NTSB Safety Recommendation P-87-026

NTSB safety recommendation P-87-026.

THE NTSB RECOMMENDS THAT THE OFFICE OF PIPELINE SAFETY: OBTAIN SUFFICIENT DATA ON LOW FREQUENCY, ELECTRIC RESISTANCE WELDED PIPE AND DETERMINE IF ITS CONTINUED USE PRESENTS AN UNREASONABLE HAZARD TO PUBLIC SAFETY AND TAKE APPROPRIATE REGULATORY ACTION FOR IDENTIFIED DEFICIENCIES.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1987-09-09

Adopted Date: 1987-07-20

Overall Date Closed: 2003-01-27

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: 2003-01-27

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 Board notes that your April 24, 2000, letter did not provide specific information on Safety Recommendations P-87-26, P-90-29, P-95-2, and P-98-34 through -36. We are aware, however, through staff contact of some ongoing activity with respect to these recommendations; these recommendations are currently classified "Open--Acceptable Response." The Safety Board would appreciate specific information on actions taken by RSPA to meet these safety recommendations so that RSPA's progress on these issues can be evaluated.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1993-03-08

Communication Type: Official Correspondence

Communication Contents: THE BOARD UNDERSTANDS THAT WHEN FORMER PRESIDENT BUSH'S REGULATORY MORATORIUM IS LIFTED, THE RSPA WILL DEVELOP THE NPRM ON HYDROSTATIC TESTING OF CERTAIN HAZARDOUS LIQUID & CARBON DIOXIDE PIPELINES. HOWEVER, THE BOARD BELIEVES THAT SAFETY REGULATIONS SHOULD BE PURSUED BY THE RSPA REGARDLESS OF THE MORATORIUM. THE NPRM WILL PROPOSE THAT ALL HAZARDOUS LIQUID PIPELINES THAT HAVE NOT BEEN HYDROSTATICALLY TESTED IN ACCORDANCE WITH CURRENT STANDARDS EITHER BE TESTED OVER THE NEXT 7 1/2 YEARS OR UNDERGO A REDUCTION IN MAXIMUM PRESSURE. PENDING ISSUANCE OF THE NPRM, RECOMMENDATION P-87-26 WILL REMAIN "OPEN--ACCEPTABLE RESPONSE."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-06-18

Communication Type: Official Correspondence

Communication Contents: THE BOARD UNDERSTANDS THAT RSPA ISSUED ALERT NOTICES TO WARN THE PIPELINE INDUSTRY OF PROBLEMS WITH ERW PIPE IN JANUARY 1988 AND AGAIN IN MARCH 1989, AND HAS A PENDING REGULATORY PROPOSAL THAT ADDRESSES THIS ISSUE. AT THE NOVEMBER 1988, OPS/SAFETY BOARD MEETING, THE BOARD SUGGESTED THAT THE OPS CONSIDER REPUBLISHING THE 1988 AND 1989 ALERT NOTICES TO REMIND THE PIPELINE INDUSTRIES OF THE PROBLEMS WITH THE ERW PIPE, IN ADDITION TO PUBLISHING THE FINAL RULES. THE BOARD ENCOURAGES THE REPUBLICATION OF THE ALERT NOTICES AND, PENDING PUBLICATION AND REVIEW OF THE FINAL REGULATIONS, P-87-26 HAS BEEN CLASSIFIED "OPEN--ACCEPTABLE RESPONSE." THE BOARD WOULD APPRECIATE BEING KEPT INFORMED OF THE STATUS OF THESE INITIATIVES.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-01-27

Communication Type: Official Correspondence

Communication Contents: The Safety Board notes that RSPA collected and evaluated data on low-frequency ERW pipe as requested and found that ERW pipelines are more prone to failures than other pipelines. Subsequently, RSPA issued an Advisory Notice in January 1988 and again in March 1989. In a 1998 final rule, Risk-Based Alternative to Pressure Testing Older Hazardous Liquid and Carbon Dioxide Pipeline Rule, (63 Federal Register 59475), RSPA allowed some limited technological alternatives to the requirement for pressure testing of all pre-1970 ERW pipelines. The deadline for implementing pressure testing or alternative, risk-based evaluations of all susceptible ERW pipe (including low-frequency ERW) was December 2000 in high- and medium-risk areas and December 2002 in low-risk areas. RSPA further reports that the new integrity management program now required of hazardous liquid pipeline operators and soon to be required of gas transmission operators allows the use of various integrity assessment methods. In addition to the pressure testing requirements, an operator's integrity management program must address the risks posed by pre-1970 ERW pipe in HCAs. This program requires periodic reassessments of the integrity of these lines if their failure could impact an HCA. Further, for gas transmission pipelines, if an operator finds ERW or other corrosion on a pipeline that could affect an HCA, RSPA proposes that the operator be required to conduct an integrity assessment and remediate all pipeline segments on the entire pipeline with similar material and environmental characteristics. RSPA reports that it believes that this testing program should lead to a full resolution of low-frequency ERW integrity. Accordingly, Safety Recommendation P-87-26 is 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: 1/88 & 3/89 - Alert notices published on risk of ERW pipe. 04/24/94 - Final Rule requiring new gas and I-L pipelines be "smart piggable" (59 FR 17281) 06/07/94 - Final Rule on pressure testing older hazardous liquid pipelines (59 FR 29379) 1 l/04/98 - Final Rule on risk-based alternative to pressure testing pipelines (63 FR 59475) 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) 01/14/02 - 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) 01/09/02 - NPRM defining HCAs for gas transmission pipelines (67 FR 1108) In Clearance - NPRM requiring IMP for gas pipelines in HCAs (by 1213 l/02) Updated Response: RSPA collected data on pipeline failures involving pipe seams on pipes manufactured prior to 1970 by the electric-resistance welding (ERW) process. A review of this data indicated that these ERW pipelines are more prone to failures. RSPA issued Alert Notices to warn the pipeline industry of problems with low frequency ERW pipe in January 1988 and March 1989. As recently as last summer, RSPA updated this analysis and found that 13 of 14 ERW seam failure-related incidents (approximately 93 percent of all suspected ERW pipe seam failures since the1989 study) were on pre-1970 ERW pipe, which closely approximates the findings in the 1989 study. When the findings for post-1988 data are combined with the data from the 1989 study, the percentage of natural gas transmission pipeline ERW seam failures involving pre-1970 pipe is approximately 95 percent and the percentage of hazardous liquid pipeline ERW seam failures involving pre-1970 pipe is approximately 98 percent, which closely matches the overall findings of the 1989 study, In addition to the Alert Notices, RSPA published a final rule on pressure testing older hazardous liquid and carbon dioxide pipelines on June 7, 1994, (59 FR 29379). Pressure testing is an effective means of identifying problems with longitudinal seams on electric resistance welded (ERW) pipe manufactured before 1970. The final rule provides that pipeline operators may not transport a hazardous liquid in a steel interstate pipeline constructed before January 8, 1971, a steel interstate offshore gathering line constructed before August 1, 1977, or a steel intrastate pipeline constructed before October 21, 1985, unless the pipeline has been pressure tested to current standards or operates at 80 percent or less of a prior test or operating pressure. In a 1998 final rule, "Risk-Based Alternative to Pressure Testing Older Hazardous Liquid and Carbon Dioxide Pipeline Rule," (63 FR 59475) RSPA allowed some limited technological alternatives to the requirement for pressure testing of all pre-1970 ERW pipelines. The deadline for implementing pressure testing or alternative, risk-based evaluations of all susceptible ERW pipe (including low frequency ERW) was December 2000 in high and medium risk areas and December 2002 in low risk areas. The new integrity management program now required of hazardous liquid pipeline operators and soon to be required of gas transmission operators allows the use of various integrity assessment methods. In addition to the pressure testing requirements, an operator's integrity management program must address the risks posed by pre-1970 ERW pipe in high consequence areas. This program requires periodic reassessments of the integrity of these lines if their failure could impact a high consequence area (HCA). Further, for gas transmission pipelines, if an operator finds ERW or other corrosion issues on a pipeline that could affect an HCA, RSPA is proposing that the operator must conduct an integrity assessment and remediate all pipeline segments on the entire pipeline with similar material and environmental characteristics. This testing program should lead to a full resolution of the low frequency ERW integrity issue. Action Requested: RSPA requests that NTSB Safety Recommendation P-87-26 be reclassified as "Closed - Acceptable Action" based on the completion of the actions described above.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1990-12-10

Communication Type: Official Correspondence

Communication Contents: RSPA PROVIDED NTSB WITH A COPY OF TECHNICAL REPORT OPS 89-1 TITLED "ELECTRIC RESISTANCE WELD PIPE FAILURES ON HAZARDOUS LIQUID AND GAS TRANSMISSION PIPELINES." THE NATIONAL INSTITUTE OF STANDARDS AND TECHNOLOGY PREPARED REPORT " AN ASSESSMENT OF THE PERFORMANCE AND RELIABILILITY OF OLDER ERW PIPELINES." WHILE THESE REPORTS DID NOT CONCLUDE THAT THE CONTINUED USE OF THE ERW PIPE POSES AN UNREASONABLE HAZARD TO PUBLIC SAFETY, RSPA HAS INITIATED A REGULATORY PROJECT THAT WILL AFFECT ERW PIPE. A NOTICE OF PROPOSED RULEMAKING IS SCHEDULED TO BE ISSUED PROPOSING THAT ALL HAZARDOUS LIQUID PIPELINES THAT HAVE NOT BEEN HYDROSTATICALLY TESTED IN ACCORDANCE WITH CURRENT STANDARDS EITHER BE HYDROSTATICALLY TESTED OVER THE NEXT 7-1/2 YEARS OR ALTERNATIVELY UNDERGO A REDUCTION IN MAXIMUM OPERATING PRESSURE.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1988-05-09

Communication Type: Official Correspondence

Communication Contents: RSPA INVESTIGATIONS OF ERW PIPE INDICATE THAT THE COMBINATION OF INEFFECTIVE COATING AND INADEQUATE CATHODIC PROTECTION MAY POSE THE GREATEST RISK FOR SEAM FAILURE IN ERW PIPE, PARTICULARLY ERW PIPE MANUFACTURED BEFORE 1970. IN 1986, RSPA BEGAN AN EFFORT TO OBTAIN FURTHER INFORMATION ON ERW PIPE UNDER A MULTI-FACETED RESEARCH PROGRAM AIMED AT DETERMINING ERW PIPE SEAM RELIABILITY. AT PRESENT THERE ARE 3 PARALLEL EFFORTS UNDERWAY TO GATHER DATA ON ERW PIPE: 1. THE ORA DISCUSSED IN P-87-24 2. A CONTRACT WITH THE DEPARTMENT OF MATERIAL SCIENCE AND ENGINEERING AT OREGON GRADUATE CENTER. THE PRIMARY OBJECTIVE OF THIS CONTRACT IS TO DETERMINE IF SIGNIFICANT DIFFERENCES EXIST IN THE SELECTIVE CORROSIVE BEHAVIOR OF ERW SEAMS PRODUCED BY SEVERAL DIFFERENT MANUFACTURERS. 3. AN ON-GOING RSPA STAFF RESEARCH STUDY AIMED AT ANALYZING METALLURGICAL REPORTS FROM FIELD ACCIDENT DATA AND THE DATAG UNDERSTANDING OF THE VARIOUS ERW SEAM FAILURE MODES AND THEIR CAUSES, AND TO SEARCH FOR METHODS FOR PREVENTING FUTURE FAILURES. AS SUFFICIENT INFORMATION IS DEVELOPED FROM THESE PROJECTS, RSPA WILL DETERMINE IF THE DATA INDICATES THAT CERTAIN ERW PIPE IS SUSCEPTIBLE TO POSSIBLE FAILURE. IF SO, RSPA WILL TAKE APPROPRIATE REGULATORY ACTION. IN THE INTERIM, RSPA HAS ISSUED AN ALERT NOTICE TO PIPELINE OPERATORS TO ADVISE THEM OF THE NEED TO TAKE PARTICULAR CARE THAT ERW PIPE IS ADEQUATELY PROTECTED FROM CORROSION.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-07-01

Communication Type: Official Correspondence

Communication Contents: RSPA COLLECTED DATA ON HAZARDOUS LIQUID PIPELINE FAILURES INVOLVING PIPE SEAMS MANUFACTURED PRIOR TO 1970 BY THE ELECTRIC-RESISTANCE WELDING (ERW) PROCESS. REVIEW OF DATA INDICATED THAT THESE ERW PIPELINES ARE MORE PRONE TO FAILURES. RSPA ISSUED AN ALERT NOTICES TO WARN THE PIPELINE INDUSTRY OF PROBLEMS WITH ERW PIPE IN JANUARY 1988 AND MARCH 1989. IN ADDITION TO THE ALERT NOTICES, RSPA PUBLISHED A FINAL RULE (59 FR 29370; JUNE 7, 1994) ON PRESSURE TESTING OLDER HAZARDOUS LIQUID AND CARBON DIOXIDE. PRESSURE TESTING IS AN EFFECTIVE MEANS OF IDENTIFYING PROBLEMS WITH LONGITUDINAL SEAMS ON ELECTRIC RESISTANCE WELDED (ERW) PIPE MANUFACTURED BEFORE 1970. THE FINAL RULE PROVIDES THAT OPERATORS MAY NOT TRANSPORT A HAZARDOUS LIQUID IN A STEEL INTERSTATE PIPELINE CONSTRUCTED BEFORE 1/8/71, A STEEL INTERSTATE OFFSHORE GATHERING LINE CONSTRUCTED BEFORE 8/1/77, OR A STEEL INTRASTATE PIPELINE CONSTRUCTED BEFORE 10/21/85, UNLESS THE PIPELINE HAS BEEN PRESSURE TESTED TO CURRENT STANDARDS OR OPERATES AT 80 PERCENT OR LESS OF A PRIOR TEST OR OPERATING PRESSURE. TO ENSURE THAT OLDER PIPE POSING THE GREATEST RISK IS TESTED FIRST AND TO PROVIDE TECHNOLOGICAL ALTERNATIVES TO PRESSURE TESTING, RSPA PUBLISHED A NOTICE OF PROPOSED RULEMAKING (NPRM), "RISK-BASED ALTERNATIVE TO PRESSURE TESTING OLDER HAZARDOUS LIQUID AND CARBON DIOXIDE PIPELINE RULE" (63 FR 5918), ON 2/5/98. THIS PROPOSED RULE WOULD ALLOW OPERATORS TO ELECT A RISK-BASED ALTERNATIVE IN LIEU OF THE EXISTING RULE (59 FR 29379; 6/7/94). THE EXISTING RULE REQUIRES THE HYDROSTATIC TESTING OF CERTAIN OLDER (INCLUDING ALL PRE-1970 ERW) PIPELINES. THIS RISK-BASED ALTERNATIVE WOULD ALLOW OPERATORS TO EVALUATE THE INTEGRITY OF THESE LINES TAKING INTO ACCOUNT INDIVIDUAL RISK FACTORS. ALTHOUGH MOST PRE-1970 ERW PIPELINES WILL BE REQUIRED TO BE PRESSURE TESTED UNDER THE RISK-BASED APPROACH, THE PROPOSAL RECOGNIZES THAT ALL PRE-1970 ERW PIPE IS NOT NECESSARILY AT RISK FROM SEAM FAILURES. THE PROPOSAL ALLOWS SELECTION OF AN ALTERNATIVE INTERNAL INSPECTION PROCEDURE IF JUSTIFIED BY AN ENGINEERING ANALYSIS. RSPA IS CURRENTLY CONSIDERING COMMENTS TO THE NPRM AND EXPECTS TO PUBLISH THE FINAL RULE BY THE END OF 1998. RSPA REQUESTS THAT P-87-26 CONTINUE TO BE CLASSIFIED AS "OPEN--ACCEPTABLE ACTION" UNTIL THE RULEMAKING DESCRIBED ABOVE IS COMPLETED, AT WHICH TIME WE REQUEST THAT IT BE RECLASSIFIED AS "CLOSED--ACCEPTABLE ACTION."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-04-09

Communication Type: Official Correspondence

Communication Contents: AN NPRM, HYDROSTATIC TESTING OF CERTAIN HAZARDOUS LIQUID AND CARBON DIOXIDE PIPELINE, WAS PUBLISHED MAY 22, 1991, (56 FR 23538), PROPOSING TO EXTEND HYDROSTATIC TESTING OR THE ALTERNATIVE REDUCTION IN MAXIMUM OPERATING PRESSURE TO ALL HAZARDOUS LIQUID STEEL PIPELINE WHERE MAXIMUM OPERATING PRESSURE HAS NOT BEEN ESTALISHED IN ACCORDANCE WITH THE REQUIREMENTS OF 49 CFR PART 195. HOWEVER, THE FURTHER DEVELOPMENT OF THIS REGULATION HAS BEEN DELAYED PENDING THE PRESIDENT'S REGULATORY MORATORIUM AND EVALUATION OF ALL REGULATIONS WHICH SUBSTANTIALLY IMPACT ECONOMIC GROWTH.

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 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: 1991-06-05

Communication Type: Official Correspondence

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-08-31

Communication Type: Official Correspondence