NTSB Safety Recommendation P-93-009

NTSB safety recommendation P-93-009.

THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: DEVELOP SAFETY REQUIREMENTS FOR STORAGE OF HIGHLY VOLATILE LIQUIDS AND NATURAL GAS IN UNDERGROUND FACILITIES, INCLUDING A REQUIREMENT THAT ALL PIPELINE OPERATORS PERFORM SAFETY ANALYSES OF NEW AND EXISTING UNDERGROUND GEOLOGIC STORAGE SYSTEMS TO IDENTIFY POTENTIAL FAILURES, DETERMINE THE LIKELIHOOD THAT EACH FAILURE WILL OCCUR, AND ASSES HE FEASIBILITY OF REDUCING THE RISK; REQUIRE THAT OPERATORS INCORPORATE ALL FEASIBLE IMPROVEMENTS.

Priority: CLASS II

Overall Status: Closed - Unacceptable Action

Issued Date: 1993-12-15

Adopted Date: 1993-11-04

Overall Date Closed: 1998-07-27

Synopsis: ON APRIL 7, 1992, AN UNCONTROLLED RELEASE OF HIGHLY VOLATILE LIQUIDS (HVLS) FROM A SALT DOME STORAGE CAVERN IN THE SEMINOLE PIPELINE SYSTEM NEAR BRENHAM, TEXAS, FORMED A LARGE, HEAVIER-THAN-AIR GAS CLOUD THAT EXPLODED. THREE PEOPLE DIED FROM INJURIES SUSTAINED EITHER FROM THE BLAST OR IN THE FIRE. AN ADDITIONAL 21 PEOPLE WERE TREATED FOR INJURIES AT AREA HOSPITALS. DAMAGE FROM THE ACCIDENT EXCEEDED $9 MILLION.

Probable Cause: None

Ntsbnumber: DCA92MP006

Report Number: PAR-93-01

Addressee Name: RSPA

Addressee Status: Closed - Unacceptable Action

Addressee Date Closed: 1998-07-27

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2011-12-07

Communication Type: NPRM Response

Communication Contents: Notation 8360: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) Advance Notice of Proposed Rulemaking (ANPRM), “Pipeline Safety: Safety of Gas Transmission Pipelines,” that was published in the Federal Register on August 25, 2011. PHMSA is considering whether changes to the regulations governing the safety of gas transmission pipelines are needed, and is inviting comments on 14 specific topic areas in 2 broad categories—integrity management-related requirements and nonintegrity management requirements. In the area of integrity management, PHMSA is seeking comments and information about revising the definition of high consequence areas (HCA), including more prescriptive language, and placing additional restrictions on the use of specific pipeline assessment methods. In the nonintegrity management area, PHMSA is seeking information and comments about strengthening or expanding requirements for the spacing of mainline valves; installation of remotely operated or automatically operated valves; and corrosion control of steel pipelines, gas gathering lines, and underground gas storage facilities. The NTSB believes that the regulations for gas transmission pipelines can and should be improved and supports the overall intent of the ANPRM. However, the publication of the ANPRM 5 days before the NTSB public meeting on the Pacific Gas and Electric Company (PG&E) natural gas transmission pipeline rupture in San Bruno, California, precluded any mention in the ANPRM of the safety recommendations the NTSB adopted at the public meeting held on August 30, 2011, and issued on September 26, 2011. As a result of the Board Meeting, the NTSB issued 13 safety recommendations (P-11-8 through P-11-20) to PHMSA to improve the safety of natural gas transmission pipelines. The NTSB believes PHMSA should seek comments and information related to its safety recommendations to PHMSA issued as a result of the San Bruno investigation to take certain regulatory actions. In the ANPRM, PHMSA is also seeking information that would be relevant to Safety Recommendation P-93-9 the NTSB issued as a result of its accident investigation of an explosion and fire of a natural gas pipeline from a salt dome storage cavern in Brenham, Texas, on April 7, 1992. The accident resulted in 3 fatalities and 21 injuries. Safety Recommendation P-93-9 was classified “Closed—Unacceptable Action” on July 27, 1998, after a rulemaking proceeding to regulate underground gas storage was terminated in 1997. The NTSB supports PHMSA’s intention to reconsider regulating underground gas storage and is pleased PHMSA is revisiting this issue by seeking information and comment in this ANPRM. In support of our position, the NTSB is providing the following table listing the NTSB’s responses (that is, previously issued safety recommendations) to certain specific questions posed by PHMSA in the ANPRM: PHMSA’s ANPRM Questions NTSB’s Responses (Safety Recommendations) K.1. Should PHMSA develop Federal standards governing the safety of underground gas storage facilities? If so, should they be voluntary? If so, what portions of the facilities should be addressed in these standards? Develop safety requirements for storage of highly volatile liquids and natural gas in underground facilities, including a requirement that all pipeline operators perform safety analyses of new and existing underground geologic storage systems to identify potential failures, determine the likelihood that each failure will occur, and assess the feasibility of reducing the risk; require that operators incorporate all feasible improvements. (P-93-9) K.6. What standards are used for emergency shutdowns, emergency shutdown stations, gas monitors, local emergency response communications, public communications, and O&M Procedures? Require operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to provide system-specific information about their pipeline systems to the emergency response agencies of the communities and jurisdictions in which those pipelines are located. This information should include pipe diameter, operating pressure, product transported, and potential impact radius. (P-11-8) L.1. Are there standards used by the pipeline industry to guide management processes including management of change? Do standards governing the management of change process include requirements for IM procedures, O&M manuals, facility drawings, emergency response plans and procedures, and documents required to be maintained for the life of the pipeline? Require operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to ensure that their control room operators immediately and directly notify the 911 emergency call center(s) for the communities and jurisdictions in which those pipelines are located when a possible rupture of any pipeline is indicated. (P-11-9) PHMSA’s ANPRM Questions NTSB’s Responses (Safety Recommendations) B.4. What measures, if any, should operators be required explicitly to implement? Should they apply to all HCAs, or is there some reasonable basis for tailoring explicit mandates to particular HCAs? Should additional preventative and mitigative measures include any or all of the following: Additional line markers (line-of-sight); depth of cover surveys; close interval surveys for cathodic protection (CP) verification; coating surveys and recoating to help maintain CP current to pipe; additional right-of-way patrols; shorter ILI run intervals; additional gas quality monitoring, sampling, and in-line inspection tool runs; and improved standards for marking pipelines for operator construction and maintenance and one-calls? Require that all operators of natural gas transmission and distribution pipelines equip their supervisory control and data acquisition systems with tools to assist in recognizing and pinpointing the location of leaks, including line breaks; such tools could include a real-time leak detection system and appropriately spaced flow and pressure transmitters along covered transmission lines. (P-11-10) Amend Title 49 Code of Federal Regulations 192.935(c) to directly require that automatic shutoff valves or remote control valves in high consequence areas and in class 3 and 4 locations be installed and spaced at intervals that consider the factors listed in that regulation. (P-11-11) M.4. Are there any standards that exist that PHMSA could adopt or from which PHMSA could adapt concepts for Quality Management System (QMS)? Amend Title 49 Code of Federal Regulations 199.105 and 49 Code of Federal Regulations 199.225 to eliminate operator discretion with regard to testing of covered employees. The revised language should require drug and alcohol testing of each employee whose performance either contributed to the accident or cannot be completely discounted as a contributing factor to the accident. (P-11-12) Issue immediate guidance clarifying the need to conduct postaccident drug and alcohol testing of all potentially involved personnel despite uncertainty about the circumstances of the accident. (P-11-13) N.2. Should PHMSA repeal the MAOP exemption for pre-1970 pipelines? Should pre-1970 pipelines that operate above 72% SMYS be allowed to continue to be operated at these levels without increased safety evaluations such as periodic pressure tests, in-line inspections, coating examination, CP surveys, and expanded requirements on interference currents and depth of cover maintenance? N.3. Should PHMSA take any other actions with respect to exempt pipelines? Amend Title 49 Code of Federal Regulations 192.619 to delete the grandfather clause and require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. (P-

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-06-06

Communication Type: NPRM Response

Communication Contents: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) notice of proposed rulemaking (NPRM), Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines, published on April 8, 2016. This NPRM addresses issues raised in an August 25, 2011, advance notice of proposed rulemaking (ANPRM) regarding the revision of pipeline safety regulations applicable to the safety of gas transmission and gas gathering pipelines, particularly those involving integrity management (IM). Proposal Topic K—Establishing Requirements Applicable to Underground Gas Storage Summary PHMSA is deferring action on this topic at this time. PHMSA stated that it intends to propose a separate rulemaking and will consider voluntary consensus standards and solicit feedback from stakeholders to inform the development of potential regulations. Response The NTSB first recommended underground gas storage regulations to PHMSA (then the Research and Special Programs Administration [RSPA]) in its investigation of the April 7, 1992, Mapco Natural Gas Liquids accident in Brenham, Texas. As a result of the investigation, the NTSB recommended that RSPA develop safety requirements for the storage of highly volatile liquids and natural gas in underground facilities. Develop safety requirements for storage of highly volatile liquids and natural gas in underground facilities, including a requirement that all pipeline operators perform safety analyses of new and existing underground geologic storage systems to identify potential failures, determine the likelihood that each failure will occur, and assess the feasibility of reducing the risk; require that operators incorporate all feasible improvements. (P-93-09) Unfortunately, the lack of action by the RSPA resulted in the NTSB classifying the recommendation as “Closed—Unacceptable Action” on July 27, 1998. Most recently, the underground storage facility at Aliso Canyon near Los Angeles, California, suffered a major gas well failure on October 23, 2015. It took more than 3 1/2 months, until February 18, 2016, to stop the release and permanently reseal the damaged well. More than 7,600 residents were forced to evacuate their homes and seek temporary residence at alternate locations until the well was sealed. The NTSB is disappointed that PHMSA continues to delay any action on regulating underground gas storage facilities. We urge PHMSA to expedite promulgating new regulations that will improve underground gas storage facility safety.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1994-04-25

Communication Type: Official Correspondence

Communication Contents: THE BOARD IS PLEASED TO LEARN THAT RSPA WILL CONDUCT A PUBLIC MEETING WITH INDUSTRY TRADE ASSOCIATIONS, STATE AGENCIES, OPERATORS OF UNDERGROUND STORAGE FACILITIES, & OTHER INTERESTED PARTIES TO IDENTIFY & DISCUSS THE SAFETY & ENVIRONMENTAL ISSUED OF UNDERGROUND STORGE. WE LOOK FORWARD TO PARTICIPATING IN THIS IMPORTANT MEETING & A DISCUSSION OF RSPA'S PLANS TO DEVELOP SAFETY REQUIREMENTS FOR UNDERGROUND STORAGE OF HIGHLY VOLATILE LIQUIDS. THE BOARD HAS CLASSIFIED P-93-9 AS "OPEN--ACCETABLE RESPONSE" PENDING ACTION TAKEN AS A RESULT OF THE FORTHCOMING MEETING.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-07-27

Communication Type: Official Correspondence

Communication Contents: THE BOARD ASKED RSPA TO DEVELOP SAFETY REQUIREMENTS FOR STORAGE OF HIGHLY VOLATILE LIQUIDS & NATURAL GAS IN UNDERGROUND FACILITIES, INCLUDING A REQUIREMENT THAT ALL PIPELINE OPERATORS PERFORM SAFETY ANALYSES OF NEW & EXISTING UNDERGROUND GEOLOGIC STORAGE SYSTEMS TO IDENTIFY POTENTIAL FAILURES, DETERMINE THE LIKELIHOOD THAT EACH FAILURE WILL OCCUR, & ASSESS THE FEASIBILITY OF REDUCING THE RISK; IT FURTHER URGED RSPA TO REQUIRE THAT OPERTORS INCORPORATE ALL FEASIBLE IMPROVEMENTS. THE BOARD IS DISAPPOINTED TO LEARN THAT ON 7/10/97, RSPA TERMINATED ITS RULEMAKING ADDRESSING THIS ISSUE. NONETHELESS, THE BOARD INTENDED THAT THE FEDERAL GOVERNMENT DEVELOP NATIONAL SAFETY REQUIREMENTS FOR STORAGE OF HIGHLY VOLATILE LIQUIDS & NATURAL GAS IN UNDERGROUND FACILITIES & NOT SHIFT THE RESPONSIBILITY TO STATE JURISDICTION. BECAUSE RSPA PLANS NO FURTHER ACTION & REQUESTS THAT THE RECOMMENDATION BE CLOSED, P-93-9 HAS BEEN CLASSIFIED "CLOSED--UNACCEPTABLE ACTION."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-03-11

Communication Type: Official Correspondence

Communication Contents: (Letter Mail Controlled 3/17/98 5:55:08 PM MC# 980349) IN 1994, RSPA INFORMED THE BOARD THAT IT WAS CONCERNED ABOUT THE SAFETY OF UNDERGROUND STORAGE FACILITIES & PLANNED TO CONDUCT PUBLIC MEETING WITH INDUSTRY TRADE ASSOCIATION, STATE AGENCIES, OPERATORS OF UNDERGROUND STORAGE FACILITIES, & OTHER INTERESTED PARTIES TO IDENTIFY & DISCUSS THE SAFETY & ENVIRONMENTAL ISSUES OF UNDERGROUND STORAGE. BECAUSE RSPA PLANS NO FURTHER ACTION & REQUESTS THAT THE RECOMMENDATION BE CLOSED.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1994-03-24

Communication Type: Official Correspondence

Communication Contents: OUR FIRST ACTION ON THIS ISSUE WILL BE CONDUCT A PUBLIC MEETING WITH INDUSTRY TRADE ASSOCIATIONS, STATE AGENCIES, OPERATORS OF UNDERGROUND STORAGE FACILITIES , & OTHER INTERESTED PARTIES OT IDENTIFY & DISCUSS THE SAFETY AND ENVIRONMENTAL ISSUES OF UNDERGROUND STORAGE.