NTSB Safety Recommendation P-95-001

NTSB safety recommendation P-95-001.

THE NTSB RECOMMENDS THAT THE RSPA: EXPEDITE REQUIREMENTS FOR INSTALLING AUTOMATIC- OR REMOTE-OPERATED MAINLINE VALVES ON HIGH-PRESSURE PIPELINES IN URBAN AND ENVIRONMENTALLY SENSITIVE AREAS TO PROVIDE FOR RAPID SHUTDOWN OF FAILED PIPELINE SEGMENTS. (Supersedes P-87-022)

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1995-02-07

Adopted Date: 1995-01-18

Overall Date Closed: 2004-04-21

Synopsis: ABOUT 11:55 ON 3/23/94, A 36-INCH DIAMETER PIPELINE OWNED AND OPERATED BY TEXAS EASTERN TRANSMISSION CORPORTION (TETCO) RUPTURED CATASTROPHICALLY IN EDISON TOWNSHIP, NEW JERSEY, WITHIN AN ASPHALT PLANT COMPOUND. THE FORCE OF THE RUPTURE AND OF NATURAL GAS ESCAPING AT A PRESSURE OF ABOUT 970 PSIG (POUNDS PER SQUARE INCH GUAGE) EXCAVATED THE SOIL AROUND THE PIPE AND BLEW GAS HUNDREDS OF FEET INTO THE AIR, PROPELLING PIPE FRAGMENTS, ROCKS, AND DEBRIS MORE THAN 800 FEET. WITHIN 1 TO 2 MINUTES OF THE RUPTURE, ONE OF SEVERAL POSSIBLE SOURCES IGNITED THE ESCAPING GAS, SENDING FLAMES UPWARD 400 TO 500 FEET IN THE AIR. HEAT RADIATING FROM THE MASSIVE FIRE IGNITED THE ROOFS OF SEVERAL BUILDING ROOFS IN A NEARBY APARTMENT COMPLEX. OCCUPANTS, ALERTED TO THE EMERGENCY BY NOISES FROM ESCAPING GAS AND ROCKS HITTING THE ROOFS, FLED FROM THE BURNING BUILDINGS. APPROXIMATELY 1,500 APARTMENT RESIDENTS WERE EVACUATED. MIRACULOUSLY, NO DEATHS DIRECTLY RESULTED FROM THE RUPTURE AND RESULTING FIRE. MOST INJURIES WERE MINOR FOOT BURNS AND CUTS THAT THE APARTMENT RESIDENTS SUSTAINED FROM THE HOT PAVEMENT & GLASS SHARDS AS THEY FLED THE COMPLEX. DAMAGE FROM THE ACCIDENT EXCEEDED 25 MILLION.

Probable Cause: None

Keywords: Remote Operated Valves

Ntsbnumber: DCA94MP001

Report Number: PAR-95-01

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: 2020-03-25

Communication Type: NPRM Response

Communication Contents: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) notice of proposed rulemaking (NPRM), Pipeline Safety: Valve Installation and Minimum Rupture Detection Standards, published on February 6, 2020. In this notice, PHMSA is proposing to “revise the Pipeline Safety Regulations applicable to newly constructed and entirely replaced onshore natural gas transmission and hazardous liquid pipelines to mitigate ruptures. Additionally, PHMSA is revising the regulations regarding rupture detection to shorten pipeline segment isolation times.” This NPRM responds to congressional mandates and recommendations from the NTSB. PHMSA states that this action is needed “to reduce the consequences of large-volume, uncontrolled releases of natural gas and hazardous liquid pipeline ruptures.” The NPRM references three open NTSB safety recommendations (P-11-9 through -11) that were issued to PHMSA as a result of our investigation of the September 9, 2010, rupture of a Pacific Gas and Electric Company natural gas pipeline and resulting fire in San Bruno, California. It also refers to an earlier closed safety recommendation (P-95-1) that was issued to PHMSA’s predecessor, the Research and Special Programs Administration (RSPA), as a result of our investigation of the March 23, 1994, natural gas pipeline explosion and fire in Edison, New Jersey. These safety recommendations are: 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) (Open—Acceptable Alternative Response) 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) (Open?Acceptable Response) 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) (Open—Acceptable Response) Expedite requirements for installing automatic- or remote-operated mainline valves on high-pressure pipelines in urban and environmentally sensitive areas to provide for rapid shutdown of failed pipeline segments. (P-95-1) (Closed—Acceptable Action) Although this NPRM addresses some aspects of Safety Recommendation P-11-9, important points are missed. For example, the proposed changes to Title 49 Code of Federal Regulations (CFR) 192.615(a)(8) and 195.402(e)(7) do not require immediate and direct notification to local jurisdictions of possible ruptures as recommended by Safety Recommendation P-11-9. Specifically, the NPRM’s clarifications to when notification is required could unnecessarily delay notification to local authorities and possibly exclude some ruptures, such as systems or portions of systems which do not contain “rupture-mitigation” valves, from the notification requirement. This would mean that ruptures to distribution systems and existing transmission systems may not be reported to local jurisdictions. In addition, clarifications are needed for some of the verbiage used in this NPRM. Terminology such as “large volume” and “uncontrolled release” can be interpreted in a myriad of ways, and thus, it does not clearly identify which releases can be excluded from the notification requirement. Although Safety Recommendation P-11-10 specifically called for PHMSA to require leak detection equipment on gas transmission and distribution pipelines, that action is not proposed in the NPRM. Instead, PHMSA intends to address leak detection through future rulemaking, research and development, and new or updated standards. PHMSA states in this NPRM that by requiring pressure monitoring upstream and downstream of all rupture-mitigation valves, ruptures can be better detected. PHMSA also notes that this pressure monitoring equipment can be used for leak detection once the technology becomes further developed. However, the criteria proposed is not specific to leak detection and the proposed requirements for installing rupture-mitigation valves exclude most of the systems that are the subject of Safety Recommendation P-11-10. For instance, gas distribution systems are excluded entirely, as are existing transmission lines, newly constructed or entirely replaced transmission lines which are less than 6-inches in diameter, and offshore transmission lines. Furthermore, the basis for the spacing intervals proposed in the NPRM is not clear and may not provide sufficient mitigation capability for those systems that are not excluded. Although PHMSA's actions to enhance leak detection and management through other avenues can be beneficial, the NTSB encourages PHMSA to act on Safety Recommendation P-11-10 to institute a more comprehensive and effective leak detection system for the pipeline industry as a whole. Safety Recommendation P-11-11 addresses the importance of having automatic shutoff valves (ASV) and remote-control valves (RCV) installed to facilitate the rapid shutdown of failed pipe segments in populated areas. The NTSB first identified this need almost 50 years ago and has continued to advocate for it. This safety recommendation is currently on the NTSB MWL of Transportation Safety Improvements. In this NPRM, PHMSA proposes changes to 49 CFR 192.935(c) that are not consistent with Safety Recommendation P-11-11. Instead of directly requiring ASVs or RCVs in high consequence areas (HCA) and Class 3 and 4 locations, the proposed changes to 49 CFR 192.935(c) would add further requirements that must be met once an operator determines that ASVs or RCVs would be efficient means of adding protection to an HCA. The additional requirements exclude most of the pipelines that are subject to 49 CFR 192.935(c) since they are only applicable to newly constructed or entirely replaced onshore gas transmission pipelines that have nominal diameters greater than or equal to 6 inches. One of the additional requirements would be to install rupture mitigation valves within specified maximum spacing intervals that extend between 8 and 20 miles for HCAs based on class location. However, the valves are not required to be spaced at intervals that consider the factors indicated in Safety Recommendation P-11-11, such as the swiftness of leak detection and pipe shutdown capabilities, the type of gas being transported, the operating pressure, the rate of potential release, the pipeline profile, the potential for ignition, and the location of nearest response personnel. The basis for the maximum rupture-mitigation valve spacing intervals may not be sufficient to mitigate the consequence of the pipe failure. The proposed changes to 49 CFR 192.935(c) also specify minimum standards for isolating ruptures and would require that operators isolate the segment as soon as practicable but within 40 minutes of rupture identification. This maximum timeframe is longer than what would be expected of an ASV and RCV and may not provide sufficient mitigation capability. For example, an ASV was installed on a service line to a school in Gary, Indiana, when its low-pressure distribution system was overpressurized on June 3, 1969. The ASV shut in time to avoid any damage to the school itself. PHMSA proposes to add a paragraph to 49 CFR 192.179 to require that “all valves on newly constructed or entirely replaced onshore

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1996-01-23

Communication Type: Recommendation Reiteration

Communication Contents: From the special investigation report: Evaluation of Accident Data and Federal Oversight of Petroleum Product Pipelines (adopted 1/23/1996): In the Edison report, the Safety Board stated its belief that RSPA's 1991 study report on emergency flow restricting devices was seriously flawed and caused the Congress, in Public Law 102-508, to inappropriately limit considerations of emergency flow restricting devices to hazardous liquid pipelines. The Safety Board also noted that its review of RSPA's 1991 study and the Edison accident clearly demonstrated that RSPA needed to reconsider its actions on using remote control valves and automatic control valves as main line valves to promptly limit the flow of natural gas to failed pipeline segments, especially in urban or environmentally sensitive areas. To that end, the Board classified Safety Recommendation P-87-22 “Closed--Unacceptable Action/Superseded” and recommended that RSPA: P-95-1 Expedite requirements for installing automatic- or remote-operated mainline valves on high pressure pipelines in urban and environmentally sensitive areas to provide for rapid shutdown of failed pipeline segments. In a May 12, 1995, response to Safety Recommendation P-95-1, RSPA stated that it intended to publish an NPRM in fall 1995 that would specify those circumstances under which operators of hazardous liquid pipelines would be required to use emergency flow restricting devices. The Safety Board classified the recommendation “Open—Acceptable Response” on July 17, 1995. On October 19, 1995, RSPA held a public workshop on emergency flow restricting devices. RSPA stated that it held the workshop in part because RSPA had received only limited data in response to the 1994 ANPRM. RSPA also stated that the purpose of the workshop was “to enable government and industry to reach a better understanding of the problem and the potential solutions before proposed rules are issued.” Placement of emergency flow restricting devices, leak detection sensitivity, requirements for a leak detection system, and use of emergency flow restricting devices at pump stations and breakout tanks were addressed at the workshop. According to the semiannual DOT regulatory plan published on November 28, 1995,40 an NPRM proposing requirements for the use of emergency flow restricting devices and other procedures, systems, and equipment to detect and locate pipeline ruptures was scheduled to be published in December 1995. Subsequently, a RSPA staff member advised a Safety Board investigator that, as of December 20, 1995, RSPA is projecting publication of the NPRM in the first quarter of 1996. Many of the topics discussed at the workshop were also considered in the Volpe Transportation Center study. Because it scheduled the workshop as a prelude to the development of proposed rules, RSPA could not meet its commitment to issue an NPRM in fall 1995 and is now predicting an additional delay of 3-6 months. As is the case with the inspection and testing of pipelines, RSPA has performed studies, conducted research, and sought industry input, but has failed to carry through and develop requirements for leak detection and rapid shutdown of failed pipelines. The Safety Board acknowledges the complexity of SCADA and leak detection systems that would indicate the proximate location of leaks. However, as noted in the Volpe study, less complex equipment can now be effectively used to enhance an operator's leak detection capability. Rapid shutdown can be achieved through appropriate use and spacing of remotely operated valves, automatic valves, and other emergency flow restriction devices. Consequently, the Safety Board believes that RSPA has not been sufficiently responsive to this issue and reiterates Safety Recommendation P-95-1. The recommendation remains classified “Open- Acceptable Response.” In light of all of these considerations, the Safety Board concludes that although RSPA has taken regulatory action and undertaken other initiatives to minimize excavation damage, RSPA has failed to take effective and timely action to address corrosion control, inspection and testing of pipelines, and methods to limit the release of product from failed pipelines.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-04-18

Communication Type: Official Correspondence

Communication Contents: Given the timeframe since issuance of the recommendation and the little information provided on action undertaken, Safety Recommendation P-95-1 is classified "Open--Unacceptable Response."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-06-18

Communication Type: Official Correspondence

Communication Contents: THE SAFETY BOARD IS AWARE THAT RSPA ISSUED AN ANPRM IN 1994 AND HELD A PUBLIC WORKSHOP IN 1995 ON THE USE OF EMERGENCY FLOW RESTRICTING DEVICES (EFRD'S) AND OTHER PROCEDURES, SYSTEMS, AND EQUIPMENT FOR DETECTING AND LOCATING HAZARDOUS LIQUID PIPELINE RUPTURES AND MINIMIZING PRODUCT RELEASES. FURTHER, THE SAFETY BOARD UNDERSTANDS THAT RSPA NOW PLANS TO ISSUE AN NPRM PROPOSING A DEFINITION FOR AREAS UNUSUALLY SENSITIVE TO ENVIRONMENTAL DAMAGE, AND THAT RSPA WILL LATER ADDRESS THE NEED TO MANDATE EFRD INSTALLATION. THEREFORE, PENDING FURTHER RESPONSE ON THE STATUS OF THESE ACTIONS, P-95-1 HAS BEEN CLASSIFIED "OPEN--ACCEPTABLE RESPONSE." THE BOARD URGES RSPA TO EXPEDITE ACTION ON THIS IMPORTANT SAFETY ISSUE.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-03-05

Communication Type: Official Correspondence

Communication Contents: The Safety Board appreciates RSPA's summary of actions taken since 1995 when the recommendation was issued. We further note that RSPA has developed new approaches and has studied a number of developing technologies that are helping industry to better assess the operation of their pipelines. In addition, RSPA developed a series of rulemakings that require every natural gas transmission and hazardous liquid pipeline operator to implement an integrity management program to protect high consequence areas (HCAs) that could be affected by a pipeline failure. RSPA reports that a notice of proposed rulemaking on this issue is expected to be published soon. Pending publication and review of the final rule requiring integrity management program for gas pipelines in HCAs, Safety Recommendation P-95-1 is classified "Open--Acceptable Response." The Safety Board appreciates RSPA's efforts on this issue and looks forward to completed action on the final rule.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-04-21

Communication Type: Official Correspondence

Communication Contents: The Safety Board appreciates RSPA's summary of action taken to address this recommendation and notes that RSPA has developed new approaches and has studied a number of developing technologies that are helping the industry to better assess the operation of their pipelines. RSPA's actions to address Safety Recommendation P-91-1 also address this recommendation. Because RSPA has satisfactorily addressed the recommendation, Safety Recommendation P-95-1 is classified "Closed--Acceptable Action."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-12-23

Communication Type: Official Correspondence

Communication Contents: The Safety Board notes that the NPRM would implement new requirements for control room management at 49 CFR Parts 192, 193, and 195 for natural gas pipelines, liquefied natural gas (LNG) facilities, and hazardous liquid pipelines, respectively. Under the proposed requirements, each operator of a natural gas pipeline, LNG facility, or hazardous liquid pipeline with a controller and control room would have to establish and follow written control room management procedures. The procedures also would have to be integrated into the operator's operations and maintenance manual, qualification program, and emergency plan, all of which are currently required under 49 CFR Parts 192, 193, and 195. The Safety Board further notes that in order to implement the proposed control room management procedures an operator would be required to do the following: define the roles and responsibilities of the controllers; provide controllers with accurate and timely system data; implement methods to prevent controller fatigue; ensure appropriate controller response to alarms and notifications when Supervisory Control and Data Acquisition (SCADA) systems are used; establish thorough and frequent communications among controllers, management, and field personnel when planning and implementing physical changes to pipelinelfacility equipment and configuration; review control room procedures following any event that must be reported under existing regulations; establish and implement a training program that includes an annual review to identify potential improvements; have a qualification program for controllers; and conduct an

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1995-07-17

Communication Type: Official Correspondence

Communication Contents: THE BOARD APPRECIATES RSPA'S RECOGNITION OF THE NEED TO ACT PROMPTLY ON THIS RECOMMENDATION. OUR STAFF HAS SPOKEN WITH REPRESENTATIVES OF THE INTERSTATE NATURAL GAS ASSOCIATION (INGAA) & LEARNED THAT THE INGAA IS WORKING ON A STUDY TO DETERMINE WHETHER & WHERE AUTOMATIC OR REMOTE-CONTROLLED VALVES SHOULD BE INSTALLED ON GAS TRANSMISSION PIPELINES. THE INGAA IS REVIEWING PREVIOUS RUPTURES TO ASSESS WHETHER PROMPT SHUTDOWN WOULD HAVE MADE A DIFFERENCE IN THE ACCIDENT OUTCOMES. ALTHOUGH WE WILL AWAIT THE RESULTS OF THE STUDY, WE HAVE CONCERNS ABOUT THE STUDY METHODOLOGY, BECAUSE ALMOST ALL PREVIOUS RUPTURES OF HIGH-PRESSURE PIPELINES DID NOT OCCUR IN DENSELY POPULATED AREAS. THE STUDY DOES NOT SEEM LIKELY TO YIELD MEANINGFUL INFO ABOUT THE POTENTIAL EFFECTS OF RUPTURES ON THE PUBLIC & COMMUNITY RESPONSE AGENCIES IN DENSELY POPULATED URBAN ENVIRONMENTS. WE ARE PLEASED THAT RSPA IS PROCEEDING WITH RULEMAKING TO SPECIFY THOSE CIRCUMSTANCES UNDER WHICH OPERATORS WILL BE REQUIRED TO INSTALL & USE EMERGENCY FLOW RESTRICTING DEVICE FOR LIQUID PIPELINES. THE EFFECTS OF RELEASED LIQUID PRODUCTS, ESPECIALLY THOSE THAT PRODUCE HEAVIER-THAN-AIR VAPORS, IN URBAN SETTINGS CAN BE ESPECIALLY DANGEROUS TO PUBLIC SAFETY. PENDING THE OUTCOME OF RSPA'S EFFORTS RELATED TO RAPID SHUTDOWN OF FAILED PIPELINES, P-95-1 HAS BEEN CLASSIFIED "OPEN--ACCEPTABLE RESPONSE." PLEASE PROVIDE PERIODIC REPORTS ON THE PROGRESS OF THE INITIATIVES.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1997-10-31

Communication Type: Official Correspondence

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 4:45:37 PM MC# 2030032 I request that Safety Recommendation P-95-l be reclassified as "Closed - Acceptable Action" based on the gas and hazardous liquid pipeline integrity management programs that are being implemented. If we can be of further assistance, please contact me or Patricia Klinger, Director of External Communications, at (202) 366-4831. RSPA's most recent efforts include 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 HCAs. On December 1, 2000, RSPA published a final rule covering pipeline integrity management in high consequence areas on hazardous liquid pipelines with 500 or more miles of pipeline (65 FR 75378). On January 16, 2002, an identical final rule for operators of hazardous liquid pipelines with less than 500 miles of pipe, was published in the Federal Register (67 FR 1108). The integrity management program rule requires an operator of hazardous liquid pipelines to establish a pipeline integrity management program to assess, evaluate, repair, and validate, through comprehensive analysis, the integrity of hazardous liquid pipeline segments that, in the event of a failure, could affect populated areas, areas unusually sensitive to environmental damage and commercially navigable waterways. The rule requires an operator to install an emergency flow restricting device (EFRD) if the operator determines that one is needed to protect the high consequence area. The rule also specifies factors that an operator must consider in making this determination, including the swiftness of leak detection and pipeline shutdown capabilities, the type of commodity carried, the rate of potential leakage, the volume that can be released, the topography or pipeline profile, potential for ignition and proximity to power sources, location of nearest response personnel, specific terrain between pipeline and high consequence area, and benefits expected from reduction in spill size. RSPA inspectors will review the adequacy of the pipeline operator's integrity inspections and analyses and examine the basis for an operator's decision on the need to install or not install an EFRD. RSPA noted its plan to include requirements for remotely controlled valves in any gas pipeline integrity program in its request for comments on gas pipeline integrity management (June 27, 200l; 66 FR 343 18). On January 9, 2002, RSPA proposed a definition of high consequence areas for gas pipeline integrity management programs. A final rule defining HCAs for gas transmission pipelines (67 FR 50824) was published in August 2002. RSPA expects to publish a proposal on gas pipeline integrity management programs within the next month. This proposal will address the need for valve installation on gas transmission lines as part of the integrity management program. Action Requested: RSPA requests that Safety Recommendation P-95-l be reclassified as "Closed - Acceptable Action" based on the information provided.

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 12/00 - Final Rule requiring JMP for large hazardous liquid pipelines in high consequence areas (HCAs) (65 FR 75378) 12/00 - Final Rule defining USAs for hazardous liquid pipelines (65 FR 80530) 1/02 - Final Rule specifying repair criteria for hazardous liquid pipelines in HCAs (67 FR 1650) 1/02 - Final Rule on JMP for small hazardous liquid pipelines in HCAs (67 FR 2136) 8/02 - Final Rule defining HCAs for gas transmission pipelines (67 FR 50824) 12/03 - Final Rule revising HCA definition and requiring IMP for gas transmission pipelines in HCAs (68 FR 69778) RSPA's recent efforts include a series of rulemakings to require natural gas transmission and hazardous liquid pipeline operators to initiate and follow a pipeline integrity management program (JMP) for HCAs and to evaluate the entire pipeline for lessons learned in HCAs that should be applied beyond HCAs. On December 1,2000, RSPA published a final rule covering pipeline integrity management in high consequence areas on hazardous liquid pipelines with 500 or more miles of pipeline (6.5 FR 75378). On January 16,2002, an identical final rule for operators of hazardous liquid pipelines with less than 500 miles of pipe was published in the Federal Register (67 FR 1108). A final rule requiring operators of natural gas transmission pipelines in HCAs to implement IMP was published December 15, 2003. The integrity management program rule requires operators of hazardous liquid pipelines to establish a pipeline integrity management program to assess, evaluate, repair, and validate, through comprehensive analysis, the integrity of hazardous liquid pipeline segments that, in the event of a failure, could affect populated areas, areas unusually sensitive to environmental damage and commercially navigable waterways. The rule requires an operator to install an emergency flow restricting device (EFRD) if the operator determines that one is needed to protect the high consequence area. The rule also specifies factors that an operator must consider in making this determination, including the swiftness of leak detection and pipeline shutdown capabilities, the type of commodity carried, the rate of potential leakage, the volume that can be released, the topography or pipeline profile, potential for ignition and proximity to power sources, location of nearest response personnel, specific terrain between pipeline and high consequence area, and benefits expected from reduction in spill size. RSPA inspectors will review the adequacy of the pipeline operator's integrity inspections and analyses and examine the basis for an operator's decision on the need to install or not install an EFRD. The rule governing integrity management for gas transmission pipelines similarly requires that each operator determine whether installing automatic or remote control valves would be an efficient means of adding protection to an HCA in the event of a gas release. Operators are required to install such valves if they determine that they would be useful. RSPA intends to use an inspection approach similar to that described above for integrity management program inspections for hazardous liquid pipelines. Inspection protocols for the gas transmission integrity management rule are now being developed. RSPA requests that Safety Recommendation P-95-l be reclassified as "CLOSED - Acceptable Action" based on the information provided.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1995-05-12

Communication Type: Official Correspondence

Communication Contents: RSPA IS IN THE PROCESS OF DEVELOPING AN ACTION PLAN TO ADDRESS THE RECOMMENDATIONS OF THE JOINT INSPECTION TASK FORCE, AS OUTLINED IN THEIR NEW JERSEY COMPREHENSIVE INSPECTION REPORT. RSPA IS ACTING ON THE REPORT RECOMMENDATION THAT A NEW TECHNICAL STUDY BE INITIATED TO ESTABLISH CRITERIA FOR THE INSTALLATION OF AUTOMATIC OR REMOTE VALVES ON GAS TRANSMISSION PIPELINE. RSPA IS PROPOSING TO WORK WITH THE INTERSTATE NATURAL GAS ASSOCIATION OF AMERICAN (INGAA) ON THIS ISSUE. IN ADDITION, RSPA IS DEVELOPING A NOTICE OF PROPOSED RULEMAKING (NPRM) THAT WILL SPECIFY THOSE CIRCUMSTANCES UNDER WHICH OPERATORS OF HAZARDOUS LIQUID PIPELINES ARE REQUIRED TO USE EMERGENCY FLOW-RESTRICTION DEVICES. THIS NPRM WILL BE PUBLISHED IN FALL 1995.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1996-08-07

Communication Type: Official Correspondence

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-07-01

Communication Type: Official Correspondence

Communication Contents: RSPA IS EXAMINING THE USE OF EMERGENCY FLOW RESTRICTING DEVICES (EFRDS) AND OTHER PROCEDURES, SYSTEMS, AND EQUIPMENT USED TO DETECT AND LOCATE HAZARDOUS LIQUID PIPELINE RUPTURES AND MINIMIZE PRODUCT RELEASES FROM HAZARDOUS LIQUID PIPELINE FACILITIES. RSPA ISSUED AN ADVANCE NOTICE OF PROPOSED RULEMAKING (ANPRM) (59 FR 2802; 1/19/94) TO SOLICIT DATA FROM THE PUBLIC ON A NUMBER OF QUESTIONS. THE ANPRM CONTAINED QUESTIONS DIRECTED MOSTLY TO THE OPERATORS OF HAZARDOUS LIQUID PIPELINES CONCERNING OPERATIONAL DATA AND COSTS OF EFRD'S AND THE PERFORMANCE OF LEAK DETECTION SYSTEMS AS ONE MEANS TO DETECT AND LOCATE HAZARDOUS LIQUID RUPTURES AND MINIMIZE PRODUCT RELEASE. THE ANPRM ALSO SOUGHT INFORMATION TO HELP DETERMINE CRITICAL LOCATIONS THAT SHOULD BE PROTECTED FROM PIPELINE RELEASES. NINTEEN COMMENTS WERE SUBMITTED IN RESPONSE TO THE ANPRM. COMMENTERS WERE GENERALLY AGAINST REQUIRING LEAK DETECTION EQUIPMENT AND EFRD'S. A NUMBER OF COMMENTERS INDICATED THE INSTALLATION OF THE EFRD'S THEMSELVES WILL POSE PROBLEMS, INCLUDING POSSIBLE PIPELINE LEAKS AND RUPTURES IF THERE IS A MALFUNCTION OF THE EFRD. FURTHER, ROADS WOULD HAVE TO BE BUILT TO PROVIDE ACCESS TO THE VALVES, AND MAY INTRUDE INTO ENVIRONMENTALLY SENSITIVE AREAS. MOREOVER, THE ADDITIONAL COMMENT WAS MADE THAT BEFORE EFRD'S SHOULD BE REQUIRED, TECHNOLOGY TO PRECLUDE THE UNINTENDED CLOSURE OF THE EFRD DUE TO LIGHTNING STRIKES, POWER SURGES, OR OTHER ANOMALIES SHOULD HAVE TO BE DEMONSTRATED. A PUBLIC WORKSHOP WAS CONDUCTED ON 10/19/95, IN PART TO DISCUSS ISSUES RELEVANT TO REQUIRING THE USE OF EFRD'S. THE PARTICIPANTS STRESSED THAT THE PLACEMENT OF REMOTE VALVES SHOULD BE ANALYZED BY A RISK ASSESSMENT FOR EACH SITUATION AND THAT A UNIVERSAL REQUIREMENT FOR ALL PIPELINES WOULD NOT BE COST EFFECTIVE. RSPA INTENDS TO BASE ALL FUTURE REGULATIONS ON RISK ASSESSMENT SINCE COMPLETION OF THE WORKSHOP, A NOTICE OF PROPOSED RULEMAKING (NPRM) ON THE REQUIREMENTS FOR EFRD'S AND LEAK DETECTION SYSTEMS HAS BEEN DELAYED TO ALLWO COMPLETION OF A DEFINITION OF AREAS UNUSUALLY SENSITIVE TO ENVIRONMENTAL DAMAGE (USA) IN THE EVENT OF A PIPELINE SPILL. SUCH A DEFINITION MAY AID IN IDENTIFYING THE MOST COST-EFFECTIVE USE OF EFRD'S. RSPA HAS BEEN CONDUCTING PUBLIC WORKSHOPS TO ENABLE GOVERNMENT AND INDUSTRY TO REACH A BETTER UNDERSTANDING ON THE CHARACTERISTICS OF UNUSUALLY SENSITIVE AREAS. AN NPRM PROPOSING A DEFINITION FOR USA'S IS EXPECTED TO BE PUBLISHED IN LATE 1998. AFTER A DEFINITION OF USA'S HAS BEEN ADOPTED, RSPA WILL ADDRESS THE NEED TO MANDATE INSTALLATION OF EFRD'S. RSPA REQUESTS THAT P-95-1 CONTINUE TO BE CLASSIFIED AS "OPEN--ACCEPTABE 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.