# NTSB Safety Recommendation P-90-029

- **operation:** document
- **citation:** P-90-029
- **title:** NTSB Safety Recommendation P-90-029
- **source type:** guidance
- **agency:** National Transportation Safety Board
- **status:** guidance
- **official:** true
- **published on:** 1990-10-01
- **effective on:** 1990-10-01
- **summary:** THE NTSB RECOMMENDS THAT THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (ORIGINALLY ISSUED TO RSPA): DEVELOP AND IMPLEMENT, WITH THE ASSISTANCE OF THE MINERALS MANAGEMENT SERVICE, THE U.S. COAST GUARD, AND THE U.S. ARMY CORPS OF ENGINEERS, EFFECTIVE METHODS AND REQUIREMENTS TO BURY, PROTECT, INSPECT THE BURIAL DEPTH OF, AND MAINTAIN ALL SUBMERGED PIPELINES IN AREAS SUBJECT TO DAMAGE BY SURFACE VESSELS AND
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**body:**

NTSB safety recommendation P-90-029.

THE NTSB RECOMMENDS THAT THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (ORIGINALLY ISSUED TO RSPA): DEVELOP AND IMPLEMENT, WITH THE ASSISTANCE OF THE MINERALS MANAGEMENT SERVICE, THE U.S. COAST GUARD, AND THE U.S. ARMY CORPS OF ENGINEERS, EFFECTIVE METHODS AND REQUIREMENTS TO BURY, PROTECT, INSPECT THE BURIAL DEPTH OF, AND MAINTAIN ALL SUBMERGED PIPELINES IN AREAS SUBJECT TO DAMAGE BY SURFACE VESSELS AND THEIR OPERATIONS. (Supersedes P-90-005)

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1990-10-01

Adopted Date: 1990-09-11

Overall Date Closed: 2008-07-01

Synopsis: ON OCTOBER 3, 1989, THE UNITED STATES FISHING VESSEL NORTHUMBERLAND STRUCK AND RUPTURED A 16-INCH-DIAMETER NATURAL GAS TRANSMISSION PIPELINE ABOUT 1/2 NAUTICAL MILE OFFSHORE IN THE GULF OF MEXICO, AND ABOUT 5 1/3 NAUTICAL MILES WEST OF THE JETTIES AT THE ENTRANCE TO SABINE PASS, TEXAS. NATURAL GAS UNDER A PRESSURE OF 835 PSIG WAS RELEASED. AN UNDETERMINED SOURCE ON BOARD THE VESSEL IGNITED THE GAS, AND WITHIN SECONDS, THE ENTIRE VESSEL WAS ENGULFED IN FLAMES. THE FIRE ON THE VESSEL BURNED ITSELF OUT ON OCTOBER 4. LEAKING GAS FROM THE PIPELINE ALSO CONTINUED TO BURN UNTIL OCTOBER 4. OF THE 14 CREW MEMBERS, 11 DIED AS A RESULT OF THE ACCIDENT.

Ntsbnumber: DCA90MM001

Report Number: PAR-90-02

Addressee Name: RSPA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2008-07-01

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: PENDING COMMENT BY RSPA ON WHAT ACTIONS IT INTENDS TO TAKE FOR PROTECTING OTHER SUBMERGED PIPELINES, RECOMMENDATION P-90-29 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: P-90-29 ASKED RSPA TO DEVELOP AND IMPLEMENT, WITH THE ASSISTANCE OF THE MINERALS MANAGEMENT SERVICE (MMS), THE U.S. COAST GUARD, AND THE U.S. ARMY CORPS OF ENGINEERS, EFFECTIVE METHODS AND REQUIREMENTS TO BURY, PROTECT, INSPECT THE BURIAL DEPTH OF, AND MAINTAIN ALL SUBMERGED PIPELINES IN AREAS SUBJECT TO DAMAGE BY SURFACE VESSELS AND THEIR OPERATIONS. BECAUSE RSPA IS DRAFTING A NOTICE OF PROPOSED RULEMAKING (NPRM) INCORPORATING THE STUDY, P-90-29 WILL REMAIN "OPEN--ACCEPTABLE RESPONSE," PENDING PUBLICATION AND REVIEW OF THE FINAL RULES.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-02-25

Communication Type: Official Correspondence

Communication Contents: The Safety Board appreciates the update on RSPA's actions to address this recommendation. In this regard, we note that in March 1998, RSPA worked with Texas A&M University to complete a report titled Analysis of Pipeline Burial Surveys in the Gulf of Mexico. We also note RSPA's issuance of three final rules related to this recommendation: 65 Federal Register (FR) 75377, which requires integrity management programs for large hazardous liquid pipelines, in December 2000; 67 FR 2136, which requires integrity management programs for smaller hazardous liquid pipelines, in January 2002; and 67 FR 50824, which defines high consequence areas (HCAs) for gas transmission pipelines, in August 2002. In addition, we note that RSPA issued a notice of proposed rulemaking (NPRM) to require integrity management programs for gas transmission pipelines in high consequence areas (HCAs) and an NPRM to require all operators to have procedures for periodic inspections of pipelines in navigable waters, both in December 2002. Accordingly, pending issuance of the remaining two final rules to complete the recommended actions, Safety Recommendation P-90-29 is classified "Open--Acceptable Response."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-04-21

Communication Type: Official Correspondence

Communication Contents: The Safety Board appreciates receiving the update on RSPA's actions to address this recommendation. We note that in March 1998, RSPA worked with Texas A&M University to complete a report titled Analysis of Pipeline Burial Surveys in the Gulf of Mexico. We also note that RSPA issued four final rules related to this recommendation: 65 Federal Register (FR) 75377, which requires integrity management programs for large hazardous liquid pipelines, in December 2000; 67 FR 2136, which requires integrity management programs for smaller hazardous liquid pipelines, in January 2002; 67 FR 50824, which defines HCAs for gas transmission pipelines, in August 2002; and 69 FR 69778, which revises the HCA definition and requires integrity management programs for gas transmission pipelines in HCAs, in January 2003. The Safety Board further notes that in December 2003, RSPA issued a notice of proposed rulemaking to require all operators to have procedures for periodic inspections of pipelines in navigable waters. Accordingly, pending issuance of the final rule that will complete the recommended actions, Safety Recommendation P-90-29 is classified "Open--Acceptable Response."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-12-20

Communication Type: Official Correspondence

Communication Contents: The Safety Board appreciates RSPA's considerable effort to address this safety recommendation, working with various industries, Federal advisory committees, academia, and several Federal agencies. In related regulatory action, RSPA has done extensive and commendable work on the issue of high consequence areas (HCA) for gas and liquid pipelines; specifically, RSPA issued four final rules related to this recommendation: 65 Federal Register (FR) 75377, which requires integrity management programs for large hazardous liquid pipelines, in December 2000; 67 FR 2136, which requires integrity management programs for smaller hazardous liquid pipelines, in January 2002; 67 FR 50824, which defines HCAs for gas transmission pipelines, in August 2002; and 69 FR 69778, which revises the HCA definition and requires integrity management programs for gas transmission pipelines in HCAs, in January 2003. Further, as noted by the Safety Board in March 1998, RSPA worked with Texas A&M University to complete a report titled Analysis of Pipeline Burial Surveys in the Gulf of Mexico. In December 2003, RSPA issued a notice of proposed rulemaking to require all operators to develop procedures for periodic inspections of pipelines in navigable waters. However, the final rule Periodic Underwater Inspections, published August 10, 2004, is only applicable to the Gulf of Mexico and its inlets. RSPA contends that (1) it has not been presented with sufficient evidence that the rule should include other offshore and inland waters and (2) hazards to navigation in these areas are already being adequately managed by application of the regulations in 49 Code of Federal Regulations (CFR) Parts 192 and 195, as well as the regulations of other agencies. The Safety Board understands that the Technical Hazardous Liquid Pipeline Safety Standards Committee and the Technical Pipeline Safety Standards Committee, both established as Federal advisory committees, have recommended, and RSPA has stated it will consider, a notice to request further public comment on the risks of exposed pipelines and possible hazards to navigation in offshore waters other than the Gulf of Mexico and its inlets. While appreciative of RSPA's efforts to get this final rule issued, the Safety Board reminds RSPA that in the final Northumberland report, Safety Recommendation P-90-29 superceded P-90-5, from the Northumberland accident, because the Board believed that the scope of the initial recommendation (P-90-5) needed to be expanded to all pipelines located in areas subject to damage by surface vessels and their operations. In so doing, the Board cited a January 2, 1990, incident where a 12-inch pipeline transporting heating oil was ruptured in the Arthur Kill channel between Staten Island, New York, and Linden, New Jersey. Accordingly, while pleased with the effort on this issue thus far, the Safety Board encourages RSPA to take action as recommended by its Technical Hazardous Liquid Pipeline Safety Standards Committee and the Technical Pipeline Safety Standards Committee, and conduct further studies to collect data on the risks of exposed pipelines and possible hazards to navigation in offshore waters other than the Gulf of Mexico and its inlets. Pending further response from RSPA, Safety Recommendation P-90-29 remains classified "Open--Acceptable Response."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-03-18

Communication Type: Official Correspondence

Communication Contents: The Safety Board is aware that in 2004, PHMSA published a final rule requiring periodic underwater inspection and notes that PHMSA recently completed a study on the risks of exposed pipelines and possible hazards to navigation in offshore waters other than the Gulf of Mexico and its inlets. The Board further notes that the study identified 58 reported instances of a vessel or its equipment striking a pipeline offshore since 1990, and that all these reported incidents occurred in the Gulf of Mexico, where regulation requires the periodic underwater inspections program. In addition, on April 30, 2007, PHMSA issued a 30-day notice seeking public comment on the adequacy of the study, but received no comments in response to the notice. Although this recommendation is 17 years old, PHMSA has been actively addressing the issues identified in the recommendation and has indicated that it intends to provide a report on actions already taken and those planned to further address this issue. Accordingly, Safety Recommendation P-90-29 is classified Open Acceptable Response, pending timely receipt of this information and our review of PHMSA’s planned actions.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-07-01

Communication Type: Official Correspondence

Communication Contents: On December 20, 2004, the Safety Board acknowledged the considerable efforts that PHMSA had expended to implement this recommendation, including comprehensive research and substantive regulatory improvements. In its letter, however, the Board pointed out that although we appreciated PHMSA’s efforts, the Board believed that the scope of the initial recommendation (P-90-5) needed to be expanded to all pipelines located in areas subject to damage by surface vessels and their operations; for this reason, in the final Northumberland report, Safety Recommendation P-90-29 superseded P-90-5. The Board cited a January 2, 1990, incident in which a 12-inch pipeline transporting heating oil had ruptured in the Arthur Kill channel between Staten Island, New York, and Linden, New Jersey. In its 2004 letter, the Board also encouraged PHMSA to take the action recommended by its Technical Hazardous Liquid Pipeline Safety Standards Committee and the Technical Pipeline Safety Standards Committee by conducting further studies to collect data on the risks of exposed pipelines and possible hazards to navigation in offshore waters other than the Gulf of Mexico and its inlets. Pending further response from PHMSA, Safety Recommendation P-90-29 was classified Open Acceptable Response. The Safety Board is pleased to learn that PHMSA has examined reports of all offshore pipeline incidents within the 15-foot-depth contour line and that PHMSA’s November 2006 report, Study on Burial of Submerged Pipelines, included the following actions relative only to the pipelines under PHMSA’s regulatory authority: ·Review of the extent of incidents in coastal states involving vessels striking pipelines ·Review of Coastal Zone Management Programs and the U.S. Army Corps of Engineers permitting process for the applicability of requirements to inspect underwater pipelines ·Review of six data sources within PHMSA and the U.S. Coast Guard for vessel incidents involving pipeline hazards to navigation and pipeline incidents involving vessels or their equipment ·Determination of the applicable area of the study, including the inland extent of tidal influence (Defining the study area included calculating the mileage of pipelines within the area of concern.) The Safety Board notes that the study revealed 58 reported instances of a vessel or its equipment striking an offshore submerged pipeline and 64 reported instances of a submerged pipeline hazard to navigation between 1990 and 2005, all occurring in the Gulf of Mexico. To obtain offshore pipeline accident data outside the Gulf of Mexico, PHMSA issued a notice in the Federal Register seeking public comment on the results of the study; it received no further information or comment on the study. The Board further notes that PHMSA anticipates changes in the number of pipelines in the offshore environment as a result of the projected increase of liquefied natural gas (LNG) import facilities and that PHMSA will work with the Federal Energy Regulatory Commission (FERC) and other oversight agencies on a case-by-case basis to develop safety measures that should be considered before granting permits for rights-of-way in the offshore shallow waters. The Board understands that PHMSA regularly provides pre-siting safety reviews for permitting agencies and that there have been cases in which FERC has added conditions to approval for a permit based on PHMSA’s advice on the need for additional, site-specific protections. The Board is pleased that PHMSA will continue to monitor the hazard to navigation risk for all submerged LNG, natural gas, and hazardous liquid pipelines and to seek ways to ensure their adequate protection. Because PHMSA has taken the recommended actions to develop and implement methods and requirements to bury, protect, inspect the burial depth of, and maintain all submerged pipelines in all areas subject to damage by surface vessels and their operations, Safety Recommendation P-90-29 is classified Closed Acceptable Action.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-12-10

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 12/18/2002 3:05:16 PM MC# 2021045 RSPA requests that Safety Recommendation P-90-29 be reclassified as "Closed - Acceptable Action" based on one completed and two imminent regulatory actions. Joint Task Force Report on Offshore Pipelines In response to this recommendation, RSPA has taken several actions. In 1990, the RSPA formed a multi agency task force on offshore pipelines. The task force included representatives of the RSPA; the U.S. Coast Guard; the Minerals Management Service; the National Oceanic and Atmospheric Administration/National Oceans Service; and the U.S. Army Corps of Engineers. Representatives of the State of Louisiana, Office of Conservation and the State of Texas, Railroad Commission were also included because of the substantial number of pipelines in their State waters and similar concerns for offshore safety. The task force reviewed information provided by government, maritime, and pipeline industry sources. The assessment focused on the extent and adequacy of federal regulations, the technology for determining pipeline location and cover, the extent and availability of maps and charts depicting the location of pipelines, and possible government initiatives to enhance safety. The task force concluded that the accidents involving fishing vessels and submerged pipelines showed that exposed pipelines pose a potential risk to navigation safety, especially for mariners operating in shallow near-shore waters. It also concluded that despite a requirement to place pipelines below the sea floor in shallow water, underwater inspections for depth of burial of those pipelines were not being performed. To reduce the likelihood of further casualties the task force recommended that operators inspect these pipelines at regular intervals and rebury or otherwise protect exposed pipelines. It was also noted that the burden must not be placed on the pipeline owner/operators alone. Vessel operators also needed to make changes in the manner in which vessels are operated. The task force also noted that safety problems with submerged pipelines are not confined to the offshore areas of the Gulf of Mexico. Although the Gulf contains most of the submerged pipelines and is located where the ocean bottom is most prone to erosion, pipelines located under a river, in a shipping channel, or other body of water are also susceptible to being exposed, damaged or ruptured by vessel operations. Therefore, the task force recommended periodic depth of burial inspections for all submerged pipelines which could pose a hazard to navigation. A copy of the task force report is enclosed. Texas A&M University Study RSPA also contracted with Texas A&M University to produce a study on the inspection and burial of offshore pipelines. The 1998 report concluded that current survey techniques can be effective and advances in internal inspection technologies can provide valuable information to management on the integrity and depth of burial of offshore pipelines. The study recommended updates to pipeline burial depth, reburial, and cover requirements, and suggested basing survey frequency on risk analysis and the establishment of a "one call" type system for offshore pipelines. Integrity Management Programs RSPA issued a final rule (65 FR 75377) on December 1,2000, that requires pipeline operators to develop and implement integrity management programs for hazardous liquid pipelines. The rule applies to onshore (including waterway crossings) and offshore pipelines that could affect a high consequence area. Submerged pipelines could affect unusually sensitive environmental areas (USAs) and commercially navigable waterways. The rule includes offshore pipeline segments because of their potential to impair unusually sensitive ecological resources; the disruption of the flow of goods to communities; and, the impairment of unusually sensitive drinking water resources. As part of their integrity management programs, operators must inspect pipelines to ensure that they remain buried or otherwise protected from damage by surface vessel operations. The rule specifies how operators must provide additional protection to critical areas (i.e., high consequence areas) through integrity management programs. Further, it ensures that these protections will be put in place, with an operator being required to initially assess 50 percent of the pipeline mileage that could affect critical areas, beginning with the highest risk pipe, within 3.5 years and the balance within seven years. An operator will then have to evaluate and repair defects within specified time frames and implement additional preventive and mitigative measures. An operator is also required to continually reassess its pipeline segments at intervals not longer than five years, as well as periodically evaluate each pipeline segment by analyzing all available information about the integrity of the entire pipeline, and its relevance to segments that could affect the high consequence areas. RSPA will soon publish a proposed rule to require operators to develop integrity management programs for gas transmission pipelines that, in the event of a failure, could impact high consequence areas (HCAs). RSPA recently finalized the definition of high consequence areas for gas transmission pipelines in a separate rulemaking. The integrity management rule will require operators to comprehensively evaluate their pipelines and to take measures to protect pipeline segments located in high consequence areas. The rule will require these pipeline operators to assess, evaluate, repair and validate the integrity of onshore and offshore pipelines. Burial depth and cover requirements for both onshore and submerged pipelines must be considered as part of these comprehensive analyses and repairs. The proposed rule will satisfy the Congressional requirements for gas integrity management programs included in H.R. 3609. NPRM on Periodic Underwater Inspections RSPA has drafted and will soon publish a proposed rule in Docket RSPA-97-3001, Periodic Underwater Inspections, to require operators of gas and hazardous liquid pipelines to have procedures for periodic inspections of pipeline facilities in offshore waters less than 15 feet deep or crossing under a navigable waterway. These inspections would ensure that the pipeline is not exposed or a hazard to navigation. RSPA proposes that owners and operators of these underwater pipeline facilities be required to develop procedures to conduct periodic underwater depth of burial inspections of their submerged pipeline. The procedures would assess the risk of the pipeline becoming exposed or a hazard to navigation by taking into account the particular dynamics of the water bottom, including the probability of flotation, scour, erosion, and the impacts of major storms. Reburial or additional protection for exposed pipelines is already required by the pipeline safety regulations. The rule would also establish a timetable for inspection of underwater pipelines based on the risk analysis. A final rule is expected to be issued in early 2003. Action Requested: RSPA requests that Safety Recommendation P-90-29 be classified as "Closed - Acceptable Action" based on the initiatives 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 3/98 - Texas R&M University report, Analysis of Pipeline Burial Surveys in the Gulf of Mexico 12/00 - Final Rule to require integrity management programs for large hazardous liquid pipelines (65 FR 75377) 1/02 - Final Rule to require integrity management programs for smaller hazardous liquid pipelines (67 FR 2 136) 8/02 - Final Rule defining HCAs for gas transmission pipelines (67 FR 50824) 12/03 - NPRM to require all operators to have procedures for periodic inspections of pipelines in navigable waters (68 FR 69368) 12/03 - Final Rule revising HCA definition and requiring IMP for gas transmission pipelines in HCAs (68 FR 69778) Periodic Underwater Inspections RSPA recently published a proposed rule (68 FR 69368), Periodic Underwater Inspections, to require operators of gas and hazardous liquid pipelines to have procedures for periodic inspections of pipeline facilities in offshore waters less than 15 feet deep or crossing under a navigable waterway. These inspections would ensure that the pipeline is not exposed or a hazard to navigation. RSPA proposes that owners and operators of these underwater pipeline facilities be required to develop procedures to conduct periodic underwater depth of burial inspections of their submerged pipeline. The procedures would assess the risk of the pipeline becoming exposed or a hazard to navigation by taking into account the particular dynamics of the water bottom, including the probability of flotation, scour, erosion, and the impacts of major storms. Reburial or additional protection for exposed pipelines is already required by the pipeline safety regulations. The rule would also establish a timetable for inspection of underwater pipelines based on the risk analysis. A final rule is forthcoming. Integrity Management Programs to Detect Damage to Submerged Pipelines RSPA issued a final rule (65 FR 75377) on December 1,2000, that requires pipeline operators to develop and implement integrity management programs for hazardous liquid pipelines. The rule applies to pipelines that affect a high consequence area, including commercially navigable waterways. Submerged pipelines could affect unusually sensitive environmental areas (USAs) and commercially navigable waterways. Pipeline operators must consider the risk to submerged pipelines of damage by surface vessel operations in developing their integrity management programs. The rule specifies how operators must provide additional protection to critical areas (i.e., high consequence areas) through integrity management programs. Further, it ensures that these protections will be put in place, with an operator being required to initially assess 50 percent of the pipeline mileage that could affect critical areas, beginning with the highest risk pipe, within 3.5 years and the balance within seven years. An operator will then have to evaluate and repair defects within specified time frames and implement additional preventive and mitigation measures. RSPA requests that Safety Recommendation P-90-29 be classified as "CLOSED - Acceptable Action" based on the initiatives described above.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2007-10-25

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 4/2/2008 10:21:12 AM MC# 2070617: This letter is in response to your October 25, 2007, letter concerning low-flying aircraft towing advertisement banners over congested highways. I appreciate the insight you offered regarding low-flying aircraR in your community. As you may know, the National Transportation Safety Board is an independent Federal agency mandated by an act of the U.S. Congress to investigate transportation accidents, determine the probable cause(s) thereof, and make recommendations to prevent future accidents. The Federal Aviation Administration (FAA) can best answer your concerns because that agency issues and enforces rules concerning the operation of aircraft. You can contact the FAA directly at the following address:

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-02-07

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 4/2/2008 10:54:38 AM MC# 2080163: This letter provides an updated response and requests the National Transportation Safety Board (NTSB) close Safety Recommendation P-90-29. Safety Recommendation P-90-29 recommends PHMSA develop submerged pipeline inspection and reburial requirements in areas subject to damage by surface vessels and their operations. On August 17,2004, PHMSA notified the NTSB that a final rule requiring periodic inspections had been published in the Federal Register. The final rule became effective August 10,2005. The final rule requires operators of hazardous liquid and natural gas pipelines to prepare and follow procedures to identify their pipelines in the Gulf of Mexico that are at risk of being a hazard to navigation. Each operator is required to conduct periodic inspections of these lines based on the identified risk. The NTSB responded with a letter dated December 20,2004 expressing concern the rule did not include the offshore pipelines in areas other than the Gulf of Mexico. NTSB asked us to conduct further studies of offshore pipelines outside the Gulf of Mexico, to determine if these lines posed hazards to navigation. Accordingly, PHMSA further examined reports of all offshore pipeline incidents within the 15-foot depth contour line. The study involved four areas of investigation: (1) Review the extent of incidents in coastal states involving vessels striking pipelines; (2) Review of Coastal Zone Management Programs and the USACE permitting process for the applicability of requirements to inspect underwater pipelines; (3) Review of six data sources within PHMSA and the USCG for vessel incidents involving pipeline hazards to navigation and pipeline incidents involving vessels or their equipment; and (4) Determination of the applicable area of the study, including the inland extent of tidal influence. Defining the study area included calculating the mileage of pipelines within the area of concern. The study only examined pipelines subject to PHMSA regulatory requirements. Enclosed is the final report, "Study on Burial of Submerged Pipelines," dated November 30,2006. According to the study, there were 58 reported instances of a vessel or its equipment striking an offshore submerged pipeline and 64 reported instances of a submerged pipeline hazard to navigation between 1990 and 2005. All incidents occurred in the Gulf of Mexico. Seeking any further information on experiences with offshore pipelines which may have been missing from the study data, PHMSA notified the public of the results of the study through a Federal Register notice with request for comment published April 4,2007. PHMSA did not receive any fbrther information or comment on the study. PHMSA anticipates there will be changes in the number of pipelines in the offshore environment resulting from the projected increase of Liquefied Natural Gas (LNG) import facilities. PHMSA will work with the Federal Energy Regulatory Commission (FERC) and other oversight agencies on a case-by-case basis to develop safety measures that should be considered prior to granting permits for right-of-ways in the offshore shallow waters. PHMSA regularly provides pre-siting safety reviews for permitting agencies. There have been instances in the past where FERC has added conditions to approval for a permit based on PHMSA advice on the need for additional protections that are site specific. PHMSA will also continue to monitor the hazard to navigation risk for all submerged LNG, natural gas, and hazardous liquid pipelines and to seek ways to ensure their adequate protection. PHMSA requests the NTSB classify Safety Recommendation P-90-29 as "Closed-Acceptable Action." If you have questions, please feel free to contact me at (202) 366-4433.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-08-17

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 8/20/2004 2:47:26 PM MC# 2040523 This is the Research and Special Programs Administration's (RSPA) updated response to the National Transportation Safety Board (NTSB) Safety Recommendation P-90-29, which urges development of requirements for inspection and reburial of submerged pipelines in areas subject to damage by vessels. In response to this recommendation, a final rule requiring periodic underwater inspection was published in the Federal Register on August 10, 2004 (69 FR 48400). A copy is enclosed. This rule amends the pipeline safety regulations to require operators of gas and hazardous liquid pipelines to prepare and follow procedures for periodic inspections of pipeline facilities located in the Gulf of Mexico and its inlets in waters less than 15 feet deep. These inspections will inform the operator if the pipeline is exposed or a hazard to navigation and help to target pipeline reburial and protection measures. RSPA requests that this recommendation be classified as "CLOSED - Acceptable Action" based on the publication of the final rule. If we can be of further assistance, please contact me or James Wiggins, Director of Policy and Program Support, at (202) 366-4831.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2007-07-31

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 8/8/2007 2:24:08 PM MC# 2070395: In 2004, PHMSA published a final rule requiring periodic underwater inspection on August 10, 2004. PHMSA submitted a letter to NTSB requesting closure. NTSB responded by encouraging PHMSA to conduct further studies on risks associated with offshore areas. PHMSA recently completed a study on the risks of exposed pipelines and possible hazards to navigation in offshore waters other than the Gulf of Mexico and its inlets. The results show 58 reported instances of a vessel or its equipment striking a pipeline offshore since 1990. All incidents were in the Gulf of Mexico, where regulation requires the periodic underwater inspections program. On April 30, PHMSA issued a 30-day notice seeking public comment on the adequacy of the study and received no comments. We will submit a closure letter to the NTSB within the next 60-90 days.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-07-08

Communication Type: Official Correspondence

Communication Contents: On June 30, the Pipeline Technical Advisory Committees voted unanimously that the proposals in the Notice of Proposed Rulemaking - "Pipeline Safety: Underwater Periodic Inspections" - are technically feasible, reasonable, cost-effective, and practicable with the following changes: 1. Clarify that operators can use engineering methods to protect the pipeline as an alternative to reburial. 2. Provide a notification process in the event the operator encounters delays in obtaining the necessary State and Federal environmental permits. 3. Clarify the notice to ensure that operators use a risk-based approach to the periodic inspections. The Committee also recommended that RSPA/OPS publish a Notice requesting additional data concerning the risks associated with exposure and hazards to navigation for offshore pipelines other than the Gulf of Mexico and its inlets. The Advisory Committees members will review the status other offshore areas on subsequent agenda for the advisory committee meetings. The next step is for RSPA/OPS to review the comments and recommendations received from the Committee and complete and publish its Final Rule. Anticipate publication of the Final Rule by the end of this month.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-07-01

Communication Type: Official Correspondence

Communication Contents: RSPA CONTRACTED WITH TEXAS A&M UNIVERSITY TO CONDUCT A STUDY OF UNDERWATER INSPECTION OF OFFSHORE PIPELINES. THIS STUDY, COMPLETED IN JANUARY 1998, EVALUATED THE GULF OF MEXICO TO DETERMINE IF PIPELINE DEPTH AND CONDITION CONSTITUTE A HAZARD TO NAVIGATION. THE STUDY CONCLUDED THAT THE CURRENT SURVEY TECHNIQUES USING SUB-BOTTOM PROFILING SONAR, GARDIOMETER ARRAYS, OR DIVERS ARE EFFECTIVE WHEN USED UNDER APPROPRIATE CONDITIONS AND THAT THE ADVANCES IN INTELLIGENT PIG TECHNOLOGY HAVE THE POTENTIAL TO IMPROVE THE QUALITY OF EFFICIENCY OF FUTURE SURVEYS. THE STUDY RECOMMENDED THAT RSPA PROCEED WITH REGULATIONS TO REQUIRE PIPELINE DEPTH OF BURIAL INSPECTIONS AND REBURIAL AND RECOMMENDS THAT RSPA USE RISK ANALYSIS TO DETERMINE THE PERIODICITY OF FUTURE SURVEYS. THE STUDY FURTHER RECOMMENDED THAT RSPA REQUIRE OPERATORS TO MAINTAIN PIPELINES THREE FEET BELOW THE NATURAL BOTTOM WITH SOIL OR SOLID MATERIAL COVER FOR PROTECTION FROM VESSEL GROUNDING, ANCHOR, AND NET HAZARDS AND THAT A MANDATORY "ONE CALL" SYSTEM BE DEVELOPED FOR MARINE PIPELINES. RSPA IS DRAFTING A NOTICE OF PROPOSED RULEMAKING WHICH WILL INCORPORATE THESE RECOMMENDATIONS. RSPA REQUESTS THAT P-90-29 CONTINUE TO BE CLASSIFIED AS "OPEN--ACCEPTABLE ACTION" UNTIL THE RULEMAKING DESCRIBED 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: 2005-02-28

Communication Type: Official Correspondence

Communication Contents: In its 2/28/2005 report to Congress, "Open Statutory Mandates Regarding Pipeline and Hazardous Materials Safety," the DOT wrote: Study completed in January 1998. Final rule published on August 10, 2004. Close-out letter dated August 17, 2004 is at NTSB for review.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-04-09

Communication Type: Official Correspondence

Communication Contents: INITIALLY, RSPA HAD INTENDED TO INCLUDE ALL OFFSHORE PIPELINES IN THE NPRM, NOT JUST THOSE IN THE GULF OF MEXICO AND ITS INLETS. HOWEVER, THE TECHNICAL PIPELINE SAFETY STANDARDS COMMITTEE AND THE TECHNICAL HAZARDOUS LIQUID PIPELINE SAFETY STANDARDS COMMITTEE UNANIMOUSLY RECOMMENDED THAT THE RSPA'S NRPM COVER ONLY THE IMMEDIATE REQUIREMENTS OF PL 101-599 AND ADDRESS OTHER OFFSHORE PROPOSALS IN A FUTURE RULEMAKING.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2006-04-14

Communication Type: Official Correspondence

Communication Contents: In its 4/14/2006 report to Congress, "National Transportation Safety Board (NTSB) and DOT Office of Inspector General (OIG): Open Safety Recommendations on Pipeline and Hazardous Materials Safety," DOT indicated: PHMSA published a final rule requiring periodic underwater inspection on August 10, 2004. PHMSA submitted a letter to NTSB requesting closure. NTSB responded by encouraging PHMSA to conduct further studies on risks associated with offshore areas. PHMSA will study offshore concerns in the first half of 2006.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2000-04-24

Communication Type: Official Correspondence

Communication Contents: Pipeline Integrity Management: 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 Hyat
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