# NTSB Safety Recommendation P-96-003 - **operation:** document - **citation:** P-96-003 - **title:** NTSB Safety Recommendation P-96-003 - **source type:** guidance - **agency:** National Transportation Safety Board - **status:** guidance - **official:** true - **published on:** 1996-03-06 - **effective on:** 1996-03-06 - **summary:** THE NTSB RECOMMENDS TO ALL STATES & THE DISTRICT OF COLUMBIA: REQUIRE GAS DISTRUBUTION OPERATOR TO INSTALL EXCESS FLOW VALVES IN ALL NEW OR RENEWED GAS SERVICE LINES, WHEN OPERATING CONDITIONS ARE COMPATIBLE WITH COMMERCIALLY AVAILABLE VALVES, INCLUDING SERVICE LINES SUPPLYING SCHOOLS, CHURCHES, & OTHER PLACES OF PUBLIC ASSEMBLY. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-96-003.json - **markdown:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-96-003.md - **app url:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-96-003 - **source url:** https://data.ntsb.gov/carol-main-public/sr-details/P-96-003 **body:** NTSB safety recommendation P-96-003. THE NTSB RECOMMENDS TO ALL STATES & THE DISTRICT OF COLUMBIA: REQUIRE GAS DISTRUBUTION OPERATOR TO INSTALL EXCESS FLOW VALVES IN ALL NEW OR RENEWED GAS SERVICE LINES, WHEN OPERATING CONDITIONS ARE COMPATIBLE WITH COMMERCIALLY AVAILABLE VALVES, INCLUDING SERVICE LINES SUPPLYING SCHOOLS, CHURCHES, & OTHER PLACES OF PUBLIC ASSEMBLY. Priority: CLASS II Overall Status: Closed - Acceptable Alternate Action Issued Date: 1996-03-06 Adopted Date: 1996-02-26 Overall Date Closed: 2001-11-06 Synopsis: ABOUT 6:45 P.M. ON 6/9/94, A 2-INCH-DIAMETER STEEL GAS SERVICE LINE THAT HAD BEEN EXPOSED DURING EXCAVATION SEPARATED AT A COMPRESSION COUPLING ABOUT 5 FEET FROM THE NORTH WALL OF JOHN T. GROSS TOWERS, AN EIGHT-STORY RETIREMENT HOME OPERATED BY THE ALLENTOWN HOUSING AUTHORITY AT ALLENTOWN, PENNSYLVANIA. THE FAILED UGI UTILITIES, INC,. (UGI) SERVICE LINE RELEASED NATAURAL GAS AT 55 PSIG PRESSURE, & THE ESCAPING GAS FLOWED UNDERGROUND TO GROSS TOWERS. THE GAS PASSED THROUGH OPENINGS IN THE BUILDING FOUNDATION, ENTERED THE MECHANICAL ROOM THROUGH FLOOR VENTS, & MIGRATED TO OTHER BUILDING FLOORS. Probable Cause: The failure of the management of Environmental Preservation Associates, Inc. (EPAI) to ensure, through project oversight, compliance with its own excavation requirements and Occupational Safety and Health Administration (OSHA) excavation requirements. Keywords: Excess Flow Valves Ntsbnumber: DCA94MP003 Report Number: PAR-96-01 Addressee Name: State of Florida Addressee Status: Closed - Acceptable Action Addressee Date Closed: 2001-01-05 Addressee Acronym: FL Addressee Organization Type: S-State Government Communication Date: 2000-09-15 Communication Type: Official Correspondence Communication Contents: Letter Mail Controlled 10/24/2000 5:55:56 PM MC# 2001576 STAFF OF THE FLORIDA PUBLIC SERVICE COMMISSION HAS FOLLOWED UP WITH EACH AND EVERY GAS COMPANY IN FLORIDA. THE STATE HAS ADOPTED P-96-3 FOR ALL NEW INSTALLATIONS. Addressee Acronym: FL Addressee Organization Type: S-State Government Communication Date: 2001-01-05 Communication Type: Official Correspondence Communication Contents: THE SAFETY BOARD NOTES THAT THE FLORIDA PUBLIC SERVICE COMMISSION HAS FOLLOWED UP WITH EVERY GAS COMPANY IN FLORIDA AND THAT THE STATE HAS ADOPTED P-96-3 FOR ALL NEW INSTALLATIONS, AS REQUESTED. ACCORDINGLY, P-96-3 IS CLASSIFIED "CLOSED--ACCEPTABLE ACTION." Addressee Name: State of Alabama Addressee Status: Closed - Unacceptable Action Addressee Date Closed: 2001-07-19 Addressee Acronym: AL Addressee Organization Type: S-State Government Communication Date: 2000-08-15 Communication Type: Official Correspondence Communication Contents: Letter Mail Controlled 09/05/2000 8:01:54 AM MC# 2001113 Addressee Acronym: AL Addressee Organization Type: S-State Government Communication Date: 1996-04-10 Communication Type: Official Correspondence Communication Contents: THE GOVERNOR, THROUGH THE ALABAMA PUBLIC SERVICE COMMISSION, CITED NUMEROUS ARGUMENTS RECEIVED FROM ALABAMA GAS OPERATORS AGAINST REQUIRING THE INSTALLATION OF EFVS. ALSO, THE ALABAMA PUBLIC SERVICE COMMISSION CITED STATEMENTS OF THE AMERICAN GAS ASSOCIATION & THE OF THE GAS RESEARCH INSTITUTE AS TO WHY EFVS SHOULD NOT BE MANDATED. FINALLY, IT CITED ITS RECENTLY PASSED LEGISLATION ON EXCAVATION DAMAGE PREVENTION STATED THAT EFFORT WOULD PREVENT THE TYPES OF ACCIDENTS IN WHICH EFVS COULD BE EFFECTIVE FOR MINIMIZING CONSEQUENCES. THE ALABAMA PUBLIC SERVICE COMMISSION ADVISED THAT IT COULD NOT, AT THIS TIME, SUPPORT OF THE BOARD'S RECOMMENDATION. Addressee Acronym: AL Addressee Organization Type: S-State Government Communication Date: 2001-07-19 Communication Type: Official Correspondence Communication Contents: BECAUSE THE SAFETY BOARD HAS RECEIVED NO FURTHER REPLY FROM THE STATE OF ALABAMA, P-96-3 IS NOW CLASSIFIED "CLOSED--UNACCEPTABLE ACTION." IF THE STATE OF ALABAMA HAS COMPLETED ANY ACTION IN RESPONSE TO THIS RECOMMENDATION OR INITIATES SUCH ACTION AND INFORMS THE BOARD TO THAT EFFECT, THE BOARD WILL EVALUATE THE ACTION AND MAY RECONSIDER THE CLASSIFICATION OF THIS RECOMMENDATION. Addressee Acronym: AL Addressee Organization Type: S-State Government Communication Date: 1997-02-26 Communication Type: Official Correspondence Communication Contents: THE BOARD IS DISAPPOINTED THAT THE STATE OF ALABAMA WILL NOT MANDATE THE USE OF EXCESS FLOW VALVELS UNDER THE CONDITIONS IDENTIFIED IN THE RECOMMENDATION & BELIEVES THAT THE CONCERNS OF THE ALABAMA PSC DO NOT ACCURATELY REFLECT THE PERFORMANCE OF EXCESS FLOW VALVES. WE ASK FOR A REVIEW OF THE ENCLOSURE PREPARED BY THE SAFETY BOARD ABOUT THE PROVEN BENEFITS OF EXCESS FLOW VALVES. IT PROVIDES INFO EXPLANING THE PERFORMANCE CAPABILITY, RELIABILITY, & SAFETY BENEFITS OF EXCESS FLOW VALVES & IDENTIFIES COMMON MISCONCEPTIONS ABOUT THESE DEVICES. ALSO, IT ADDRESSES THE ARGUMENTS AGAINST EXCESS FLOW VALVES ADVANCED BY THE ALABAMA PSC. OUR ASSESSMENT OF AVAILABLE INFO IS THAT EXCESS FLOW VALVES ARE INEXPENSIVE, ARE RELIABLE, & ARE ABLE TO ENHANCE PUBLIC SAFETY. THE BOARD BELIEVES THAT THE STATES MUST BECOME ACTIVE PROPONENTS OF EXCESS FLOW VALVES BECAUSE GAS CUSTOMERS & THE GENERAL PUBLIC RARELY ARE KNOWLEDGEABLE ABOUT THE DEVICES & HOW THEIR USE CAN MINIMIZE THE RISKS TO PEOPLE & PROPERTY IN THE EVENT OF A SERVICE LINE RUPTURE. THE BOARD POINTS OUT THAT P-96-3 ASKS THAT EXCESS FLOW VALVES BE INSTALLED ONLY WHEN OPERATING CONDITIONS ARE COMPATIBLE WITH COMMERCIALLY AVAILABLE VALVES. THE USE OF EXCESS FLOW VALVES IS SUPPORTED BY THE INTERNATIONAL ASSOCIATION OF FIRE CHIEFS & THE GAS SAFETY ACTION COUNCIL, A GAS CONSUMER ADVOCACY GROUP. A NUMBER OF NATIONAL INDUSTRY ORGANIZATIONS RECOGNIZE THE IMPORTANCE OF EXCESS FLOW VALVES. THE GAS PIPING TECHNICAL STANDARD COMMITTEE, A BODY THAT MAKE RECOMMENDATIONS TO GAS OPERATORS ON SAFE OPERATIONS, IS DEVELOPING GUIDANCE ON SELECTING & USING EXCESS FLOW VALVES. THE MANUFACTURERS STANDARDIZATION SOCIETY & THE AMERICAN SOCIETY FOR TESTING & MATERIALS HAVE ISSUED STANDARDS TO ENSURE THE SAFE USE OF EXCESS FLOW VALVES. PENDING REVIEW OF THE ENCLOSED MATERIAL & RECONSIDERATION OF THE RECOMMENDED ACTION. P-96-3 HAS BEEN CLASSIFED "OPEN--UNACCEPTABLE RESPONSE." WE BELIEVE THAT THE INFO PROVIDED SHOULD ENCOURAGE THE ALABAMA PSC EITHER TO REQUIRE THE INSTALLATION OF EXCESS FLOW VALVES OR, AT THE VERY LEAST, TO IMPLEMENT A PUBLIC EDUCATION PROGRAM ENCOURAGING GREATER USE OF THESE SAFETY VALVES. THE BOARD WOULD APPRECIATE BEING KEPT INFORMED ABOUT YOUR STATE'S ACTIVITIES CONCERNING THE USE OF EXCESS FLOW VALVES. SAFETY BOARD STAFF WOULD BE PLEASED TO PROVIDE ADDITIONAL INF OR TO ASSIST IN ANY WAY REGARDING THIS MATTER. Addressee Acronym: AL Addressee Organization Type: S-State Government Communication Date: 2000-06-27 Communication Type: Official Correspondence Communication Contents: ON 2/26/97, P-96-3 WAS CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE," BASED ON INFORMATION PROVIDED TO THE SAFETY BOARD IN A LETTER FROM THE STATE OF ALABAMA DATED 4/10/97. TO DATE THERE HAS BEEN NO FURTHER RESPONSE TO THE BOARD REGARDING P-96-3. THE SAFETY BOARD WOULD APPRECIATE LEARNING WHAT ACTION YOUR STATE HAS TAKEN TO IMPLEMENT THIS RECOMMENDATION. Addressee Name: State of North Carolina Addressee Status: Closed - Unacceptable Action Addressee Date Closed: 1997-06-19 Addressee Acronym: NC Addressee Organization Type: S-State Government Communication Date: 1996-05-13 Communication Type: Official Correspondence Communication Contents: THE GOVERNOR, THROUGH THE NORTH CAROLINA UTILITIES, ADVISED THAT IT WAS CONCERNED ABOUT THE PERFORMANCE OF EFVS CITING SERVERAL ARGUMENTS FOSTER BY GAS OPERATORS & IT STATED THAT IT MUST ALSO LOOK TO COSTS & PUBLIC ACCPETANCE OF THAT COST. THE COMMISSION THEN CITED A RESOLUTION OF THE NATIONAL ASSOCIATION OF REGULATORY UTILITY COMMISSIONERS WHICH HELD THAT THE USE OF EFVS SHOULD BE LEFT TO THE DECISIONS OF APPROPRIATE STATE REGULATORY AGENCIES. THE LETTER CONCLUDES THAT THE COMMISSION HAS LEFT THE DECISION ON USE OF EFVS IN THE HANDS OF THE GAS OPERATORS AS IT SEES NO REASON TO MANDATE THEIR USE. Addressee Acronym: NC Addressee Organization Type: S-State Government Communication Date: 1997-03-13 Communication Type: Official Correspondence Communication Contents: THE GOVERNOR, THROUGH THE STATE UTILITIES COMMISSION, ADVISED THAT THE GOVERNOR, BECAUSE OF HIS CONCERN & COMMITMENT, REVIEWED THE STATE'S PREVIOUS POSITION IN LIGHT OF THE SAFETY BOARD CHAIRMAN'S LETTER. THEY CONSIDERED THE PROFESSIONAL DEBATE ON ALL FACETS OF THE EXCESS FLOW VALVE ISSUE & THE CONGRESSIONAL, ADMINISTRATIVE, & STATE LEGISLATIVE ACTION & INACTION, BUT CONTINUE TO BE PERSUADED THAT A MANDATORY REQUIREMENT IS NOT IN THE PUBLIC INTEREST AT THIS TIME. CONCERNING THE BOARD'S SUGGESTION THAT THE STATE INITIATE A PUBLIC EDUCATION EFFORT ON THE USE OF EXCESS FLOW VALVES, THE STATE BELIEVES IT PRUDENT TO AWAIT THE OFFICE OF PIPELINE SAFETY'S FINAL RULE ON THE USE OF EXCESS FLOW VALVES, A RULE THAT THE STATE UNDERSTANDS WILL BE ISSUED IN APRIL 1997. AFTER THE FINAL RULE HAS BEEN REVIEWED, THE STATE WILL DECIDE WHAT, IF ANY, ADDITIONAL ACTION IT SHOULD TAKE. Addressee Acronym: NC Addressee Organization Type: S-State Government Communication Date: 1997-02-26 Communication Type: Official Correspondence Communication Contents: THE BOARD IS DISAPPOINTED THAT THE STATE OF NORTH CAROLINA WILL NOT MANDATE THE USE OF EXCESS FLOW VALVES UNDER THE CONDITIONS IDENTIFIED IN RECOMMENDATION & BELIEVES THAT THE CONCERNS OF THE NORTH CAROLINA UTILITIES COMMISSION DO NOT ACCURATELY REFLECT THE PERFORMANCE OF EXCESS FLOW VALVES. WE ASK FOR A REVIEW OF THE ENCLOSURE PREPARED BY SAFETY BOARD STAFF ABOUT THE PROVEN BENEFITS OF EXCESS FLOW VALVES. IT PROVIDES INFO EXPLANING THE PERFORMANCE CAPABILITY, RELIABILITY, & SAFETY BENEFITS OF EXCESS FLOW VALVES & IDENTIFIES COMMON MISCONCEPTIONS ABOUT THESE DEVICES. ALSO, IT ADDRESSES THE ARGUMENTS AGAINST EXCESS FLOW VALVES ADVANCED BY THE NORTH CAROLINA UTILITIES COMMISSION. OUR ASSESSMENT OF AVAILABLE INFO IS THAT EXCESS FLOW VALVES ARE INEXPENSIVE, ARE RELIABLE, & ARE ABLE TO ENHANCE PUBLIC SAFETY. THE BOARD BELIEVES THAT THE STATES BECOME ACTIVE PROPONENTS OF EXCESS FLOW VALVES BECAUSE GAS CUSTOMERS & THE GENERAL PUBLIC RARELY ARE KNOWLEDGEABLE ABOUT THE DEVICE & HOW THEIR USE CAN MINIMIZE THE RISKS TO PEOPLE & PROPERTY IN THE EVENT OF A SEVICE LINE RUPTURE. THE BOARD POINTS OUT THAT P-96-3 ASKS THAT EXCESS FLOW VALVES BE INSTALLED ONLY WHEN OPERATING CONDITIONS ARE COMPATIBLE WITH COMMERCIALL AVAILABLE VALVES. THE USE OF EXCESS FLOW VALVES IS SUPPORTED BY THE INTERNATIONAL ASSOCIATION OF FIRE CHIEFS & THE GAS SAFETY ACTION COUNCIL, A GAS CONSUMER ADVOCACY GROUP. A NUMBER OF NATIONAL INDUSTRY ORGANIZATIONS RECOGNIZE THE IMPORTANCE OF EXCESS FLOW VALVES. THE GAS PIPING TECHNICAL STANDARDS COMMITTEE, A BODY THAT MAKES RECOMMENDATIONS TO GAS OPERATORS ON SAFE OPERATIONS, IS DEVELOPING GUIDANCE ON SLECTING & USING EXCESS FLOW VALVES. THE MANUFACTURERS STANDARDIZATION SOCIETY & THE AMERICAN SOCIETY FOR TESTING & MATERIALS HAVE ISSUED STANDARD TO ENSURE THE SAFE USE OF EXCESS FLOW VALVES. PENDING REVIEW OF THE ENCLOSE MATERIAL & RECONSIDERATION OF THE RECOMMENDED ACTION, P-96-3 HAS BEEN CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE." WE BELIEVE THAT THE INFO PROVIDED SHOULD ENCOURAGE THE NORTH CAROLINA UTILITIES COMMISSION EITHER TO REQUIRE THE INSTALLATION OF EXCESS FLOW VALVES OR, AT THE VERY LEAST, TO IMPLEMENT A PUBLIC EDUCATION PROGRAM ENCOURAGING GREATER USE OF THESE SAFETY VALVES. THE BOARD WOULD APPRECIATE BEING KEPT INFORMED ABOUT YOUR STATE'S PROGRESS CONCERNING THE USE OF EXCESS FLOW VALVES. ALSO, BOARD STAFF WILL BE PLEASED TO PROVIED ADDITIONAL INFO OR TO ASSIST YOU IN ANY WAY REGARDING THIS MATTER. Addressee Acronym: NC Addressee Organization Type: S-State Government Communication Date: 1997-06-13 Communication Type: Official Correspondence Communication Contents: THE BOARD IS DISAPPOINTED THAT NORTH CAROLINA DOES NOT FULLYL APPRECIATE THE SAFETY ADVANTAGES OF USING EXCESS FLOW VALVES. THE RESULT IS THAT NORTH CAROLINIANS NOW WILL HAVE TO DEPEND ON THE FEDERAL GOVERNMENT FOR AN OPPORTUNITY TO BENEFIT FROM THE USE OF THE VALVES. THEREFORE, P-96-3 HAS BEEN CLASSIFIED "CLOSED--UNACCEPTABLE ACTION." Addressee Name: State of Wyoming Addressee Status: Closed - Unacceptable Action Addressee Date Closed: 1997-07-21 Addressee Acronym: WY Addressee Organization Type: S-State Government Communication Date: 1997-09-29 Communication Type: Official Correspondence Addressee Acronym: WY Addressee Organization Type: S-State Government Communication Date: 1996-03-26 Communication Type: Official Correspondence Communication Contents: THE GOVERNOR, THROUGH THE WYOMING PUBLIC SERVICE COMMISSION EXPRESSED HIS UNDERSTANDING THAT THE SMALLER EFVS USED ON GAS SERVICE LINES ARE NOT AS RELIABLE AS LARGER EFVS NOW USED ON PIPELINES IN WYOMING. HE DIRETED THE WYOMING PUBLIC SERVICE COMMISSIOIN TO CLOSELY MONITOR NEW DEVELOPMENT IN VALVE TECHNOLOG, BUT HAS NO PLANS TO ACT NOW ON THE RECOMMENDATION. Addressee Acronym: WY Addressee Organization Type: S-State Government Communication Date: 1997-04-24 Communication Type: Official Correspondence Communication Contents: THE GOVERNOR ADVISED THAT THE WYOMING PUBLIC SERVICE COMMISSION INFORMED HIM THAT SMALL EXCESS FLOW VALVES FOR USE ON CUSTOMER SERVICE LINES EXPERIENCE HIGH RATES OF FAILURE & THAT THIS HAS POSED A SUBSTANTIAL & EXPENSIVE PROBLEM FOR UTILITIES & THEIR CUSTOMERS. HE STATED THE COMMISSION OPPOSES THE MANDATORY USE OF EFVS UNTIL THEY CAN BE IMPROVED TO PREVENT UNINTENTIONAL CLOSINGS. HE CONCURRED WITH THE COMMISSION' POSITION. Addressee Acronym: WY Addressee Organization Type: S-State Government Communication Date: 1997-02-26 Communication Type: Official Correspondence Communication Contents: THE BOARD IS DISAPPOINTED THAT THE STATE OF WYOMING WILL NOT MANDATE THE USE OF EXCESS FLOW VALVES UNDER THE CONDITIONS IDENTIFIED IN THE RECOMMENDATION & BELIEVES THAT THE CONCERNS OF THE WYOMING PUBLIC SERVICE COMMISSION DO NOT ACCURATELY REFLECT THE PERFORMANCE OF EXCESS FLOW VALVES. WE ASK FOR A REVIEW OF THE ENCLOSURE PREPARED BOARD STAFF ABOUT THE PROVEN BENEFITS OF EXCESS FLOW VALVES. IT PROVIDES INFO EXPLAINING THE PERFORMANCE CAPABILITY, RELIABILITY, & SAFETY BENEFITS OF EXCESS FLOW VALVES & IDENTIFIES COMMON MISCONCEPTIONS ABOUT THESE DEVICES. ALSO, IT ADDRESSES THE ARGUMENTS AGAINST EXCESS FLOW VALVES ADVANCED BY THE WYOMING PUBLIC SERVICE. OUR ASSESSMENT OF AVAILABLE INFO IS THAT EXCESS FLOW VALVES ARE INEXPENSIVE, ARE RELIABLE, & ARE ABLE TO ENHANCE PUBLIC SAFETY. THE BOARD BELIEVES THAT THE STATES MUST BECOME ACTIVE PROPONENTS OF EXCESS FLOW VALVES BECAUSE GAS CUSTOMERS & THE GENERAL PUBLIC RARELY ARE KNOWLEDGEABLE ABOUT THE DEVICES & HOW THEIR USE CAN MINIMIZE THE RISKS TO PEOPLE PROPERTY IN THE EVENT OF A SERVICE LINE RUPTURE. THE BOARD POINTS OUT THAT P-96-3 ASKS THAT EXCESS FLOW VALVES BE INSTALLED ONLY WHEN OPERATING CONDITIONS ARE COMPATIBLE WITH COMMERCIALLY AVAILAVLE VALVES. THE USE OF EXCESS FLOW VALVES IS SUPPORTED BY TH E INTERNATIONAL ASSOCIATION OF FIRE CHIEFS & THE GAS SAFETY ACTION COUNCIL, A GAS CONSUMER ADVOCACY GROUP. A NUMBER OF NATIONAL INDUSTRY ORGANIZATIONS RECOGNIZE THE IMPORTANCE OF EXCESS FLOW VALVES. THE GAS PIPING TECHNICAL STANDARDS COMMITTEE, A BODY THAT MAKES RECOMMENDATIONS TO GAS OPERATORS ON SAFE OPERATIONS, IS DEVELOPING GUIDANCE ON SELECTING & USING EXCESS FLOW VALVES. THE MANUFACTURERS STANDARDIZATION SOCIETY & THE AMERICAN SOCIETY FOR TESTING & MATERIALS HAVE ISSUED STANDARDS TO ENSURE THE SAFE USE OF EXCESS FLOW VALVES. PENDING REVIEW OF THE ENCLOSED MATERIAL & RECONSIDERATION OF THE RECOMMENDED ACTION, P-96-3 HAS BEEN CLASSIFIED "OPEN--UNACCEPTABLE RESPOSNE." THE BOARD WOULD APPRECIATE BEING KEPT INFORMED ABOUT YOUR STATE'S ACTIVITIES CONCERNING THE USE OF EXCESS FLOW VALVES. THE BOARD STAFF WOULD BE PLEASED TO PROVIDE ADDITIONAL INFO OR TO ASSIST IN ANY WAY REGARDING THIS MATTER. Addressee Acronym: WY Addressee Organization Type: S-State Government Communication Date: 1997-07-21 Communication Type: Official Correspondence Communication Contents: THE BOARD ENCLOSED WITH ITS 2/26/97, LETTER TO YOU A FACT SHEET ON EXCESS FLOW VALVES. THAT FACT SHEET INCLUDED INFO ON EXPERIENCE WITH MODERN EXCESS FLOW VALVE DESIGNS BY MAJOR GAS OPERATORS. THAT INFO IS CONTRARY TO THE INFO GIVEN YOU BY THE WYOMING PUBLIC SERVICE COMMISSION. IT APPEARS THAT THE COMMISSION'S INFO RELATES TO EXCESS FLOW VALVE DESIGNS OF THE 1950S & EARLY 1960; IT CERTAINLLY IS NOT CONSISTENT WITH MODER EXCESS FLOW VALVE DESIGNS. THE PROBLEMS WITH THE OLDER EXCESS FLOW VALVES HAVE BEEN TRACED PRIMARILY TO PROBLEMS OF INSALLATION BY GAS OPERATORS, NOT TO THE DESIGN OF THE VALVES. THE BOARD IS DISAPPOINTED THAT THE STATE WYOMING WILL NOT MANDATE USE OF EXCESS FLOW VALVES UNDER THE CONDITIONS IDENTIFIED IN THE RECOMMENDATION. IT IS UNFORTUNATE THAT THE WYOMING PUBLIC SERVICE COMMISSION HAS NOT REVIEWED MODERN EXCESS FLOW VALVE DESIGNS & NOT MADE YOU AWARE OF THEIR RELIABILITY & THEIR POTENTIAL FOR MINIMIZING THE CONSEQUENCES OF SERVICE LINE RUPTURES. IN RESPONSE TO THE WYOMING PUBLIC SERVICE COMMISSION'S POSITION, P-96-3 HAS BEEN CLASSIFIED "CLOSED--UNACCEPTABLE ACTION." Addressee Name: State of Nevada Addressee Status: Closed - Unacceptable Action Addressee Date Closed: 2001-07-19 Addressee Acronym: NV Addressee Organization Type: S-State Government Communication Date: 1997-03-24 Communication Type: Official Correspondence Addressee Acronym: NV Addressee Organization Type: S-State Government Communication Date: 1996-04-16 Communication Type: Official Correspondence Communication Contents: THE GOVERNOR, THROUGH THE NEVADA PUBLIC SERVICE COMMISSION ADVISED THAT IT BELIEVE THAT THE ACTIONS BY RSPA WERE ADEQUATE & BELIEVES THAT THERE IS NOT REASON FOR IT TO BEGIN & EXTENSIVE EVALUTION ON THE SAME ISSUE. IT CONSIDERED THAT TO DO SO WOULD BE DUPLICATIVE OF THE RSPA EFFORT. Addressee Acronym: NV Addressee Organization Type: S-State Government Communication Date: 2001-07-19 Communication Type: Official Correspondence Communication Contents: BECAUSE THE SAFETY BOARD HAS RECEIVED NO REPLY TO THESE REQUESTS, P-96-3 IS CLASSIFIED "CLOSED--UNACCEPTABLE ACTION." IF NEVADA HAS COMPLETED ANY ACTION IN RESPONSE TO THIS RECOMMENDATION OR INITIATES SUCH ACTION AND INFORMS THE BOARD TO THAT EFFECT, THE BOARD WILL EVALUATE THE STATE'S ACTION AND MAY RECONSIDER THE CLASSIFICATION OF THIS RECOMMENDATION. Addressee Acronym: NV Addressee Organization Type: S-State Government Communication Date: 1997-03-27 Communication Type: Official Correspondence Communication Contents: THE BOARD BELIEVES THAT VARIOUS FACTORS & CONDITONS WARRANT RECONSIDERATION OF THE PSCN'S POSITION. THE BOARD REVIEWED THE RSPA EVALUATION OF EXCESS FLOW VALVES & DETERMINED THAT IT WAS BOTH LIMITED IN SCOPE & NOT AN EFFECTIVE ASSESSMENT OF AVAILABLE INFO. THE EVALUATION CONSIDERED ONLY EXCESS FLOW VALVES IN SINGLE-RESIDENT GAS SERVICE LINES THAT OPERATE ABOVE 10 PSIG (POUNDS PER SQUARE INCH) PRESSURE; IT DID NOT CONSIDER EXCESS FLOW VALVES IN SERVICE LINES TO MULTISTORY APARTMENT BUILDINGS. MOREOVER, RSPA HAS NOT PERFORMED AN ASSESSMENT ON USING EXCESS FLOW VALVAES IN SERVICE LINES TO BUILDINGS IN WHICH A SINGLE VALVE WOULD PROTECT HUNDREDS OF LIVES. & LAST, RSPA'S PREVIOUS STUDY ON EXCESS FLOW VALVES FOUND THEM TO BE BOTH EFFECTIVE & COST BENEFICIAL. THE BOARD IS DISAPPOINTED THAT THE STATE OF NEVADA WILL NOT MANDATE THE USE OF EXCESS FLOW VALVES UNDER THE CONDITIONS IDENTIFIED IN RECOMMENDATION & BELIEVES THAT THE CONCERNS OF THE PSCN DO NOT ACCURATELY REFECT THE PERFORMANCE OF EXCESS FLOW VALVES. WE ASK FOR A REVIEW OF THE ENCLOSURE PREPARED BY BOARD STAFF ABOUT THE PROVEN BENEFITS OF EXCESS FLOW VALVES. IT PROVIDES INFO EXPLAINING THE PERFORMANCE CAPABILITY, RELIABILTY & SAFETY BENEFITS OF EXCESS FLOW VALVES & IDENTIFIES COMMON MISCONCEPTIONS ABOUT THESE DEVICES. ALSO, IT ADDRESS THE ARGUMENTS AGAINST EXCESS FLOW VALVES ADVANCED BY THE PSCN. OUR ASSESSMENT OF AVAILABLE INFO IS THAT EXCESS FLOW VALVES ARE INEXPENSIVE, ARE RELIABLE, & ARE ABLE TO ENHANCE PUBLIC SAFETY. THE BOARD BELIEVES THAT THE STATES MUST BECOME ACTIVE PROPONENTS OF EXCESS FLOW VALVES BECAUSE GAS CUSTOMERS & THE GENERAL PUBLIC RARELY ARE KNOWLEDGEABLE ABOUT THE DEVICES & HOW THEIR USE CAN MINIMIZE THE RISKS TO PEOPLE & PROPERTY IN THE EVENT OF A SERVICE LINE RUPUTURE. THE BOARD POINTS OUT THAT P-96-3 ASKS THAT EXCESS FLOW VALVES BE INSTALLED ONLY WHEN OPERATING CONDITIONS ARE COMPATIBLE WITH COMMERCIALLY AVAILABLE VALVES. THE USE OF EXCESS FLOW VALVES IS SUPPORTED BY THE INTERNATIONAL ASSOCIATION OF FIRE CHIEFS & THE GAS SAFETY ACTION COUNCIL, A GAS CONSUMER ADVOCACY GROUP. A NUMBER OF NATIONAL INDUSTRY ORGANIZATIONS RECOGNIZE THE IMPORTANCE OF EXCESS FLOW VALVES. THE GAS PIPING TECHNICAL STANDARDS COMMITTEE, A BODY THAT MAKES RECOMMENDATIONS TO GAS OPERATORS ON SAFE OPERATIONS, IS DEVELOPING GUIDANCE ON SELECTING & USING EXCESS FLOW VALVES. THE MANUFACTURERS STANDARDIZATION SOCIETY & THE AMERICAN SOCIETY FOR TESTING & MATERIALS HAVE ISSUED STANDARDS TO ENSURE THE SAFE USE OF EXCESS FLOW VALVES. PENDING REVIEW OF THE ENCLOSED MATAERIAL & RECONSIDERATION OF THE RECOMMENDED ACTION, P-96-3 HAS BEEN CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE." WE BELIEVE THAT THE INFO PROVIDED SHOULD ENCOURAGE THE PSCN EITHER TO REQUIRE THE INSTALLATION OF EXCESS FLOW VALVES OR, AT THE VERY LEAST, TO IMPLEMENT A PUBLIC EDUCATION PROGRAM ENCOURAGING GREATER USE OF THESE SAFETY VALVES. THE BOARD WOULD APPRECIATE BEING KEPT INFORMED ABOUT YOUR STATE'S ACTIVITIES CONCERNING THE USE OF EXCESS FLOW VALVES. SAFETY BOARD STAFF WOULD BE PLEASED TO PROVIDE ADDITIONAL INFO OR TO ASSIST IN ANY WAY REGARDING THIS MATTER. Addressee Acronym: NV Addressee Organization Type: S-State Government Communication Date: 2000-07-06 Communication Type: Official Correspondence Communication Contents: ON 2/26/97, P-96-3 WAS CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE," BASED ON INFORMATION IN THE STATE OF NEVADA LETTER OF 4/16/96. TO DATE THERE HAS BEEN NO FURTHER RESPONSE TO P-96-3. THE SAFETY BOARD WOULD APPRECIATE LEARNING WHAT ACTION YOUR STATE HAS TAKEN TO IMPLEMENT THIS RECOMMENDATION. Addressee Name: State of Texas Addressee Status: Closed - Acceptable Alternate Action Addressee Date Closed: 1997-10-16 Addressee Acronym: TX Addressee Organization Type: S-State Government Communication Date: 1996-04-29 Communication Type: Official Correspondence Communication Contents: THE GOVERNOR, THROUGH THE RAILROAD COMMISSION OF TEXAS, ADVISED IT DOES NOT ANTICIPATE ACTING ON THIS RECOMMENDATION AT THIS TIME. IT ADVISED ALSO THAT IT IS CONTINUING TO MONITOR THE EFV ISSUE THROUGH THE RECOMMENDATIONS OF THE BOARD & THROUGH ACTIONS OF THE DOT. Addressee Acronym: TX Addressee Organization Type: S-State Government Communication Date: 1997-04-02 Communication Type: Official Correspondence Addressee Acronym: TX Addressee Organization Type: S-State Government Communication Date: 1997-04-30 Communication Type: Official Correspondence Addressee Acronym: TX Addressee Organization Type: S-State Government Communication Date: 1997-02-26 Communication Type: Official Correspondence Communication Contents: THE BOARD IS DISAPPOINTED THAT THE STATE OF TEXAS WILL NOT MANDATE THE USE OF EXCESS FLOW VALVES UNDER THE CONDITIONS IDENTIFIED IN THE SAFETY RECOMMENDATION & BELIEVES THAT THE CONCERNS OF THE RAILROAD COMMISSION OF TEXAS DO NOT ACCURATELY REFLECT THE PERFORMANCE OF EXCESS FLOW VALVES. WE ASK FOR A REVIEW OF THE ENCLOSURE PREPARED BY SAFETY BOARD STAFF ABOUT THE PROVEN BENEFITS OF EXCESS FLOW VALVES. IT PROVIDES INFO EXPLAINING THE PRFORMANCE CAPABILITY, RELIABILITY, & SAFETY BENEFITS OF EXCESS FLOW VALVES & IDENTIFIES COMMON MISCONCEPTIONS ABOUT THESE DEVICES. OUR ASSESSMENT OF AVAILABLE INFO IS THAT EXCESS FLOW VALVES ARE INEXPENSIVE, ARE RELIABLE & ARE TO ENHANCE PUBLIC SAFETY. THE BOARD BELIEVES THAT THE STATES MUST BECOME ACTIVE PROPONENTS OF EXCESS FLOW VALVES BECAUSE GAS CUSTOMERS & THE GENERAL PUBLIC RARELY ARE KNOWLEDGEABLE ABOUT THE DEVICES & HOW THEIR USE CAN MINIMIZE THE RISKS TO PEOPLE & PROPERTY IN THE EVENT OF A SEVICE LINE RUPTURE. THE BOARD POINTS OUT THAT P-96-3 ASKS THAT EXCESS FLOW VALVES BE INSTALLED ONLY WHEN OPERATING CONDITIONS ARE COMPATIBLE WITH COMMERCIALLY AVAILABLE VALVES. THE USE OF EXCESS FLOW VALVES IS SUPPORTED BY THE INTERNATIONAL ASSOCIATION OF FIRE CHIEFS & THE GAS SAFETY ACTION COUNCIL, A GAS CONSUMER ADVOCACY GROUP. A NUMBER OF NATIONAL INDUSTRY ORGANIZATIONS RECOGNIZE THE IMPORTANCE OF EXCESS FLOW VALVES. THE GAS PIPING TECHNICAL STANDARDS COMMITTEE, A BODY THAT MAKES REOMMENDATIONS TO GAS OPERATORS ON SAFE OPERATIONS, IS DEVELOPING GUIDANCE ON SELECTING & EXCESS FLOW VALVES. THE MANUFACTURERS STANDARDIZATIOIN SOCIETY & THE AMERICAN SOCIETY FOR TESTING & MATERIALS HAVE ISSUED STANDARDS TO ENSURE THE SAFE USE OF EXCESS FLOW VALVES. PENDING REVIEW OF THE ENCLOSED MATERIAL & RECONSIDERATION OF THE RECOMMENDED ACTION. P-96-3 HAS BEEN CLASSIFIED "OPEN--UNACCEPTABLE RESPONSE." WE BELIEVE THAT THE INFO PROVIDED SHOULD ENCOURAGE RAILROAD COMMISSION OF TEXAS EITHER TO REQUIRE THE INSTALLATION OF EXCESS FLOW VALVES OR, AT THE VERY LEAST, TO IMPLEMENT A PUBLIC EDUCATION PROGRAM ENCOURAGING GREATER USE OF THESE SAFETY VALVES. THE BOARD WOULD APPRECIATE BEING KEPT INFORMED ABOUT YOUR STATE'S ACTIVITIES CONCERNING THE USE OF EXCESS FLOW VALVES. THE BOARD STAFF WOULD BE PLEASED TO PROVIDE ADDITIONAL INFO OR TO ASSIST IN ANY WAY REGARDING THIS MATTER. Addressee Acronym: TX Addressee Organization Type: S-State Government Communication Date: 1997-10-16 Communication Type: Official Correspondence Addressee Name: State of South Carolina Addressee Status: Closed - Acceptable Alternate Action Addressee Date Closed: 2001-01-12 Addressee Acronym: SC Addressee Organization Type: S-State Government Communication Date: 2000-08-25 Communication Type: Official Correspondence Communication Contents: Letter Mail Controlled 08/31/2000 1:39:41 PM MC# 2001195 YOUR LETTER WAS FORWARDED TO THE PUBLIC SERVICE COMMISSION ON 3/29/96 FOR A RESPONSE. OUR RECORDS SUBSTANTIATE THAT MR. JAMES STITES, WHO WAS THE SAFETY DEPARTMENT MANAGER AT THAT TIME, DID INDEED RESPOND TO YOU BY LETTER ON 4/9/96. THEN, ON 4/16/96, YOU ACKNOWLEDGED THAT RESPONSE IN A LETTER TO MR. STITES (SEE COPIES OF EACH LETTER ENCLOSED). ALBEIT MR. STITES' RESPONSE MAY NOT HAVE BEEN ADEQUATE, INSOMUCH AS P-96-3 WAS NOT SPECIFICALLY REFERENCED AND DISCUSSED, NONETHELESS, A RESPONSE WAS MADE. SUBSEQUENTLY, I SHALL ATTEMPT TO MAKE A MORE PERSPICACIOUS RESPONSE. EFFECTIVE ON 2/3/99, AND THEREAFTER, THE U.S. DEPT. OF TRANSPORTATION (DOT) BEGAN REQUIRING PIPELINE OPERATORS TO NOTIFY ALL NEW AND REPLACED SERVICE LINE CUSTOMERS OF THE AVAILABILITY AND SAFETY BENEFITS OF THE EXCESS FLOW VALVE (EFV). (THE TEXT OF THE RULE IS FOUND IN TITLE 49 OF THE CODE OF FEDERAL REGULATIONS (CFR) PART 192.383). THIS RULE FURTHER REQUIRES OPERATORS TO INSTALL AND MAINTAIN THE EFV, AT THE CUSTOMER'S EXPENSE, FOR THE ENTIRE LIFE OF THE PIPELINE. AS WE ARE IN AGREEMENT WITH THE DOT AND OUR REGULATORY ACTIVITIES IN PIPELINE SAFETY ARE MONITORED BY THE OFFICE OF PIPELINE SAFETY'S SOUTHERN REGION OFFICE IN ATLANTA, GA, WE HAVE ADOPTED THE RULE AND ARE ENFORCING IT HERE IN SOUTH CAROLINA. IN EXECUTING THE RUDIMENTS OF OUR AGREEMENT, THE PUBLIC SERVICE COMMISSION OF SOUTH CAROLINA ACCEPTS 49 CFR PIPELINE SAFETY REGULATIONS AS ISSUED AND UPDATED AS NECESSARY BY THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION (RSPA) OF DOT. THESE GUIDELINES ARE INCORPORATED IN OUR COMMISSION RULES AND REGULATIONS GOVERNING GAS SYSTEMS. WE BELIEVE THAT THE EFV RULE HAS SUFFICIENTLY ADDRESSED AND ENCOMPASSED THE INTENT OF NTSB'S SAFETY RECOMMENDATION P-96-3. IT IS PURPORTED BY US TO INSURE THAT THE PIPELINE OPERATORS IN THIS STATE CONTINUE TO PROVIDE SAFE AND RELIABLE SERVICE TO THE PEOPLE OF SOUTH CAROLINA, AND THAT THE SAFETY OF THE GENERAL PUBLIC IS TO BE CONSIDERED FIRST AND FOREMOST AT ALL TIMES. I TRUST THAT THIS INFORMATION IS ACCEPTABLE AND SATISFIES ANY CONCERNS YOU HAVE HAD REGARDING SOUTH CAROLINA'S RESPONSIVENESS TO THIS AND ANY OTHER NTSB SAFETY RECOMMENDATIONS. HOPEFULLY, I HAVE EFFECTIVELY COMMUNICATED OUR APPARENT COMMON DESIRE TO PROMOTE PIPELINE INDUSTRY SAFETY AS A WHOLE. IF I CAN BE OF ANY FURTHER ASSISTANCE TO YOU OR OUR OFFICE IN THE FUTURE IN RELATION TO THIS MATTER OR OTHERS, PLEASE DO NOT HESITATE TO CALL ON ME. Addressee Acronym: SC Addressee Organization Type: S-State Government Communication Date: 1996-04-09 Communication Type: Official Correspondence Addressee Acronym: SC Addressee Organization Type: S-State Government Communication Date: 2001-01-12 Communication Type: Official Correspondence Communication Contents: THE SAFETY BOARD IS DISAPPOINTED THAT SOUTH CAROLINA HAS TAKEN NO ACTION TO REQUIRE GAS DISTRIBUTION OPERATORS TO INSTALL EFV'S. THE SAFETY BOARD NOTS THAT SOUTH CAROLINA HAS INCORPORATED IN ITS PUBLIC SERVICE COMMISSION RULES AND REGULATIONS GOVERNING GAS SYSTEMS THE REQUIREMENTS OF 49 CFR PIPELINE SAFETY REGULATIONS PART 192 TO NOTIFY NEW SERVICE LINE CUSTOMERS, AS WELL AS CUSTOMERS WHOSE SERVICE LINES HAVE BEEN REPLACED, OF THE AVAILABILITY AND SAFETY BENEFITS OF EFV'S. THE SAFETY BOARD DOES, HOWEVER, NOTE THAT SOUTH CAROLINA HAS INCORPORATED THE REQUIREMENTS OF 49 CFR PIPELINE SAFETY REGULATIONS PART 192 IN ITS PUBLIC SERVICE COMMISSION RULES AND REGULATIONS GOVERNING GAS SYSTEMS TO NOTIFY BOTH THESE GROUPS OF CUSTOMERS OF THE AVAILABILITY AND SAFETY BENEFITS OF EFV'S. ALTHOUGH THERE IS NO STATE REQUIREMENT MANDATING EFV'S, BECAUSE SOUTH CAROLINA HAS ADOPTED AND IS ENFORCING 49 CFR PART 192 AS ITS OWN REGULATIONS, P-96-3 IS CLASSIFIED "CLOSED--ACCEPTABLE ALTERNATE ACTION." Addressee Name: State of Minnesota Addressee Status: Closed - Acceptable Alternate Action Addressee Date Closed: 2001-12-10 Addressee Acronym: MN Addressee Organization Type: S-State Government Communication Date: 2001-09-07 Communication Type: Official Correspondence Communication Contents: Letter Mail Controlled 09/17/2001 3:55:24 PM MC# 2010737 The state's Office of Pipeline Safety has encouraged, but not mandated, the use of excess flow valves where practical. A review of the state's largest utilities that supply over 80% of the customers indicate the industry is doing this voluntarily where practical on all new and renewed services for single residences. Commercial customers are also having valves installed depending on the gas demand and service line size. The Office of Pipeline Safety continues to encourage smaller customers and municipals to do the same as part of their damage prevention education. The delayed development of an industry standard and adoption of federal rules requiring notification of EFV to residential customers was not required until February 3, 1999. Minnesota regulations incorporate these same notification procedures and performance standards in its state pipeline safety code. Therefore, we continue to evaluate the utilities customer notification and voluntary installation procedures in this area as part of our ongoing safety inspection and damage prevention efforts. Addressee Acronym: MN Addressee Organization Type: S-State Government Communication Date: 2001-07-19 Communication Type: Official Correspondence Communication Contents: On July 5, 2000, the Safety Board requested information on action the state of Minnesota had taken or intended to take to implement Safety Recommendation P-96-3. Because the Safety Board has received no reply, Safety Recommendation P-96-3 is classified "Closed--Unacceptable Action/No Response Received." If Minnesota has completed any action in response to this recommendation or initiates such action and informs the Board to that effect, the Board will evaluate the action and may reconsider the classification of this recommendation. Addressee Acronym: MN Addressee Organization Type: S-State Government Communication Date: 2001-12-10 Communication Type: Official Correspondence Communication Contents: The Safety Board notes that although Minnesota has not followed the recommendation in P-96-3 to require operators to install excess flow valves (EFVs), Minnesota has taken action which mirrors the Federal pipeline safety standards at Title 49 Code of Federal Regulations Part 192. Specifically, the Minnesota Office of Pipeline Safety has encouraged, but not mandated, the use of EFVs where practical. Reportedly, a review of the state's largest utilities, which supply gas to over 80 percent of Minnesota's customers, indicates that the industry is doing this voluntarily, where practical, on all new and renewed services for single residences. Commercial customers are also having valves installed, depending on the gas demand and service line size, and the Minnesota Office of Pipeline Safety will continue to encourage smaller customers and municipals to do the same as part of their damage prevention education. The Safety Board understands that the development of an industry standard was delayed, and adoption of federal rules requiring notification of residential customers regarding EFV availability was not required until February 3, 1999; the Board further understands that Minnesota regulations incorporate these same notification procedures and performance standards in its state pipeline safety code. Finally, Minnesota will continue to evaluate the utilities' customer notification and voluntary installation procedures in this area as part of the state's ongoing safety inspection and damage prevention efforts. Although Minnesota has not enacted a state requirement mandating EFVs, the state has provided a viable alternative by adopting and enforcing standards similar to those of the Federal regulations at Title 49 CFR Part 192. Accordingly, Safety Recommendation P-96-3 to Minnesota is classified "Closed--Acceptable Alternate Action." Addressee Name: State of Michigan Addressee Status: Closed - Acceptable Alternate Action Addressee Date Closed: 2000-10-03 Addressee Acronym: MI Addressee Organization Type: S-State Government Communication Date: 2000-08-08 Communication Type: Official Correspondence Communication Contents: Letter Mail Controlled 08/11/2000 3:36:14 PM MC# 2001048 MICHIGAN'S GAS PIPELINE SAFETY PROGRAM IS ADMINISTERED BY THE MICHIGAN PUBLIC SERVICE COMMISSION. THE PUBLIC SERVICE COMMISSION HAS ADOPTED THE FEDERAL PIPELINE SAFETY STANDARDS 49 CFR 192.381 AND 192.383, WHICH WERE ADDITIONAL SAFETY STANDARDS ADOPTED TO ADDRESS SIMILAR SAFETY BOARD RECOMMENDATIONS TO THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION AND RELATED CONGRESSIONAL REQUIREMENTS. STANDARD 192.381 ADDRESSES PERFORMANCE STANDARDS FOR EXCESS FLOW VALVES, AND STANDARD 192.383 REQUIRES THE NOTIFICATION OF CUSTOMERS REGARDING THE AVAILABILITY OF EXCESS FLOW VALVES AND REQUIRES THE OPERATOR TO INSTALL EXCESS FLOW VALVES IF THE CUSTOMER REQUESTS A VALVE BE INSTALLED. MOST OPERATORS IN MICHIGAN ARE INSTALLING EXCESS FLOW VALVES ON THE SERVICE LINES IN QUESTION BECAUSE IT IS LESS COSTLY THAN COMPLYING WITH THE NOTIFICATION REQUIREMENTS. MICHIGAN HAS APPROXIMATELY 3,000,000 NATURAL GAS CUSTOMERS, AND UTILITIES ADD ABOUT 50,000 CUSTOMER PER YEAR. OPERATORS THAT ADOPTED A POLICY OF INSTALLING EXCESS FLOW VALVES REPRESENT UTILITIES SERVING OVER 95 PERCENT OF OUR STATE'S NATURAL GAS CUSTOMERS. IF YOU HAVE FURTHER QUESTIONS REGARDING THIS ISSUE, PLEASE DIRECT THEM TO MICHAEL KIDD, DIRECTOR OF THE PUBLIC SERVICE COMMISSION'S GAS DIVISION. HE CAN BE REACHED AT 517-241-6131. Addressee Acronym: MI Addressee Organization Type: S-State Government Communication Date: 2000-10-03 Communication Type: Official Correspondence Communication Contents: THE SAFETY BOARD IS PLEASED TO LEARN THAT MICHIGAN HAS ADOPTED THE FEDERAL PIPELINE SAFETY STANDARDS TITLE 49 CFR 192.381, WHICH ADDRESSES PERFORMANCE STANDARDS FOR EXCESS FLOW VALVES (EFV'S), AND TITLE 49 CFR 192.383, WHICH REQUIRES (1) THE NOTIFICATION OF CUSTOMERS REGARDING THE AVAILABILITY OF EFV'S AND (2) OPERATOR INSTALLATION OF EFV'S IF THE CUSTOMER REQUESTS THAT A VALVE BE INSTALLED. THE BOARD UNDERSTANDS THAT MOST OPERATORS IN THE STATE ARE INSTALLING EFV'S ON THE SERVICE LINES IN QUESTION BECAUSE IT IS LESS COSTLY THAN COMPLYING WITH THE NOTIFICATION REQUIREMENTS. ALTHOUGH MICHIGAN HAS NO STATE REQUIREMENT MANDATING EFV'S, BECAUSE THE STATE HAS ADOPTED TITLE 49 CFR PART 192.381 AND 192.383, P-96-3 IS CLASSIFIED "CLOSED--ACCEPTABLE ALTERNATE ACTION." Addressee Name: State of Georgia Addressee Status: Closed - Acceptable Alternate Action Addressee Date Closed: 2000-10-03 Addressee Acronym: GA Addressee Organization Type: S-State Government Communication Date: 2000-08-07 Communication Type: Official Correspondence Communication Contents: Letter Mail Controlled 08/15/2000 1:42:42 PM MC# 2001071 THE GPSC IS THE PROPER AGENCY TO CONTACT REGARDING NATURAL GAS INTRASTATE PIPELINE SAFETY MATTERS. IN THE FUTURE, PLEASE SEND ALL SUCH INQUIRIES TO THE GPSC AT 47 TRINITY AVENUE, S.W., ATLANTA, GEORGIA 30334. ENCLOSED YOU WILL FIND COPIES OF CFR SECTIONS 192.381 AND 192.383 AS ADOPTED AND CURRENTLY ENFORCED BY OUR PIPELINE SAFETY SECTION. IF WE CAN BE OF FURTHER ASSISTANCE, PLEASE LET US KNOW. Addressee Acronym: GA Addressee Organization Type: S-State Government Communication Date: 2000-10-03 Communication Type: Official Correspondence Communication Contents: THE SAFETY BOARD NOTES THAT THE PIPELINE SAFETY SECTION OF THE GEORGIA PUBLIC SERVICE COMMISSION, HAS ADOPTED AND ENFORCES TITLE 49 CFR SECTIONS 192.381 AND 192.383 WHICH ADDRESS PERFORMANCE STANDARDS AND CUSTOMER NOTIFICATION, RESPECTIVELY. ALTHOUGH THERE IS NO STATE REQUIREMENT MANDATING EFV'S, GEORGIA HAS ADOPTED AND IS INFORCING TITLE 49 CFR PART 192. THEREFORE, P-96-3 IS CLASSIFIED "CLOSED--ACCEPTABLE ALTERNATE ACTION." Addressee Name: State of Tennessee Addressee Status: Closed - Acceptable Alternate Action Addressee Date Closed: 2000-11-14 Addressee Acronym: TN Addressee Organization Type: S-State Government Communication Date: 2000-08-18 Communication Type: Official Correspondence Communication Contents: Letter Mail Controlled 08/23/2000 3:16:40 PM MC# 2001131 WHEN THIS RECOMMENDATION WAS INITIALLY PROPOSED, AND CONTINUING AFTER ITS ADOPTION BY THE NTSB, MANY STATES QUESTIONED THE APPROPRIATENESS OF THE RECOMMENDATION ON MANY GROUNDS, INCLUDING, BUT NOT LIMITED TO, THE EFFECTIVENESS OF THE EFV'S. WE HAVE RECENTLY LEARNED THAT THE NTSB NO LONGER LISTS EFV'S ON THE LIST OF "MOST WANTED TRANSPORTATION SAFETY IMPROVEMENTS." IN FACT, AS CONCERNING THIS ISSUE, IT IS OUR UNDERSTANDING THAT THE NTSB CURRENTLY ENCOURAGES EDUCATION AND TRAINING RELATED TO DAMAGE PREVENTION INSTEAD. THE STATE OF TENNESSEE IS FULLY COMMITTED TO LIMITING THE LOSS OF LIFE, INJURY, AND PROPERTY DAMAGE DUE TO GAS LEAKAGE CAUSED BY PIPELINE OR SERVICE LINE DAMAGE. WITH THIS COMMITMENT IN MIND, IN JULY OF THIS YEAR, THE TRA CONDUCTED A STATEWIDE SURVEY REGARDING THE PERFORMANCE AND USE OF EFV'S IN NATURAL GAS PIPELINE DISTRIBUTION SYSTEMS. THE RESULTS FROM THE SURVEY INDICATED THAT ALL SYSTEMS ARE MAKING AVAILABLE TO THEIR CUSTOMERS EFV'S FOR PURCHASE OR INCLUDING THEM IN THE INSTALLATION OF ALL NEW SERVICE LINES. FURTHERMORE, DURING THEIR INSPECTIONS, OUR GAS PIPELINE SAFETY ENGINEERS HAVE FOUND FULL COMPLIANCE WITH SECTION 192.383: EXCESS FLOW VALVE CUSTOMER NOTIFICATION REQUIREMENTS OF THE MINIMUM FEDERAL SAFETY STANDARDS (NFSS). IN FACT, THE TRA HAS ONLY CITED ONE OPERATOR FOR NON-COMPLIANCE WITH SECTION 192.383 OF THE NWSS SINCE THE EFFECTIVE DATE OF THE REGULATION. FINALLY, RECENT MODIFICATIONS TO THE "TENNESSEE UNDERGROUND DAMAGE PREVENTION LAW" AND TENNESSEE'S PARTICIPATION IN THE FEDERAL OFFICE OF PIPELINE SAFETY'S - **truncated:** true - **body characters:** 150679