NTSB Safety Recommendation P-91-001

NTSB safety recommendation P-91-001.

THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: DEFINE THE OPERATING PARAMETERS THAT MUST BE MONITORED BY PIPELINE OPERATORS TO DETECT ABNORMAL OPERATIONS AND ESTABLISH PERFORMANCE STANDARDS THAT MUST BE MET BY PIPELINE MONITORING SYSTEMS INSTALLED TO DETECT AND LOCATE LEAKS.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1991-07-17

Adopted Date: 1991-06-11

Overall Date Closed: 2004-04-21

Synopsis: ON MARCH 13, 1990, THE TEXAS EASTERN PRODUCTS PIPELINE COMPANY (TEPPCO) LINE P-41, AN 8-INCH-DIAMETE LIQUID PROPANE PIPELINE, RUPTURED WITHIN A PIPELINE CASING BENEATH COUNTY ROAD 43 (CR 43) NEAR THE VILLAGE OF NORTH BLENHEIM, NEW YORK. LIQUID PROPANE GAS ESCAPED FROM THE ENDS OF THE CASING, VAPORIZED, AND FORMED A WHITE, HEAVIER-THAN-AIR GAS CLOUD. THE GAS CLOUD FLOWED DOWNHILL ALONG CR 43 UNTIL IT ENTERED NORTH BLENHEIM AND IGNITED. THE FIRE QUICKLY CONSUMED THE PROPANE VAPOR AND FLASHED BACK TO THE PIPELINE RUPTURE, TWO PEOPLE WERE KILLED, SEVEN PERSONS INJURED AND MORE THAN $4 MILLION IN PROPERTY DAMAGE AND OTHER COSTS RESULTED.

Probable Cause: None

Ntsbnumber: DCA90MP006

Report Number: PAR-91-01

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: 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 UNDERSTANDS THAT RSPA WILL SOON ISSUE A FINAL RULE INCORPORATING THE INDUSTRY STANDARD FOR LEAK DETECTION CONTAINED IN THE AMERICAN PETROLEUM INSTITUTE'S (API'S) COMPUTATIONAL PIPELINE MONITORING (API 1130) DOCUMENT. HOWEVER, THIS STANDARD ONLY APPLIES TO SYSTEMS THAT CURRENTLY EXIST. IF NO SYSTEM IS ALREADY IN PLACE, OPERATORS WILL NOT YET BE REQUIRED TO INSTALL ONE. ACCORDINGLY, BECAUSE RSPA HAS INDICATED THAT IT HAS NOT YET REQUIRED OPERATORS TO INSTALL SUCH SYSTEMS, PENDING THE PUBLICATION OF A REQUIREMENT TO INSTALL SYSTEMS, P-91-1 HAS BEEN CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-02-03

Communication Type: Official Correspondence

Communication Contents: Your letter provides a comprehensive review of RSPA's previous actions and addresses its progress with respect to the new integrity management rulemakings, the protocols for inspecting leak detection systems, the Broad Area Announcement (BAA) for research projects, and the System Control and Data Acquisition (SCADA) training program. The Safety Board appreciates this update and encourages RSPA to complete the final regulations on this issue, especially in consideration of the age of this recommendation. Pending publication of a final rule on this issue, Safety Recommendation P-91-1 is classified "Open--Acceptable Response" in recognition of the extensive research conducted on this issue.

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 to require natural gas transmission and hazardous liquid pipeline operators to initiate and follow a pipeline integrity management program for HCAs and to evaluate the entire pipeline for lessons learned in HCAs that should be applied beyond HCAs. The rules require that each hazardous liquid pipeline operator have a means to detect leaks on its pipeline system. An operator must evaluate the capability of its leak detection systems and modify them as necessary to protect HCAs, based on a risk analysis of threats to the pipeline. Operators of gas transmission pipelines are also required to take additional measures to protect their pipelines in HCAs. Because these final regulations satisfy the recommendation, Safety Recommendation P-91-1 is classified "Closed--Acceptable Action."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-12-30

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 01/09/2003 4:48:48 PM MC# 2030033 Since our last update, RSPA has tnade significant progress in completing a series of rulemakings to require natural gas transmission and hazardous liquid pipeline operators to initiate and follow a pipeline integrity management program (IMP) for high consequence areas (HCA), including areas unusually sensitive to environmental damage (USA) in the event of a hazardous liquid release. The rules require that each operator have a means to detect leaks on its pipeline system. An operator must evaluate the capability of its leak detection systems and modify them to protect high consequence areas. At a minimum, an operator’s evaluation must consider the following factors: the length and size of the pipeline; the type of product carried; the pipeline’s proximity to the high consequence area; the swiftness of leak detection; the location of the nearest response personnel; the leak history; and, the risk assessment results.Integrity Management Protocols RSPA’s enforcement approach encourages and monitors continuous improvement in operator compliance with the rule’s provisions, particularly related to leak detection capability. Beginning in summer 2002, RSPA inspectors began comprehensive reviews of the integrity management programs of hazardous liquid pipelines in US4s. The inspection effort is very extensive, and requires larger inspection teams of Federal and State inspectors for one or two weeks with each company. The inspectors use our recently finalized integrity management inspection protocols. The protocols provide detailed direction to the inspector to determine the adequacy of an operator’s decision process based on specific criteria and parameters and to thoroughly document the progress the operator has made. Protocols form the basis for consistent enforcement actions to correct any deficiencies. These include questions on leak detection system capabilities, the factors to be considered when evaluating leak detection systems, the effectiveness of leak detection, and leak detection response times. The protocols are publicly available and are used by operators to help achieve compliance, creating a standard method to review leak detection system operating parameters. We update the protocols on an ongoing basis with the results of research and experience. Research and Development RSPA has awarded seven research contracts to address pipeline damage prevention and leak detection solutions. These awards implement the first phase of RSPA’s new competitive pipeline safety research partnership with universities, independent research organizations, and both the oil and natural gas industries. The Department of Transportation’s award provides approximately 50 percent of funding equal to $1.6 million, for partnerships totaling $3.4 million. We believe this leveraged funding from multiple interests will produce a wide range of research and stimulate the market with beneficial technologies two to three years sooner than would have otherwise been possible. The projects awarded to date address in-line inspection and alternatives to in-line inspection for unpiggable pipelines, digital mapping, and technologies to better detect corrosion, mechanical damage, pipeline wall stress, and leak detection. In an effort to establish performance standards for leak detection systems, we are sponsoring ongoing research by the General Physics Corporation. Under this contract they have completed an analysis of the leak detection aspects of the existing integrity management inspection protocols mentioned above. In a second phase, they will conduct additional analysis to improve leak detection program evaluations during integrity management inspections. In addition, we are funding research by LaSen, Inc. to develop an airborne laser- based sensor system for detecting pipeline leaks. We are continuing this funding over the next two years to achieve commercial deployment of this powerful pipeline leak detection technology. In a third Broad Agency Agreement to be advertised next month, we will put a renewed emphasis on leak detection proposals. SCADA Training Program To provide a better understanding of various methods and means to detect leaks, RSPA is improving its guidance for inspectors in the area of control, operations integrity, and security, and has developed a SCADA training program required for Federal and State integrity Management Program (IMP) inspectors. The course provides inspectors with a knowledge of the basic design, installation, operation, and maintenance of station equipment and protective systems, and how to identify and evaluate SCADA monitors and controls, The course enables IMP pipeline safety inspectors to recognize leak detection features and performance of SCADA systems and to evaluate the adequacy of the leak detection features of the systems. Action Requested: RSPA requests that Safety Recommendation P-91- 1 be classified as "Closed - Acceptable Action" based on the programs 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 9/96 - "Remote Control Spill Reduction Technology: A Survey and Analysis of Applications for Liquid Pipeline Systems," Volpe National Transportation Systems Center (VNTSC) 7/98 -Final Rule adopting API 1130 standard for computational pipeline monitoring leak detection systems (63 FR 36373) 12100 -Final Rule requiring integrity management programs (IMP) for large hazardous liquid pipelines in high consequence areas (HCA) (65 FR 75378) 2001 - Transportation Safety Institute (TSI) SCADA training for inspectors; updated Operations and Maintenance Inspection Manual 1/02 -Final Rule on integrity management programs for small hazardous liquid pipelines in HCAs (67FR 1108) 8/02 -Final rule defining HCAs for gas transmission pipelines (67 FR 50824) 12/03 -Final Rule revising HCA definition & requiring IMP for gas transmission pipelines in HCAs (68 FR 69778) Integrity Management Rules on Detecting Abnormal Operations and Leak Detection Since our last update, RSPA completed a series of rulemakings to require natural gas transmission and hazardous liquid pipeline operators to initiate and follow a pipeline 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 rules require that each hazardous liquid pipeline operator have a means to detect leaks on its pipeline system. An operator must evaluate the capability of its leak detection systems and modify them as necessary to protect high consequence areas. At a minimum, an operator's evaluation must consider the following factors: the length and size of the pipeline; the type of product carried; the pipeline's proximity to the high consequence area; the swiftness of leak detection; the location of the nearest response personnel; the leak history; and, the risk assessment results. Operators of gas transmission pipelines are also required to take additional measures to protect their pipelines in high consequence areas, such as installing computerized monitoring and leak detection systems. The actions an operator takes must be based on a risk analysis of the threats to which its pipeline is subjected. Integrity Management Protocols on Leak Detection RSPA's enforcement approach encourages and monitors continuous improvement in operator compliance with the rule's provisions, particularly for leak detection capability. In summer 2002, RSPA inspectors began comprehensive reviews of the integrity management programs of hazardous liquid pipelines in HCAs. The inspection effort is very extensive, and requires large inspection teams of Federal and State inspectors for one or two weeks at each company. The inspectors use written integrity management inspection protocols. The protocols provide detailed direction to the inspector to determine the adequacy of an operator's decision process based on specific criteria and parameters and to thoroughly document the progress the operator has made. Protocols form the basis for consistent enforcement actions to correct any deficiencies. These include questions on leak detection system capabilities, the factors to be considered when evaluating leak detection systems, the effectiveness of leak detection, and leak detection response times. The protocols are publicly available and are used by operators to help achieve compliance, creating a standard method to review leak detection system operating parameters. We update the protocols on an ongoing basis to reflect research and experience. RSPA intends to use the same approach to inspection and enforcement of the integrity management rule for gas transmission pipelines. Inspection protocols for that rule are now being developed. Research and Development RSPA has awarded seven research contracts to address pipeline damage prevention and leak detection solutions. These awards implement the first phase of RSPA's new competitive pipeline safety research partnership with universities, independent research organizations, and both the oil and natural gas industries. The Department of Transportation's award is approximately 50 percent of funding equal to $1.6 million, for partnerships totaling $3.4 million. We believe this leveraged funding from multiple interests will produce a wide range of research and stimulate the market with beneficial technologies two to three years sooner than would have otherwise been possible. The projects awarded to date address in-line inspection and alternatives to in-line inspection for unpiggable pipelines, digital mapping, and technologies to better detect corrosion, mechanical damage, pipeline wall stress, and leak detection. In an effort to establish performance standards for leak detection systems, we are sponsoring ongoing research by the General Physics Corporation. Under this contract they have completed an analysis of the leak detection aspects of the existing integrity management inspection protocols. In a second phase, they will conduct additional analysis to improve leak detection program evaluations during integrity management inspections. In addition, we are funding research by LaSen, inc. to develop an airborne laser-based sensor system for detecting pipeline leaks. We are continuing this funding over the next two years to achieve commercial deployment of this powerful pipeline leak detection technology. In a third Broad Agency Agreement we placed renewed emphasis on leak detection proposals. SCADA Training Program To provide a better understanding of various ways to detect leaks, RSPA is improving its guidance for inspectors in the area of control, operations integrity, and security, and has developed a SCADA training program required for Federal and State Integrity Management Program (IMP) inspectors. The course provides inspectors with knowledge about basic design, installation, operation, and maintenance of station equipment and protective systems, and how to identify and evaluate SCADA monitors and controls. The course enables IMP pipeline safety inspectors to recognize leak detection features and performance of SCADA systems and to evaluate the adequacy of the leak detection features of the systems. RSPA requests that Safety Recommendation P-91-1 be classified as "CLOSED - Acceptable Action" based on the programs described above.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1991-10-18

Communication Type: Official Correspondence

Communication Contents: IN FY 1992, THE RSPA PLANS TO BEGIN A 2-YEAR STUDY OF SCADA SYSTEMS AND SCADA-BASED LEAK DETECTION SYSTEMS TO SEE IF THEY SHOULD BE REQUIRED ON GAS AND HAZARDOUS LIQUID PIPELINES. THIS STATE-OF-THE-ART STUDY WILL INCLUDE AN INVESTIGATION AND ANALYSIS OF THE VARIOUS SCADA SYSTEM AND SCADA-BASED LEAK DETECTION CURRENTLY AVAILABLE FOR USE TO DETECT LEAKS IN GAS AND HAZARDOUS LIQUID PIPELINES.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1992-09-02

Communication Type: Official Correspondence

Communication Contents: SCADA STUDY TO BE COMPLETED BY END OF 1993.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-07-01

Communication Type: Official Correspondence

Communication Contents: RSPA WILL SOON ISSUE A FINAL RULE TO ADOPT AS A REFERENCED DOCUMENT AN INDUSTRY PUBLICATION FOR LEAK DETECTION, API 1130, COMPTUATIONAL PIPELINE MONITORING, PUBLISHED BY THE AMERICAN PETROLEUM INSTITUTE (API). API 1130 IS A COMPREHENSIVE DOCUMENT CONTAINING: (1) DESCRIPTIONS OF THE SOFTWARE-BASED COMPUTATIONAL PIPELINE MONITORING (CPM) SYSTEMS IN USE TODAY; (2) OPERATING PRACTICE IN THE DESIGN AND MAINTENANCE OF THE FIELD INSTRUMENTATION NECESSARY TO ADEQUATELY SUPPORT A CPM SYSTEM; (3) SCADA SYSTEM DESIGN FACTORS THAT CAN IMPACT THE QUALITY AND TIMELINESS OF THE DATA REQUIRED BY A CPM SYSTEM; (4) STANDARDS FOR THE OPERATION, MAINTENANCE, AND TESTING OF THE CPM SYSTEM; AND (5) STANDARDS FOR PIPELINE DISPATCHER TRAINING. THIS FINAL RULE WILL REQUIRE OPERATORS OF HAZARDOUS LIQUID PIPELINES TO USE API 1130 IN CONJUNCTION WITH OTHER INFORMATION IN THE DESIGN, EVALUATION, OPERATION, MAINTENANCE AND TESTING OF SOFTWARE-BASED LEAK DETECTION SYSTEMS, WHICH WILL RESULT IN A SIGNIFICANT ADVANCE IN THE ACCEPTANCE OF LEAK DETECTION TECHNOLOGY ON HAZARDOUS LIQUID PIPELINES. HOWEVER, RSPA IS NOT, AT THIS TIME, MANDATING THAT OPERATORS INSTALL SUCH SYSTEMS. RSPA REQUESTS THAT P-91-1 BE RECLASSIFIED AS "CLOSED--ACCEPTABLE ACTION."

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, expecially 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: 1991-12-20

Communication Type: Official Correspondence