipelines (adopted 1/23/1996): The Safety Board issued Safety Recommendations P-87-4 through -7 on internal inspection of pipelines following its investigation of two pipeline ruptures that took place in Beaumont and Lancaster, Kentucky.32 The four safety recommendations urged that RSPA: P-87-4 Require operators of both gas and liquid transmission pipelines to periodically determine the adequacy of their pipelines to operate at established maximum allowable operating pressures by performing inspections or tests capable of identifying corrosion-caused and other time-dependent damages that may be detrimental to the continued safe operation of these pipelines and require necessary remedial action. P-87-5 Establish criteria for use by operators of pipelines in determining the frequency for performing inspections and tests conducted to determine the appropriateness of established maximum allowable operating pressures. P-87-6 Require existing natural gas transmission and liquid petroleum pipeline operators, when repairing or modifying their systems, to install facilities to incorporate the use of in-line [internal] inspection equipment. P-87-7 Require that all new gas and liquid transmission pipelines be constructed to facilitate the use of in-line [internal] instrument inspection equipment. On November 20, 1992, RSPA issued an NPRM on the internal inspection of pipelines. In the final rule, published on April 12, 1994, RSPA required that new and replacement gas transmission and hazardous liquid pipelines be designed to accommodate internal inspection devices. Because the new regulations required that new and most refitted gas and hazardous liquid pipelines accommodate the passage of internal inspection devices, the Safety Board classified Safety Recommendations P-87-6 and -7 “Closed--Acceptable Action” on February 7, 1995. RSPA also indicated that it was planning to issue an NPRM proposing that internal inspection devices or other equivalent inspection methods be required on gas pipelines in highly populated areas and on hazardous liquid pipelines in highly populated areas, environmentally sensitive areas, and navigable waterways. The Safety Board reaffirmed in the Edison report the need for periodic inspections of high pressure pipelines, especially in urban and environmentally sensitive areas, to assess their fitness for continued safe operation. The Board also reaffirmed that RSPA should take: Complete regulatory action to require that internal inspection technology be used to periodically assess the condition of pipelines, and to establish criteria for operators to use in determining how often pipelines should be internally inspected to ensure unsafe conditions are detected before a pipe fails. The Safety Board affirmed the “Open--Acceptable Response” classification of Safety Recommendation P-87-4, reiterated the recommendation, and urged RSPA to complete action on this issue in 1995. On October 18, 1995, RSPA conducted a public workshop to discuss issues “relevant” to the development of regulations requiring increased inspection of certain gas and hazardous liquid pipelines. The purpose of the workshop was to “enable government and industry representatives to reach a better understanding of the problem and potential solutions before proposed rules are issued.” The issues addressed in the workshop included the: (1) adequacy of current DOT safety regulations that require periodic inspection of pipelines for corrosion and leaks; (2) circumstances in which the regulations should require the use of instrumented internal inspection devices; (3) types of defects that should be required to be detected by internal inspection devices; (4) alternative inspection methods to the use of instrumented internal inspection devices; (5) definitions for “high density population,” “environmentally sensitive areas,” and “navigable waterways;” and (6) costs of inspections with internal inspection devices. In an update of its regulatory agenda that was published on November 28, 1995, RSPA projected that an NPRM would be published by April 1996. Although 8 years have past since the Safety Board issued Safety Recommendation P-87-4, RSPA has yet to complete action on this recommendation. By conducting the workshop in October 1995, RSPA prolonged the regulatory process and will not publish an NPRM before April 1996, despite the Safety Board's reiteration of the recommendation and strong urging in the Edison report to complete action on this issue in 1995. The Safety Board recognizes that RSPA’s need to coordinate with industry about the problems and potential solutions for the inspection and testing of pipelines is valid, but much of the coordination could and should have been accomplished much earlier. Although coordination with industry is likely to be an ongoing process, RSPA could and should have proceeded with the regulatory process in those areas in which there was a consensus by industry and government. Consequently, the Safety Board believes that RSPA has not been responsive to this issue and therefore classifies Safety Recommendation P-87-4 “Open--Unacceptable Response.” Further, the establishment of criteria for determining the frequency of inspections and tests as called for in Safety Recommendation P-87-5 cannot be addressed in a meaningful way until the action needed to implement Safety Recommendation P-87-4 has been completed. Consequently, the Safety Board also classifies Safety Recommendation P-87-5 “Open--Unacceptable Response.” Because of the importance of this issue, the Safety Board reiterates Safety Recommendations P-87-4 and -5.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1997-10-31

Communication Type: Official Correspondence

Communication Contents: NTSB REQUESTED A FOLLOWUP ON THIS DATE 10/31/97.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-04-18

Communication Type: Official Correspondence

Communication Contents: The Safety Board is aware of the reported action that has been taken on these issues and appreciates the RSPA update. Specifically, RSPA reports that in accordance with its risk-based regulatory philosophy, it intends to incorporate a process into its regulations to validate pipe integrity, especially in high-consequence areas. RSPA staff provided a briefing to Safety Board staff on a new initiative to examine effective methods to maintain pipeline integrity in high-consequence areas. In addition, RSPA has issued a Notice of Proposed Rulemaking (NPRM) concerning pipeline integrity management for pipeline operators who operate 500 or more miles of hazardous liquid pipelines. On September 13, 2000, the Safety Board provided its comments regarding this NPRM. On December 1, 2000, RSPA issued its rule for operators who operate 500 or more miles of hazardous liquid pipelines. The Board is also aware that RSPA plans to issue NPRMs covering the balance of operators of hazardous liquid pipelines, as well as operators of natural gas transmission pipelines. The Safety Board is also aware that on December 8, 2000, RSPA issued a NPRM to address P-98-35 and -36. The Safety Board is reviewing the NPRM and expects to provide comments in the near future. The Safety Board appreciates this update and the periodic staff briefings on these issues and encourages RSPA to complete its action to implement the recommendations. Because action on these recommendations has taken so long, Safety Recommendations P-87-4, P-87-5, P-87-23, and P-91-1 will remain classified "Open--Unacceptable Response," pending completion of action by RSPA on each issue. The Safety Board encourages RSPA to continue providing periodic updates regarding action being taken to implement these safety recommendations.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-06-18

Communication Type: Official Correspondence

Communication Contents: THE SAFETY BOARD IS AWARE THAT IN FEBRUARY 1987, RSPA ISSUED AN ADVANCE NOTICE OF PROPOSED RULEMAKING (ANPRM) FOR PUBLIC COMMENT ON A NUMBER OF PROPOSED SOLUTIONS TO POTENTIAL PIPELINE SAFETY PROBLEMS. THE BOARD ALSO UNDERSTANDS THAT IN JUNE 1990, BASED ON PUBLIC COMMENTS AND THE OPINIONS EXPRESSED BY PIPELINE SAFETY ADVISORY COMMITTEES TO THE NPRM, AS WELL AS THE RESULTS OF A STUDY THAT RSPA SENT TO CONGRESS IN COMPLIANCE WITH THE HAZARDOUS LIQUID PIPELINE SAFETY ACT OF 1979, RSPA CONCLUDED THAT INSPECTION AND TESTING OF ALL PIPELINES AT PRESET INTERVALS TO ASSESS INTEGRITY WAS NOT JUSTIFIED. WE UNDERSTAND THAT RSPA IS EXAMINING A RISK-BASED APPROACH IN RESPONSE TO THE MOST RECENT CONGRESSIONAL DIRECTIVE ON PERIODIC INSPECTION (49 U.S.C. 60102(F)(2). THE BOARD UNDERSTANDS THAT RSPA IS NOW DEFINING PRIORITIES FOR INTERNAL INSPECTION, STARTING WITH DETERMINATION OF AREAS THAT ARE UNUSUALLY SENSITIVE TO ENVIRONMENTAL DAMAGE IN THE EVENT OF A PIPELINE ACCIDENT. RSPA'S CURRENT ACTIVITIES ARE PROMISING, HOWEVER, GIVEN THAT THESE RECOMMENDATIONS ARE MORE THAN 12 YEARS OLD, THE SAFETY BOARD ENCOURAGES RSPA TO CONTINUE ITS EFFORTS ON THESE ISSUES AND CLASSIFIES P-87-4, -5 AND -23 "OPEN--UNACCEPTABLE RESPONSE," DUE TO THE LENGTH OF TIME THAT HAS PASSED WITHOUT ACTION CONSISTENT WITH THE RECOMMENDATION. THE BOARD WOULD APPRECIATE BEING PROVIDED PERIODIC UPDATES ON THE STATUS OF THE RELATED RSPA INITIATIVES.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-07-18

Communication Type: Official Correspondence

Communication Contents: The Safety Board understands that RSPA now requires integrity management programs for hazardous liquid pipelines in high consequence areas. RSPA reports that it (1) published a notice in the Federal Register on June 27, 2001, requesting comments on integrity management concepts for gas transmission pipelines, (2) published a proposed definition of high consequence areas for gas pipelines on January 9, 2002, and (3) will propose a gas pipeline integrity management program later this year. RSPA reports that the new rules include criteria for use by pipeline operators in scheduling tests and inspections and that pipeline operators will be required to address risks to pipeline safety, including repairs and pressure reductions as necessary, and will be required to consider the range of risk factors relevant to the pipeline segment being assessed. RSPA further reports that it is also contemplating a similar approach for gas transmission operators. RSPA also advised the Safety Board that in fiscal year 2002, Congress authorized a 20-person increase to RSPA's inspection and enforcement staff to help implement the integrity management rules, and in fiscal year 2003, RSPA will intensify its focus on operator compliance with the pipeline integrity management program rules. Compliance with these integrity management rules will likely require pipeline operators to inspect and evaluate considerable pipeline mileage outside of high consequence areas, and RSPA will require pipeline operators to consider risk factors and data for the entire pipeline system as part of the integrity management program. The Safety Board appreciates this comprehensive update and encourages RSPA to complete action to implement the recommendations. Further, the Safety Board understands that this action has involved a comprehensive and oftentimes an arduous regulatory project requiring extensive research and coordination with industry. Safety Recommendations P-87-4 and -5 are now classified "Open--Acceptable Response," pending completion of action by RSPA.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1996-02-06

Communication Type: Official Correspondence

Communication Contents: THE BOARD RECOGNIZES THAT RSPA'S NEED TO COORDINATE WITH INDUSTRY ABOUT THE PROBLEMS & POTENTIAL SOLUTIONS FOR THE INSPECTION & TESTING OF PIPELINE IS VALID, BUT MUCH OF THE COORDINATION COULD & SHOULD HAVE BEEN ACCOMPLISHED MUCH EARLIER. ALTHOUGH COORDINATION WITH INDUSTRY IS LIKELY TO BE AN ONGOING PROCESS, RSPA COULD & SHOULD HAVE PROCEEDED WITH REGULATORY PROCESS IN THOSE AREAS IN WHICH THERE WAS CONSENSUS BY INDUSTRY & GOVERNMENT. CONSEQUENTLY, THE BOARD FOUND THAT RSPA HAS NOT BEEN RESPONSIVE TO THIS ISSUE & CLASSIFIED P-87-4 "OPEN--UNACCEPTABLE RESPONSE." FURTHER, THE ESTABLISHMENT OF CRITERIA FOR DETERMINING THE FREQUENCY OF INSPECTIONS & TESTS AS CALLED FOR IN P-87-5 CANNOT BE ADDRESSED IN A MEANINGFUL WAY UNTIL THE ACTION NEEDED TO IMPLEMENT P-87-4 HAS BEEN COMPLETED. CONSEQUENTLY, THE BOARD CLASSIFIED P-87-5 "OPEN--UNACCEPTABLE RESPONSE." BECAUSE OF THE URGENCY OF THIS ISSUE, THE BOARD REITERATED P-87-4 & -5. From the special investigation report: Evaluation of Accident Data and Federal Oversight of Petroleum Product Pipelines (adopted 1/23/1996): The Safety Board issued Safety Recommendations P-87-4 through -7 on internal inspection of pipelines following its investigation of two pipeline ruptures that took place in Beaumont and Lancaster, Kentucky.32 The four safety recommendations urged that RSPA: P-87-4 Require operators of both gas and liquid transmission pipelines to periodically determine the adequacy of their pipelines to operate at established maximum allowable operating pressures by performing inspections or tests capable of identifying corrosion-caused and other time-dependent damages that may be detrimental to the continued safe operation of these pipelines and require necessary remedial action. P-87-5 Establish criteria for use by operators of pipelines in determining the frequency for performing inspections and tests conducted to determine the appropriateness of established maximum allowable operating pressures. P-87-6 Require existing natural gas transmission and liquid petroleum pipeline operators, when repairing or modifying their systems, to install facilities to incorporate the use of in-line [internal] inspection equipment. P-87-7 Require that all new gas and liquid transmission pipelines be constructed to facilitate the use of in-line [internal] instrument inspection equipment. On November 20, 1992, RSPA issued an NPRM on the internal inspection of pipelines. In the final rule, published on April 12, 1994, RSPA required that new and replacement gas transmission and hazardous liquid pipelines be designed to accommodate internal inspection devices. Because the new regulations required that new and most refitted gas and hazardous liquid pipelines accommodate the passage of internal inspection devices, the Safety Board classified Safety Recommendations P-87-6 and -7 “Closed--Acceptable Action” on February 7, 1995. RSPA also indicated that it was planning to issue an NPRM proposing that internal inspection devices or other equivalent inspection methods be required on gas pipelines in highly populated areas and on hazardous liquid pipelines in highly populated areas, environmentally sensitive areas, and navigable waterways. The Safety Board reaffirmed in the Edison report the need for periodic inspections of high pressure pipelines, especially in urban and environmentally sensitive areas, to assess their fitness for continued safe operation. The Board also reaffirmed that RSPA should take: Complete regulatory action to require that internal inspection technology be used to periodically assess the condition of pipelines, and to establish criteria for operators to use in determining how often pipelines should be internally inspected to ensure unsafe conditions are detected before a pipe fails. The Safety Board affirmed the “Open--Acceptable Response” classification of Safety Recommendation P-87-4, reiterated the recommendation, and urged RSPA to complete action on this issue in 1995. On October 18, 1995, RSPA conducted a public workshop to discuss issues “relevant” to the development of regulations requiring increased inspection of certain gas and hazardous liquid pipelines. The purpose of the workshop was to “enable government and industry representatives to reach a better understanding of the problem and potential solutions before proposed rules are issued.” The issues addressed in the workshop included the: (1) adequacy of current DOT safety regulations that require periodic inspection of pipelines for corrosion and leaks; (2) circumstances in which the regulations should require the use of instrumented internal inspection devices; (3) types of defects that should be required to be detected by internal inspection devices; (4) alternative inspection methods to the use of instrumented internal inspection devices; (5) definitions for “high density population,” “environmentally sensitive areas,” and “navigable waterways;” and (6) costs of inspections with internal inspection devices. In an update of its regulatory agenda that was published on November 28, 1995, RSPA projected that an NPRM would be published by April 1996. Although 8 years have past since the Safety Board issued Safety Recommendation P-87-4, RSPA has yet to complete action on this recommendation. By conducting the workshop in October 1995, RSPA prolonged the regulatory process and will not publish an NPRM before April 1996, despite the Safety Board's reiteration of the recommendation and strong urging in the Edison report to complete action on this issue in 1995. The Safety Board recognizes that RSPA’s need to coordinate with industry about the problems and potential solutions for the inspection and testing of pipelines is valid, but much of the coordination could and should have been accomplished much earlier. Although coordination with industry is likely to be an ongoing process, RSPA could and should have proceeded with the regulatory process in those areas in which there was a consensus by industry and government. Consequently, the Safety Board believes that RSPA has not been responsive to this issue and therefore classifies Safety Recommendation P-87-4 “Open--Unacceptable Response.” Further, the establishment of criteria for determining the frequency of inspections and tests as called for in Safety Recommendation P-87-5 cannot be addressed in a meaningful way until the action needed to implement Safety Recommendation P-87-4 has been completed. Consequently, the Safety Board also classifies Safety Recommendation P-87-5 “Open--Unacceptable Response.” Because of the importance of this issue, the Safety Board reiterates Safety Recommendations P-87-4 and -5.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-04-21

Communication Type: Official Correspondence

Communication Contents: The Safety Board understands that RSPA completed a series of rulemakings (1) to require that natural gas transmission and hazardous liquid pipeline operators initiate and follow a pipeline integrity management program for high consequence areas (HCA) and (2) to evaluate the entire pipeline for lessons learned in HCAs that should be applied beyond HCAs. Critical parts of the program will be (1) implementation of required testing to identify and remedy corrosion and other time-dependent pipeline damage and (2) validation of the safety of pipelines at their maximum operating pressures. In addition, RSPA now requires each gas and liquid pipeline operator with HCAs to consider a number of criteria when establishing priorities for, and frequency of, pipeline integrity assessments. Operators are also required to address risks to pipeline safety, including repairs and pressure reductions as necessary. Because RSPA has taken action as requested, Safety Recommendations P-87-4, -5, and -23 are classified "Closed--Acceptable Action."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-04-30

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 05/16/2002 1:29:32 PM MC# 2020508 As noted in NTSB's letter of April 18, 2001, RSPA is completing a series of rulemakings to require natural gas transmission and hazardous liquid pipeline operators to initiate and follow a pipeline integrity management program (IMP) for high consequence areas (FICA), including areas unusually sensitive to environmental damage (USA) in the event of a hazardous liquid release. A critical part of this program is the implementation of mandatory inspection and testing to identify and remedy corrosion and other time-dependent pipeline damage. The program validates the safety of the pipelines at their maximum operating pressures. RSPA overcame a number of difficult issues to implement this series of rules, not the least of which was the process of defining and mapping USAs. RSPA consulted with the relevant Federal environmental agencies, including the Environmental Protection Agency (EPA), as mandated by statute, and the Department of Interior (DOI), Department of Commerce (DOC), and Agriculture (USDA), environmental organizations, and technical experts, to define, identify, and locate USAs. We conducted five public workshops and numerous meetings to exchange views on a USA definition with Federal, State, academic, non-government organizations, and the public. Finally, we sponsored pilot testing and a technical review of the results. This process resulted in identification of USAs - those resources that are most susceptible to damage by a hazardous liquid release should one occur. The final rule on US As was issued on December 21, 2000 (65 FR 80530). The USA definition was used as part of the determination of high consequence areas in the hazardous liquid pipeline IMP rules. On December 1, 2000, RSPA issued the first integrity management rule for hazardous liquid pipeline operators with 500 or more miles of pipeline (65 FR 75378). This rule, which became effective May 29, 2001, applies to pipeline systems that could affect high consequence areas as defined in the rule. On January 14,2002, RSPA published a rule on repair criteria for hazardous liquid pipelines (67 FR 1650). On January 16, 2002, RSPA published a nearly identical IMP rule for hazardous liquid pipeline operators with less than 500 miles of pipeline (67 FR 2136). Building on the integrity management principles established in these rules, RSPA published a notice on June 27, 2001, requesting comments on integrity management concepts for gas transmission pipelines (66 FR 34318). On January 9,2002, RSPA published a proposed definition of high consequence areas for gas pipelines (67 FR 1108) and will propose a gas pipeline integrity management program by close of 2002. All these rules include criteria for use by pipeline operators in scheduling tests and inspections. For example, after completing baseline testing, large liquid operators must consider the severity of specified risk factors, analyze the results of the last integrity assessment, and integrate information from these analyses and other data sources to develop plans for ongoing assessment of pipe integrity and mitigation and repair actions. These assessments must occur at established intervals not to exceed five years, unless the operator can demonstrate that there is an engineering basis for a longer period. All pipeline operators are required to address risks to pipeline safety, including repairs and pressure reductions as necessary. RSPA requires operators to consider the range of risk factors relevant to the pipeline segment being assessed. Examples of the specified risk factors include leak history, cathodic protection history, type and quality of pipe coating, age of pipe, the product transported, pipe wall thickness, pipe size, and location relative to land movement. A similar approach is contemplated for gas transmission operators, as evidenced in the June 27, 2001, notice. All the testing required by the IMP rules applies only to areas in which a failure could impact HCAs, the analysis results in evaluation of the entire pipeline system. For gas pipelines, we are considering whether to require pipeline operators to identify and address pipeline segments outside of HCAs that have environments and risk characteristics similar to areas within HCAs where significant defects have been identified. In fiscal year 2002, Congress authorized RSPA to increase its inspection and enforcement staff by twenty people to help implement the integrity management rules. In fiscal year 2003, we will intensify our focus on operator compliance with the IMP rules. As discussed at our recent meeting with NTSB staff, compliance with the integrity management rules will likely require pipeline operators to inspect and evaluate considerable pipeline mileage outside of HCAs. And, as noted above, we require pipeline operators to consider risk factors and data for the entire pipeline system as part of their integrity management program. RSPA requests that Safety Recommendations P-87-4 and P-87-5 be classified as "Open - Acceptable Action" while we continue to pursue the actions described above.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-02-25

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 2/27/2004 1:29:08 PM MC# 2040095 12/00 -Final Rule requiring IMP for large HL pipelines in HCAs (65 FR 75378) 1/02 - Final Rule on repair criteria for large HL pipelines in HCAs (67 FR 1650) 1/02 - Final Rule on IMP for small HL pipelines in HCAs (67 FR 2136) 8/02 - Final Rule on HCAs for gas transmission pipelines (67 FR 50824) 12/03 - Final Rule revising HCA definition & requiring IMP for gas transmission pipelines in HCAs (68 FR 69778) In December 2003, the Research and Special Programs Administration (RSPA) completed a series of rulemakings to require natural gas transmission and hazardous liquid pipeline operators to initiate and follow a pipeline integrity management program for high consequence areas (HCA) and to evaluate the entire pipeline for lessons learned in HCAs that should be applied beyond HCAs. A critical part of this program will be the implementation of required testing to identify and remedy corrosion and other time-dependent pipeline damage. The program also validates the safety of the pipelines at their maximum operating pressures. RSPA requires each gas and liquid pipeline operator with HCAs to consider a number of criteria when establishing the prioritization and frequency of pipeline integrity assessments. All operators are required to address risks to pipeline safety, including repairs and pressure reductions as necessary. On December 1, 2000, RSPA issued the first integrity management rule for hazardous liquid pipeline operators with 500 or more miles of pipeline (65 FR 75378). This rule, which became effective May 29, 2001, applies to pipeline systems that could affect high consequence areas as defined in the rule. On January 14, 2002, RSPA published a rule on Repair Criteria for Hazardous Liquid Pipelines (67 FR 1650). On January 16, 2002, RSPA published a nearly identical rule for hazardous liquid pipeline operators with less than 500 miles of pipeline (67 FR 2136). On August 6, 2002, RSPA published a rule defining high consequence areas for gas transmission pipelines. On December 15,2003, RSPA published a rule that further refined that definition and requires operators of gas transmission pipelines in high consequence areas to implement an integrity management program. All these rules have criteria for use by pipeline operators in scheduling tests and inspections. For example, after completing baseline testing, large liquid operators must consider the severity of specified risk factors, analyze the results of the last integrity assessment, and integrate information from these analyses and other data sources to develop plans for ongoing assessment of pipe integrity and mitigation and repair actions. These assessments must occur at established intervals not to exceed five years, unless the operator can demonstrate that there is an engineering basis for a longer period. For gas transmission pipelines, operators must consider the potential threats to which each pipeline is subjected and establish testing intervals using the methodology in a consensus national standard (ANSI/ASME B31.8S). Operators must conduct testing at least every seven years, as required by the Pipeline Safety Improvement Act of 2002. The final rule allows operators to use a streamlined approach, known as confirmatory direct assessment, for the testing. If operators opt for confirmatory direct assessment, they must use one of the other methods specified in the rule at maximum intervals based on the stresses to which the pipeline is subjected in operation: 10 years for pipelines operating above 50 percent SMYS, 15 years for pipelines operating between 30 and 50 percent SMYS, and 20 years for pipelines operating below 30 percent SMYS. RSPA is requiring operators to consider the range of risk factors relevant to the pipeline segment being assessed. Examples of the specified risk factors include leak history, cathodic protection history, type and quality of pipe coating, age of pipe, the product transported, pipe wall thickness, pipe size, and location relative to land movement. RSPA requests that Safety Recommendations P-87-4 and P-87-5 be classified as "CLOSED - Acceptable Action."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-06-30

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 7/2/98 1:03:47 PM MC# 980837 FOLLOWING A MAJOR GASOLINE PIPELINE ACCIDENT IN MOUNDS VIEW, MN, RSPA PUBLISHED AN ADVANCE NOTICE OF PROPOSED RULEMAKING FOR PUBLIC COMMENT ON AN ASSORTMENT OF PROPOSED SOLUTIONS TO POTENTIAL PIPELINE SAFETY PROBLEMS (52 FR 43 6 1; FEBRUARY 11, 1987). THE CONCEPT OF REQUIRING OPERATORS TO PERIODICALLY INSPECT AND TEST PIPELINES TO ASSESS INTEGRITY OR TO REAFFIRM THEIR MAXIMUM ALLOWABLE OPERATING PRESSURE WERE INCLUDED IN THIS PROPOSAL. BASED ON PUBLIC COMMENTS, OPINIONS OF OUR PIPELINE SAFETY ADVISORY COMMITTEES, AND THE RESULTS OF A STUDY THAT WE SENT TO CONGRESS IN COMPLIANCE WITH SECTION 2 1 0 OF THE HAZARDOUS LIQUID PIPELINE SAFETY ACT OF 1979, WE CONCLUDED THAT INSPECTION AND TESTING OF ALL PIPELINES AT PRESET INTERVALS TO ASSESS INTEGRITY WAS NOT JUSTIFIED (55 FR 23515; JUNE 8, 1990). THIS CONCLUSION WAS CONFIRMED BY A SUBSEQUENT STUDY OF PERIODIC SMART PIG INSPECTION THAT WE SENT TO CONGRESS UNDER SECTION 304 OF THE PIPELINE SAFETY REAUTHORIZATION ACT OF 1988. CONTRIBUTING TO THIS DECISION WAS OUR BELIEF THAT THE UNCERTAINTIES INVOLVED IN PREDICTING THE BEHAVIOR OF TIME-DEPENDENT DEFECTS MAKE IT IMPOSSIBLE TO DEVELOP VALID CRITERIA FOR CALCULATING THE APPROPRIATE FREQUENCY OF INSPECTIONS AND TESTS. OF COURSE, WE DO REQUIRE MANY INSPECTION PROCEDURES TO ENSURE THE INTEGRITY OF PIPELINES. RSPA BELIEVES IT IS MORE EFFECTIVE TO BASE THE NEED TO INSPECT OR TEST ON RISK FACTORS, SUCH AS CORROSION RECORDS, LEAK HISTORY, AND PIPELINE LOCATION, RATHER THAN ON A PRESET FREQUENCY. WE ARE EXAMINING A RISK-BASED APPROACH IN RESPONSE TO THE MOST RECENT CONGRESSIONAL DIRECTIVE ON PERIODIC INSPECTION (49 U.S.C. 60102(F)(2). UNDER THIS DIRECTIVE, RSPA IS TO PRESCRIBE, IF NECESSARY, ADDITIONAL STANDARDS FOR THE PERIODIC INSPECTION OF CERTAIN GAS AND HAZARDOUS LIQUID PIPELINE FACILITIES, INCLUDING CIRCUMSTANCES IN WHICH AN INTERNAL INSPECTION DEVICE (SMART PIG), OR A METHOD NO LESS EFFECTIVE, IS TO BE USED. WE HELD A PUBLIC WORKSHOP ON THIS DIRECTIVE, THAT WAS ATTENDED BY PIPELINE COMPANIES, RESEARCH ORGANIZATIONS, CONSUMER ORGANIZATIONS, AND ENVIRONMENTAL GROUPS. THE OVERWHELMING SENSE OF THE PARTICIPANTS WAS THAT WE SHOULD AVOID A PRESCRIPTIVE APPROACH AND ALLOW OPERATORS TO WEIGH RISK FACTORS IN DECIDING WHEN TO PROVIDE ADDITIONAL INSPECTION AND WHAT METHOD TO USE. WE ARE IN THE PROCESS OF DEFINING PRIORITIES FOR INTERNAL INSPECTION, STARTING WITH DETERMINATION OF AREAS THAT ARE UNUSUALLY SENSITIVE TO ENVIRONMENTAL DAMAGE IN THE EVENT OF A PIPELINE ACCIDENT. HOWEVER, RSPA IS NOT PLANNING TO PRESCRIBE STANDARDIZED INSPECTION INTERVALS AS SUGGESTED IN P-87-4. IN VIEW OF THE ABOVE, WE ASK THAT YOU CLASSIFY P-87-4 AND -5 AS "CLOSED--RECONSIDERED."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1996-08-07

Communication Type: Official Correspondence

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1987-04-29

Communication Type: Official Correspondence

Communication Contents: THE TOPICS OF THE NEED FOR AND FREQUENTLY OF POST-CONSTRUCTION INSPECTIONS OR TESTS TO DETERMINE PIPELINE FLAWS AND APPROPRIATE OPERATING PRESSURES AND THE USE OF THE IN-LINE EQUIPMENT ARE RELATED TO ONE OF THE PROPOSALS CONTAINED IN THE ADVANCE NOTICE OF PROPOSED RULEMAKING ISSUED ON FEBRUARY 11, 1987, AS DOCKET NO. PS-93. THE COMMENT PERIOD CLOSED ON MARCH 30, 1987, AND RSPA IS REVIEWING THE COMMENTS RECEIVED.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2000-04-24

Communication Type: Official Correspondence

Communication Contents: In accordance with our risk-based regulatory philosophy, RSPA intends to incorporate a process into its regulations to validate pipe integrity, especially in high consequence areas. At the last semiannual meeting RSPA briefed the NTSB pipeline safety staff on a new initiative to examine effective methods to maintain pipeline integrity in hight consequence areas. We updated the NTSB staff on our progress earlier this month. RSPA held a public meeting at the Dulles Hyatt Hotel (Herndon, Virginia) on November 18-19, 1999, to consider the need for additional safety and environmental regulations for gas transmission lines and hazardous liquid pipelines in high-density population areas, commercially navigable waters, and areas unusually sensitive to environmental damage. We were pleased that Robert Chipkevich, Chief of NTSB's Hazardous Materials Division, was able to share his insights on this issue. The purpose of the meeting was to determine the extent to which operators now have integrity management programs, to explore effective ways to promote their development and implementation by all operators, and to discuss mechanisms by which RSPA could confirm the existence and adequacy of such operator-developed programs. The attendees discussed a practical definition of high consequence areas, as well as the possible need for increased inspection, enhanced damage prevention, improved emergency response, and other measures to prevent and mitigate pipeline leaks and ruptures in high consequence areas. We believe that an effective regulation to protect pipelines in high consequence areas will help address NTSB Safety Recommendations P-87-4, P-87-5, P-87-23, P-87-26, P-90-29, P-91-1, P-95-1, P-95-2, and P-98-34. A proposed regulation for hazardous liquid pipelines will be issued by early April 2000.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1987-06-24

Communication Type: Official Correspondence

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-08-31

Communication Type: Official Correspondence