NTSB Safety Recommendation P-87-024

NTSB safety recommendation P-87-024.

THE NTSB RECOMMENDS THAT THE OFFICE OF PIPELINE SAFETY: REVISE 49 CFR PART 195 TO INCLUDE CRITERIA, SIMILAR TO THOSE FOUND IN PART 192, AGAINST WHICH LIQUID PIPELINE OPERATORS CAN EVALUATE THEIR CATHODIC PROTECTION SYSTEMS.

Priority: CLASS II

Overall Status: Closed - Unacceptable Action

Issued Date: 1987-09-09

Adopted Date: 1987-07-20

Overall Date Closed: 1996-01-23

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 - Unacceptable Action

Addressee Date Closed: 1996-01-23

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-03-19

Communication Type: NPRM Response

Communication Contents: Notation 7338: The National Transportation Safety Board has reviewed the Notice of Proposed Rulemaking (NPRM) that would add Subpart H, covering corrosion control, to the existing 49 CFR Part 195. The Safety Board is pleased that corrosion control requirements are being improved and consolidated in a separate subpart. The Safety Board has investigated numerous hazardous liquid pipeline accidents in which corrosion played a significant role. On September 9, 1987, as a result of its investigation of a July 8, 1986, hazardous liquid pipeline accident at Mounds View, Minnesota, the Safety Board recommended that the Research and Special Programs Administration (RSPA): P-87-24 Revise 49 Code of Federal Regulations Part 195 to include criteria, similar to those found in Part 192, against which liquid pipeline operators can evaluate their cathodic protection systems. Because RSPA took no action on this recommendation, the Safety Board, on January 23, 1996, classified Safety Recommendation P-87-24 “Closed-Unacceptable Action.” Unfortunately, external corrosion continues to account for a significant number of petroleum product pipeline accidents. On November 18, 1998, as a result of its investigation of an August 24, 1996, hazardous liquid pipeline accident near Lively, Texas, the Safety Board issued the following safety recommendations to RSPA: P-98-35 Revise 49 Code of Federal Regulations Part 195 to require pipeline operators to determine the condition of pipeline coating whenever pipe is exposed and if degradation is found, to evaluate the coating condition of the pipeline. P-98-36 Revise 49 Code of Federal Regulations Part 195 to include performance measures for the adequate cathodic protection of liquid pipelines. In its April 12, 1999, response to the Safety Board regarding these two safety recommendations, RSPA stated that it was rewriting the corrosion regulations for hazardous liquid pipelines and that it would further explore the issue of requiring that the pipeline coating be examined whenever a buried pipeline is exposed for any reason. RSPA also noted that it was developing criteria and performance measures for adequate cathodic protection of hazardous liquid pipelines and that it would include these in the revised corrosion regulations. Pending the adoption and publication of new regulations, the Safety Board, on November 30, 1999, classified these two recommendations “Open Acceptable Response.” In April 200, RSPA provided an update indicating that the subject NPRM would be issued in the year 2000. The proposed Section 195.565 would require that an operator exposing any portion of a buried pipeline examine the exposed portion for evidence of external corrosion if the pipe is bare or if the coating is deteriorated. The section would not, however, require the operator to conduct any further examination or evaluation of the pipeline if no corrosion damage requiring remedial action (Sec. 195.583) is observed underneath the deteriorated coating. The Safety Board is concerned that even if no significant corrosion damage is observed underneath disbonded coating at a particular excavation location, a similar disbonded condition could exist at other locations along the pipeline, and these locations could have significant damage or could provide suitable sites for future corrosion. Therefore, the Safety Board believes that if the exposed portion of the pipeline shows indications of damaged or disbonded coating, the operator should take appropriate action to determine the condition of the coating at other locations on the pipeline, especially at locations adjacent to these with identified coating problems. The Safety Board thus believes that the proposed Subpart H, section 195.565, should be revised to address this issue and to meet the intent of Safety Recommendation P-98-35. As noted in the NPRM, while the proposed Section 195.567 would require that an operator comply with one or more of the applicable criteria for cathodic protection cited in Section 6 of NACE Standard RP0169-96, it would also allow the use of alternative criteria as provided by paragraph 6.2.1 of the NACE standard. That is, an operator could continue using its existing “successfully applied” criteria so long as those criteria achieve corrosion control “comparable” to that which would be achieved by the criteria described in paragraph 6.2.2 of the NACE standard. In the NPRM, RSPA states its view that protection criteria, in order to be considered both successful and comparable, would have to result in the absence of corrosion leaks or metal loss due to corrosion on the pipeline between inspections or test. The Safety Board is comfortable with this interpretation and endorses its incorporation into the final rule. RSPA has invited comments on whether the entire NACE Standard RP0169-96 should be considered as an alternative to the proposed Subpart H. In the view of the Safety Board, NACE Standard RP0169-96 often is not specific or stringent enough. For example, the NACE standard does not explicitly state that each underground structure should have cathodic protection, nor does it require that cathodic protection be provided within a specified period of time after installation. Also, the NACE Standard refers to several other standards (for example, in the coatings section). The OPS may or may not have input into the revision of these other standards, and it must consider any difficulty it may experience in maintaining adequate requirements. Section 195.555 identifies the pipelines that are covered by the proposed Sections 195.557, 195.559, and 195.561. The Safety Board notes that because of the applicable date clauses, these sections may not cover some older pipelines. Considering the number of pipeline accidents that have involved older pipe, the Safety Board urges RSPA to apply Sections 195.559 and 195.561 to all pipelines, regardless of age, or, as an alternative, to require more frequent inspections of older pipelines. Further, the Safety Board believes that the requirement in section 195.559 (like the previous section 195.242 that it replaces) that an operator install a cathodic protection system “not later than one year after completing the construction” is not always appropriate. For example, in an aggressive corrosive environment, an unprotected pipe can corrode in less than 1 year. Because construction of a pipeline may take more than a year, the Safety Board believes that an operator should be required to install and operate a cathodic protection system within a reasonable but specified period of time after a pipe is buried, considering its environment. Section 195.587, requires the operator to keep records related to: • Examination of a buried pipeline when exposed (195.565). • Cathodic protection monitoring/test data (195.569 (a)). • Evaluation data of active corrosion on unprotected pipelines (195.569 (c)). • Internal corrosion coupon/monitoring data (195.577 (c)). • Internal corrosion inspection data when a pipe is removed from a pipeline (195.577 (d)). These records must be kept for as long as the pipeline remains in service. Because good historical data are necessary to identify potential corrosion problems and/or to determine the effectiveness of any implemented solution to an observed corrosion problem, the Safety Board supports this record-keeping requirement. The Safety Board appreciates the opportunity to comment on this proposed rulemaking. If additional clarification of information is needed regarding our comments, feel free to contact us.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1996-01-23

Communication Type: Official Correspondence

Communication Contents: (CLOSED IN A REPORT NTSB/SIR-96/02) AS INDICATED BY THE BOARD'S EVALUATION OF RSPA'S ACCIDENT DATA, EXTERNAL CORROSION FAILURES CONTINUE TO ACCOUNT FOR NEARLY 20 PERCENT OF THE ACCIDENTS INVOLVING PETROLEUM PRODUCT PIPELINES. IN THE 8 YEARS THAT HAVE ELAPSED SINCE P-87-24 WAS ISSUED, RSPA HAS NOT TAKEN ANY MEANINGFUL ACTION TO ADDRESS THIS ISSUE. FURTHER, THERE IS NOT INDICATION FROM THE DOT REGULATORY AGENDA THAT RSPA INTENDS TO ACT ON THIS RECOMMENDATION. BECAUSE OF RSPA'S INACTION, THE BOARD CLASSIFIES P-87-24 "CLOSED--UNACCEPTABLE ACTION."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1988-05-09

Communication Type: Official Correspondence

Communication Contents: THE CRITERIA IN 49 CFR 192 USED BY GAS OPERATORS TO EVALUATE THEIR CATHODIC PROTECTION SYSTEMS IS THE CRITERIA SET FORTH IN THE INDUSTRY STANDARD, "RECOMMENDED PRACTICE 01-69," ESTABLISHED BY THE NATIONAL ASSOCIATION OF CORROSION ENGINEERS (NACE). NACE IS CURRENTLY REVIEWING AND PLANS TO REVISE ITS RECOMMENDED PRACTICE FOR CATHODIC PROTECTION CRITERIA. RSPA EXPECTS NACE TO COMPLETE ITS WORK IN 1988. RSPA PLANS TO REVIEW THE NACE STANDARD AND, IF CHANGES ARE JUSTIFIED ON THE BASIS OF THE NACE WORK, PROPOSE A CHANGE IN THE PART 192 CRITERIA. AT THE SAME TIME, RSPA WILL PROPOSE A COMPARABLE STANDARD TO BE INCLUDED IN PART 195.

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: 1992-08-31

Communication Type: Official Correspondence