# NTSB Safety Recommendation P-87-009 - **operation:** document - **citation:** P-87-009 - **title:** NTSB Safety Recommendation P-87-009 - **source type:** guidance - **agency:** National Transportation Safety Board - **status:** guidance - **official:** true - **published on:** 1987-03-24 - **effective on:** 1987-03-24 - **summary:** THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAM ADMINISTRATION, U.S. DEPARTMENT OF TRANSPORTATION: REVISE 49 CFR 192 AND, NECESSARY, REQUEST LEGISLATIVE AUTHORITY TO AMEND 49 CFR 192 TO ELIMINATE THE "GRANDFATHER CLAUSE" WHICH PERMITS OPERATORS OF PIPELINES INSTALLED BEFORE NOVEMBER 12, 1970, TO OPERATE AT LEVELS OF STRESS THAT EXCEED THOSE LEVELS PERMITTED FOR PIEPLINE INSTALLED AFTER THE EFFECTIVE DATE OF - **machine formats:** - **json:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-87-009.json - **markdown:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-87-009.md - **app url:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-87-009 - **source url:** https://data.ntsb.gov/carol-main-public/sr-details/P-87-009 **body:** NTSB safety recommendation P-87-009. THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAM ADMINISTRATION, U.S. DEPARTMENT OF TRANSPORTATION: REVISE 49 CFR 192 AND, NECESSARY, REQUEST LEGISLATIVE AUTHORITY TO AMEND 49 CFR 192 TO ELIMINATE THE "GRANDFATHER CLAUSE" WHICH PERMITS OPERATORS OF PIPELINES INSTALLED BEFORE NOVEMBER 12, 1970, TO OPERATE AT LEVELS OF STRESS THAT EXCEED THOSE LEVELS PERMITTED FOR PIEPLINE INSTALLED AFTER THE EFFECTIVE DATE OF 49 CFR 192. Priority: CLASS II Overall Status: Closed - Acceptable Action Issued Date: 1987-03-24 Adopted Date: 1987-02-18 Overall Date Closed: 1994-04-22 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: 1994-04-22 Addressee Acronym: RSPA Addressee Organization Type: G-Federal Government Communication Date: 1994-04-22 Communication Type: Official Correspondence Communication Contents: THE SEPTEMBER 2, 1992, LETTER ADVISED THE 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 & ASKED THE BOARD TO CLOSE THIS RECOMMENDATION. AFTER OUR REVIEW RSPA'S ACTIONS, THE BOARD AGREES THAT THIS RECOMMENDATION SHOULD BE CLOSED & HAS CLASSIFIED P-87-9 "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. Addressee Acronym: RSPA Addressee Organization Type: G-Federal Government Communication Date: 1994-02-24 Communication Type: Official Correspondence Communication Contents: ON DECEMBER 11, 1989, RSPA ISSUED A RULEMAKING PROPOSAL INVITING THE PUBLIC TO COMMENT ON THE ACTION RSPA SHOULD TAKE WITH RESPECT TO THE "GRANDFATHER CLAUSE." RSPA HAS CONCLUDED THAT BASED ON THE PUBLIC COMMENTS IT WAS UNABLE TO JUSTIFY ELIMINATION OF THE GRANDFATHER CLAUSE. Addressee Acronym: RSPA Addressee Organization Type: G-Federal Government Communication Date: 1987-04-29 Communication Type: Official Correspondence Communication Contents: RSPA HAS INITIATED A STUDY OF THE OPERATING PRESSURE "GRANDFATHER CLAUSE" ISSUE. 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 - **truncated:** false - **body characters:** 9987