NTSB Safety Recommendation P-87-023

NTSB safety recommendation P-87-023.

THE NTSB RECOMMENDS THAT THE OFFICE OF PIPELINE SAFETY: REVISE 49 CFR PARTS 192 AND 195 TO INCLUDE OPERATIONAL BASED CRITERIA FOR DETERMINING SAFE SERVICE INTERVALS FOR PIPE LINES BETWEEN HYDROSTATIC RETESTS. (Supersedes P-78-058)

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1987-09-09

Adopted Date: 1987-07-20

Overall Date Closed: 2004-04-21

Synopsis: ABOUT 4:20 A.M. ON JULY 8, 1986, LINE 2N, AN 8-INCH PRODUCTS PIPELINE OPERATED BY WILLIAMS PIPE LINE COMPANY (WPL) AT MOUNDS VIEW, MINNESOTA, RUPTURED. UNLEADED GASOLINE UNDER 1,434 PSIG SPEWED FROM A 7 1/2-FOOT-LONG OPENING ALONG THE LONGITUDINAL SEAM OF THE PIPE. VAPORIZED GASOLINE COMBINED WITH AIR AND LIQUID GASOLINE FLOWED ALONG NEIGHBORHOOD STREETS. ABOUT 20 MINUTES LATER, THE GASOLINE VAPOR WAS IGNITED WHEN AN AUTOMOBILE ENTERED THE AREA. FOLLOWING AN EXPLOSION-LIKE NOISE, FIRE SPREAD RAPIDLY ALONG THE PATH OF THE LIQUID GASOLINE. TWO PERSONS WERE BURNED SEVERELY AND LATER DIED, AND ONE PERSON SUFFERED SERIOUS BURNS. THERE WAS SUBSTANTIAL PROPERTY DAMAGE AND SOIL AND WATER POLLU TION.

Ntsbnumber: DCA86AP014

Report Number: PAR-87-02

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: 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 PRESENT 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 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: 2002-09-09

Communication Type: Official Correspondence

Communication Contents: At the July 11, 2002, meeting, RSPA staff indicated that a final rule was issued on December 1, 2000, requiring Integrity Management Programs for large hazardous liquid pipelines in high consequence areas (HCA); that RSPA's final rule for small hazardous liquid pipelines in HCAs was published on January 14, 2002; and that RSPA's Notice of Proposed Rulemaking and final rule requiring an Integrity Management Program for gas pipelines in HCAs are in progress, with expected completion by December 31, 2002. The Safety Board recognizes the long-term effort that went into accomplishing these rules. Accordindly, Safety Recommendation P-87-23 is classified "Open--Acceptable Response," pending publication of the final rule for gas pipelines.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-01-27

Communication Type: Official Correspondence

Communication Contents: RSPA reports that a notice of proposed rulemaking on this issue is expected to be published soon. Accordingly, pending publication and review of the final rule requiring an integrity management program for gas pipelines' HCAs, Safety Recommendation P-87-23 is classified "Open--Acceptable Response." The Safety Board appreciates RSPA's efforts on this issue and looks forward to completed action on the final rule.

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: 2002-10-11

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 10/22/2002 3:33:50 PM MC# 2020885 This letter updates the Research and Special Programs Administration's (RSPA) response to National Transportation Safety Board (NTSB) Safety Recommendations P-87-23, which urges RSPA to determine safe service intervals between pipeline hydrostatic retests, and P-87-26, which urges RSPA to determine if the continued use of Electric Resistance Weld (ERW) pipe is a hazard and to take appropriate regulatory action. RSPA requests that these recommendations be reclassified as "Closed - Acceptable Action" based on the information provided. If we can be of further assistance, please contact me or Patricia Klinger, Director of External Communications, at (202) 366-4831. Actions: 12/01/00 - Final Rule requiring IMP for large HL pipelines in HCAs (65 FR 75378) 12/21/00 - Final Rule defining USAs for HL pipelines (65 FR 80530) 01/09/02 - NPRM defining HCAs for gas transmission pipelines (67 FR 1108) 01/14/02 - Final Rule specifying repair criteria for large HCAs (67 FR 1650) 01/16/02 - Final Rule on IMP for small HL pipelines in HCAs (67 FR 2136) In Clearance - NPRM requiring IMP for gas pipelines in HCAs (by 12/3 l/02) Undated Response: Since this recommendation was issued in 1987, RSPA has developed new approaches and has studied a number of developing technologies that are helping industry to better assess the operation of their pipelines. We have developed a series of rulemakings to require every natural gas transmission and hazardous liquid pipeline operator to implement an integrity management program to protect high consequence areas (HCA) that could be affected by a pipeline failure. The program must include inspection, testing, comprehensive integrated management analysis of all facets of operational history and mitigative actions. Consistent with the recommendation, operators must consider operational-based criteria in determining test and inspection frequencies and prioritizing the pipeline segments for assessment. The continued improvement of technologies now enables operators to choose, subject to RSPA review, how they can best assess their individual pipelines. Operators must conduct either periodic hydrostatic tests, employ internal inspection tools, or use alternative assessment technologies that provide equivalent data describing the condition of the pipeline. All of the integrity management rules include criteria for use by pipeline operators in determining an appropriate schedule for tests and inspections. 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 to RSPA that there is an engineering basis for a longer period. A similar approach is about to be proposed for gas transmission pipelines, The NPRM is now at the Office of Management and Budget for clearance, which is expected shortly. Action Requested: RSPA requests that Safety Recommendation P-87-23 be reclassified as "Closed - Acceptable Action" based on the completion of the integrity management rules for hazardous liquid pipelines and RSPA's commitment to publish a similar rule for gas transmission lines in the next few months.

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) 12/00 - Final Rule defining USAs for HL pipelines (65 FR 80530) 01/02 - Final Rule specifying repair criteria for large HL pipelines in HCAs (67 FR 1650) 01/02 - Final Rule on IMP for small HL pipelines in HCAs (67 FR 2136) 08/02 - Final Rule on HCAs for gas transmission pipelines (67 FR 50824) 12/03 - Final Rule revising HCA definition and requiring IMP for gas transmission pipelines in HCAs (68 FR 69778) RSPA has developed new approaches and has studied a number of developing technologies that are helping industry to better assess the operation of its pipelines. We have developed a series of rulemakings to require every natural gas transmission and hazardous liquid pipeline operator to implement an 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. The program must include inspection, testing, comprehensive integrated management analysis of all facets of operational history and mitigative actions. Consistent with the recommendation, operators must consider operational-based criteria in determining test and inspection frequencies and prioritizing the pipeline segments for assessment. The continued improvement of technologies now enables operators to choose, subject to RSPA review, how they can best assess their individual pipelines. Operators must conduct either periodic hydrostatic tests, employ internal inspection tools, or use alternative assessment technologies that provide equivalent data describing the condition of the pipeline. All of the integrity management rules include criteria for use by pipeline operators in determining an appropriate schedule for tests and inspections. After completing baseline testing, 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. Integrity assessments must occur at established intervals. For hazardous liquid pipelines, the interval may not exceed five years, unless the operator can demonstrate to RSPA that there is an engineering basis for a longer period. All gas transmission pipelines must be assessed at least every seven (7) years with a rigorous assessment (e.g., internal inspection, hydrotest) based on the operating stress level of the pipeline. For pipelines operating above 50 percent SMYS, inspections must occur at least every 10 years. The maximum interval for pipelines operating between 30 and 50 percent SMYS is 15 years and for pipelines below 30 percent SMYS is 20 years. RSPA requests that Safety Recommendation P-87-23 be reclassified as "CLOSED - Acceptable Action" based on the completion of the integrity management rules for hazardous liquid and gas transmission pipelines.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-07-11

Communication Type: Official Correspondence

Communication Contents: RSPA Administrator - NTSB Chairman Meeting: At this meeting, the RSPA Administrator advised the Chairman that Mr. Richard Huriaux (366-4565 & Michael Israni (366-4571) were the RSPA leads on this issue. RSPA issued a final rule on 12-1-00 requiring Integrity Management Program for large Hazardous Liquid pipelines in High Consequence Areas; RSPAs final rule for small Hazardous Liquid pipelines in HCS was published on 1-14-02. RSPAs NPRM and final rule requiring Integrity Management Program for gas pipelines High Consequence Areas are in progress, with expected completion by 12-31-02. RSPA Administrator requests P-87-23 be classified "Open--Acceptable Response," pending the final rule.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1989-01-03

Communication Type: Official Correspondence

Communication Contents: WITH REGARD TO THIS RECOMMENDATION, IT SHOULD BE POINTED OUT THAT THE NTSB INTERPRETATION THAT RSPA ADVOCATES INTERNAL INSPECTION EQUIPMENT AS A SUBSTITUTE FOR HYDROSTATIC TESTING IS NOT AN ACCURATE ASSESSMENT OF RSPA'S APPROACH TO INSPECTION OR TESTING. THE RSPA BELIEVES THAT INTERNAL INSPECTION AUGMENTS HYDROSTATIC TESTING.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1988-05-09

Communication Type: Official Correspondence

Communication Contents: RSPA BELIEVES THAT THE CONTINUED INTEGRITY OF OPERATING PIPELINES NEEDS TO BE ASSURED AND THAT CERTAIN PIPELINES SHOULD BE INSPECTED BY OPERATORS ON A PRIORITY BASIS WITH THE INSPECTION PRIORITY DETERMINED BY OPERATIONAL BASED CRITERIA. RSPA BELIEVES, HOWEVER, THAT THE METHODS TO DETERMINE INTEGRITY SHOULD INCLUDE INSPECTIONS BY INSTRUMENTED PIGS IN ADDITION TO HYDROSTATIC TESTING. RSPA HAS BEGUN A TECHNICAL STUDY TO DETERMINE IF IT IS FEASIBLE TO ESTABLISH CRITERIA TO SURVEY PIPELINES WITH INSTRUMENTED PIGS TO DETECT CORROSION AND OTHER ANOMALIES. IF THE RESULTS OF THE TECHNICAL STUDY INDICATE THAT IT IS FEASIBLE TO ESTABLISH CRITERIA, RSPA WILL PROPOSE A RULEMAKING TO REVISE THE GAS AND HAZARDOUS LIQUIDS PIPELINE REGULATIONS. RSPA DOES NOT BELIEVE THAT REQUIRING PERIODIC HYDROSTATIC TESTING OF ALL GAS AND HAZARDOUS LIQUID PIPELINES IS APPROPRIATE. RSPA WILL PROPOSE, EARLY IN SUMMER OF 1988, TO TESTED TO PART 195 STANDARDS BE HYDROSTATICALLY TESTED IN ORDER TO MAINTAIN CURRENT MAXIMUM OPERATING PRESSURE. RSPA POINTS OUT THAT THEY HAVE INVESTIGATED THE NEED FOR PERIODIC TESTING OF HVL PIPELINES BY HYDROSTATIC TESTING IN 1986 AND IN 1987. BOTH TIMES THE RESULTS SHOWED THAT THE POSITIVE EFFECTS OF PERIODIC INTEGRITY TESTING (HYDROSTATIC) WOULD BE SMALL IN COMPARISON TO THE HIGH TESTING COSTS, INCREASED ACCIDENT POTENTIAL DURING TESTING, THE POTENTIAL FOR ENVIRONMENTAL HARM, AND THE POTENTIAL ADVERSE EFFECTS OF DIVERTING TRANSPORTATION DURING SHUTDOWN.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-07-01

Communication Type: Official Correspondence

Communication Contents: FOLLOWING A MAJOR GASOLINE PIPELINE ACCIDENT IN MOUNDS VIEW, MN, RSPA PUBLISHED AN ADVANCE NOTICE OF PROPOSED RULEMAKING FOR PUBLIC COMMENT ON VARIOUS PROPOSED SOLUTIONS TO POTENTIAL PIPELINE SAFETY PROBLEMS (52 FR 4361; FEBRUARY 11, 1987). THE-NOTION OF REQUIRING OPERATORS TO INSPECT OR TEST PIPELINES PERIODICALLY TO DETERMINE THEIR OPERATIONAL INTEGRITY WAS ONE OF THESE SOLUTIONS. BASED ON THE PUBLIC COMMENTS AND THE OPINIONS OF OUR PIPELINE SAFETY TECHNICAL ADVISORY COMMITTEES, 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 IN NOVEMBER 1992. AT THAT TIME, WE CONCLUDED 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. THERE HAVE BEEN NO SIGNIFICANT CHANGES IN AVAILABLE TECHNOLOGY THAT CHANGE THIS CONCLUSION. RSPA REQUESTS THAT P-87-23 BE RECLASSIFIED AS "CLOSED--RECONSIDERED."

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 brifed the NTSB pipeline safety staff on a new initiative to examine effective methods to maintain pipeline integrity in high 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: 1988-10-12

Communication Type: Official Correspondence

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1989-05-19

Communication Type: Official Correspondence

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-08-31

Communication Type: Official Correspondence