NTSB Safety Recommendation P-98-002

NTSB safety recommendation P-98-002.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (ORIGINALLY ISSUED TO RSPA): Determine the extent of the susceptibility to premature brittle-like cracking of older plastic piping (beyond that piping marketed by Century Utility Products, Inc.) That remains in use for gas service nationwide. Inform gas system operators of the findings & require them to closely monitor the performance of the older plastic piping & identify & replace, in a timely manner, any of the piping that indicates poor performance based on such evaluation factors as installation, operating, & environmental conditions; piping failure characteristics; & leak history.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1998-04-30

Adopted Date: 1998-04-23

Overall Date Closed: 2010-04-28

Synopsis: Despite the general acceptance of plastic piping as a safe and economical alternative to piping made of steel or other materials, the board notes that a number of pipeline accidents it has investigated have involved plastic piping that cracked in a brittle-like manner. For example, on 10/17/94, an explosion and fire in Waterloo, Iowa, destroyed a building and damaged other property. Six persons died and seven were injured in the accident. The board investigation determined that natural gas has been released from a plastic service pipe that had failed in a brittle-like manner at a connection to a steel main.

Probable Cause: None

Ntsbnumber: DCA95MP001

Report Number: SIR-98-01

Addressee Name: RSPA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2010-04-28

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2003-03-17

Communication Type: Official Correspondence

Communication Contents: In response to Safety Recommendation P-98-2, RSPA, in conjunction with the American Gas Association (AGA), the American Public Gas Association (APGA), the Plastics Pipe Institute, the Gas Research Institute, and industry, formed the Joint Government-Industry Plastic Pipe Study Committee. This committee determined that the data necessary to definitely identify all polyethylene pipes did not exist, as gas operators had not maintained data on the manufacturers of the plastic pipe installed in their systems through the years. Nevertheless, the committee identified several types of polyethylene pipe materials that are known to exhibit a susceptibility to brittle-like cracking, including the following: · Century Utility Products, Inc. products. · Low-ductile inner wall "Aldyl A" piping manufactured by E. I. Dupont Company prior to 1973. · Polyethylene gas pipe designated PE 3306. (As a result of poor performance, this designation was removed from ASTM D-25 13.) Subsequently, the Plastic Pipe Database Committee (PPDC), with membership comprising representatives of all fifty states, members from the National Association of Pipeline Safety Representatives, the National Association of Regulatory Commissioners, and Safety Board staff observers, was formed to develop a process for gathering data on future plastic pipe failures. The PPDC is coordinating the creation of a database, managed by AGA, of in-service plastic piping material failures with the objective of identifying trends in the performance of these materials. RSPA reports that as of January 25, 2002, approximately 140 companies were actively participating in the program, and according to the AGA, these companies operate about 55 percent of all installed plastic main lines and about 70 percent of all installed plastic service lines in the United States. The PPDC has requested that the AGA and the APGA encourage additional participation, focusing on companies that may have declined to participate because they have had few, if any, plastic material failures. The PPDC is seeking data from individual states that have instituted data collection efforts. RSPA also advises that the data will allow it, the PPDC, and the gas system operators to identify failure trends that may be susceptible to brittle-like cracking and to further understand the phenomenon. Further, the data supplied by participants in the PPDC initiative will be analyzed to determine the frequency and causes of plastic material failures unrelated to third-party damage and will provide an accurate picture of the performance of plastic pipe. The Safety Board appreciates the continuing data collection efforts of the PPDC along with RSPA's work towards completion of this issue. Accordingly, Safety Recommendation P-98-2 is classified OPEN -- ACCEPTABLE RESPONSE.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-04-28

Communication Type: Official Correspondence

Communication Contents: The NTSB has reviewed PHMSA’s final rule, published on December 4, 2009, Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines, which requires operators of gas distribution pipelines to develop and implement integrity management programs. Because the new regulations, along with the initiatives described in PHMSA’s February 3, 2010, letter, satisfy the recommendation, Safety Recommendation P 98-2 is classified CLOSED -- ACCEPTABLE ACTION.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-04-02

Communication Type: Official Correspondence

Communication Contents: The NTSB is currently reviewing the action taken by PHMSA on the above recommendations, identified in your letter, and expects to have a more substantive response back to you shortly. We apologize for the delay in responding regarding some of the recommendations; however, additional documentation was needed for these before their evaluation for closure could be completed. Action on Safety Recommendation R-89-53 (see enclosure) was completed on March 19, 2010.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2009-09-22

Communication Type: Official Correspondence

Communication Contents: On November 18, 2008, the NTSB provided comments to the docket regarding PHMSA’s notice of proposed rulemaking (NPRM), Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines, which was published at 73 Federal Register 36015 on June 25, 2008. PHMSA proposed to amend the federal pipeline safety regulations, 49 Code of Federal Regulations Part 192, to require operators of gas distribution pipelines to develop and implement integrity management programs. PHMSA anticipates that this rule will be finalized by summer 2010. The NTSB notes that the Plastic Pipe Database Committee, with representation from government and industry, recently completed collecting 5 years of data for in-service plastic piping material failures and is in the process of documenting the results. The NTSB further notes that the Gas Distribution Integrity Management Program Report found a need for the American Society for Testing and Materials (ASTM) to consider enhancing performance testing for plastic pipe fittings, and the ASTM is currently addressing these issues. The NTSB is pleased that PHMSA is considering requiring operators to report, either by telephone or through PHMSA’s website, suspect older plastic pipe resulting from failure as part of a distribution integrity management program; we encourage PHMSA to implement such a requirement. In the meantime, pending publication of the final integrity management rules, Safety Recommendation P-98-2 is classified OPEN -- ACCEPTABLE RESPONSE. Safety Recommendation P-01-2, stated below, was issued to PHMSA on June 22, 2001, as a result of the NTSB’s investigation of the July 7, 1998, natural gas explosion and fire in South Riding, Virginia.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-11-15

Communication Type: Official Correspondence

Communication Contents: The Safety Board notes that RSPA recognizes the Board's concern regarding the susceptibility to brittle-like cracking failures of plastic pipe systems installed prior to 1980 and that RSPA published an advisory bulletin in March 1999 that addresses the potential for premature brittle-like failures of older plastic pipe. The Safety Board points that RSPA's advisory bulletin, 'Potential Failures Due to Brittle-like Cracking of Older Plastic Pipe in Natural Gas Distribution Systems', recommends that pre-1982 plastic pipe installations be addressed. However, as indicated in the Board's special investigation report, the plastic pipe institute advised the industry that, effective January 1986, all materials not demonstrating validated performance to 100,000 hours would be dropped from its listing. Accordingly, P-98-2 has been classified OPEN – ACCEPTABLE RESPONSE pending further information from RSPA on evaluating approaches to develop an understanding of the brittle-like cracking phenomenon and the susceptibility of older plastic pipe to brittle-like cracking failures, including random testing of field sample pipe, and pending information on whether RSPA intends to require operators to closely monitor the performance of the older plastic piping and to identify and replace, in a timely manner, any piping that indicates poor performance.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1998-10-21

Communication Type: Official Correspondence

Communication Contents: The Board would appreciate being advised of any actions that RSPA has taken or plans to take on each of these recommendations. Copies of our 1/6/98, and our 4/30/98, correspondence are enclosed.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2000-07-13

Communication Type: Official Correspondence

Communication Contents: On 11/15/99, based on information in the RSPA letter of 3/17/99, P-98-1 through -5 were classified OPEN – ACCEPTABLE RESPONSE, pending further reply from RSPA. Copies of recommendations P-87-34, P-90-21, P-95-4, P-96-1, P-97-6, P-97-7, P-97-8, P-98-1, P-98-2, P-98-3, P-98-4, P-98-5, and P-98-25 and associated correspondence are enclosed. The Safety Board would appreciate learning of any action taken or planned to comply with these recommendations, especially P-97-7 and -8, which may be discussed at a board meeting.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-02-11

Communication Type: Official Correspondence

Communication Contents: NMC# 103112: The Safety Board notes that the Plastic Pipe Database Committee, with representation from government and industry, recently completed collecting 5 years of data for in-service plastic piping material failures and is in the process of documenting the results. The Board further notes that the Gas Distribution Integrity Management Program Report found a need for the American Society for Testing and Materials (ASTM) to consider enhancing performance testing for plastic pipe fittings, and the ASTM is currently addressing these issues. In addition, PHMSA will seek comments on some plastic-pipe issues in its rulemaking regarding the management of gas distribution integrity management. On September 6, 2007, PHMSA also issued an advisory bulletin that addresses vintage plastic pipes. The Board appreciates the steady progress being made by PHMSA on this recommendation. Accordingly, Safety Recommendation P-98-2 is classified OPEN -- ACCEPTABLE RESPONSE, pending completion of the integrity management initiatives.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-11-19

Communication Type: Official Correspondence

Communication Contents: In a respone to a PHMSA NPRM, the Safety Board made the following comments: The National Transportation Safety Board has reviewed the Pipeline and Hazardous Materials Safety Administration's (PHMSA's) notice of proposed rulemaking (NPRM), "Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines," that was published at 73 Federal Register 36015 on June 25, 2008. PHMSA is proposing to amend the Federal pipeline safety regulations, 49 Code of Federul Regulutions Part 192, to require operators of gas distribution pipelines to develop and implement integrity management programs. Proposed Regulatory Approach The IVPRM proposes requiring operators of distribution pipeline systems to develop integrity management programs that would have the same objectives as the existing integrity management programs for hazardous liquid and gas transmission pipeline systems. Integrity management programs require operators to identify and invest in risk control measures, identify and manage factors that affect risks to the pipeline, and integrate the best available information about the pipeline in order to make informed risk management decisions. The Safety Board notes that PHMSA is proposing a regulatory approach to integrity management programs for distribution lines that accounts for the design and operational differences between gas distribution systems and hazardous liquid or gas transmission pipelines. The Safety Board supports this approach and agrees that, overall, the NPRM provides a reasonable and logical approach that operators of distribution pipelines can use to develop and implement integrity management plans. Integrity management programs for hazardous liquid or gas transmission pipelines generally require the operators to assess the condition of their pipelines primarily by using in-line inspection tools and pressure testing, which yield direct information on the condition of the pipelines. However, the pipe used in distribution pipelines has a smaller diameter than the pipe used in hazardous liquid or transmission pipelines. Distribution pipelines also tend to have many bends and service lines that branch off. Consequently, using in-line inspection tools for the typical distribution pipeline system is not feasible. PHMSA notes that because distribution pipelines operate at far lower pressures than hazardous liquid or gas transmission pipelines, the failure of a distribution pipeline is typically detected from reports of a gas leak rather than from a catastrophic rupture, which often occurs when hazardous liquid and gas transmission pipelines fail. Therefore, the implementation of an effective leak management program is, in the Board's view, an important element of an integrity management program for a distribution pipeline. An effective leak management program must prescribe the use of equipment that prevents or mitigates leaks and establish criteria for monitoring and, if necessary, replacing aging components susceptible to failure. Consequently, the Board believes that the NPRM does not adequately address the use of excess flow valves (EFVs) and compression couplings. PWMSA also notes in the NPRM that the leading causes of accidents on distribution pipelines include excavation damage and equipment failures. PHMSA does not address directional drilling, a major cause of excavation damage. Addressing these areas as discussed in the sections that follow can strengthen the NPRM. Leak Management The principal tools for detecting leaks in a distribution pipeline are leak surveys, corrosion control surveys, odorization surveys, and valve inspections; the use of all these tools is required under current safety regulations for distribution systems. Effective leak management depends on combining the data yielded by each of these tools, statistically analyzing the combined data to determine the problems within a system, and correcting the problems before they pose an unacceptable risk to public safety. However, an effective leak management program must also prescribe the use of equipment that prevents or mitigates leaks and must discourage the use of unreliable components. The Board believes that the NPRM is not sufficiently explicit about the use of EFVs to mitigate leaks or about the risks posed by compression couplings, as discussed in the following sections. Excess Flow Valves In 1974, the Safety Board investigated the explosion of a commercial building in New York city.' Over the next 34 years, the Safety Board investigated 17 accidents and issued 20 recommendations, as well as a recommendation to each governor of the 50 States, urging the use of EFVs for all distribution pipeline systems. The Pipeline Integrity, Protection, Enforcement, and Safety (PIPES) Act of 2006 mandated that PHMSA require operators of distribution pipeline systems to install EFVs after June 1, 2008, on all new and replacement service lines to singlefamily residences. Further, the PIPES Act mandated that the requirement be incorporated in the integrity management rulemaking for distribution pipeline systems. Because the rulemaking was delayed, PHMSA issued an advisory bulletin (ADB-08-04) on May 30, 2008, which was published in the Federal Register on June 5, 2008. The bulletin advised operators that as of June 1, 2008, EFVs must be installed on new and replacement services for single-family homes that operate continuously at a pressure above 10 pounds per square inch, guage, and that are not connected to a gas stream with a history of contaminants. Although the NPRM and the advisory bulletin may satisfy the mandate of the PIPES Act, they fail to require EFVs for apartment buildings, other multifamily dwellings, and commercial properties, which are susceptible to the same risks from damaged service lines as single-family residences. On June 22,2001, the Board recommended that PHMSA: Require that excess flow valves be installed in all new and renewed gas service lines, regardless of a customer's classification, when the operating conditions are compatible with readily available valves. (P-01-2) The recommendation was issued as the result of the Board's investigation of the July 7, 1998, natural gas explosion and fire that destroyed a newly constructed residence in South Riding, a community in Loudoun County, Virginia. The accident caused one fatality and one serious injury. The Safety Board determined that the service line to a home had failed and that an uncontrolled release of gas had accumulated in the basement and subsequently ignited. The Board concluded from its investigation that had an EFV been installed in the service line, the EFV would have closed after the hole in the service line developed and the explosion likely would not have occurred. The Board urges PHMSA to amend the NPRM to require EFVs on all new and renewed service lines for all gas service customers, regardless of customer classification, as specified in Safety Recommendation P-01-2, when the operator's conditions are compatible with readily available valves. Compression Couplings Between 1970 and 1990, the Safety Board investigated 20 accidents involving pipe in distribution systems that had pulled out of compression couplings. The Board issued 32 safety recommendations on the subject and attributed the causes of the pullouts to various factors and conditions, such as thermal contraction of the pipe and soil, overpressurization, and mechanical damage. Following the successful implementation of several of the Safety Board's recommendations, the number of accidents involving compression couplings decreased significantly. From 1991 to 2004, the Board investigated only three such accidents, and it did not issue any safety recommendations to PHMSA about compression couplings. However, because of incidents involving compression couplings, four States since the 1990s have been increasingly demanding that the couplings be replaced, and, in a few instances, individual distribution

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-06-21

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 7/6/2010 1:08:34 PM MC# 2100235 - From Cynthia L. Quarterman, Administrator: Thank you for your letter of April 28 regarding the closing of the National Transportation Safety Board (NTSB) safety recommendations P-98-2 and P-99-12. The Pipeline and Hazardous Materials Safety Administration appreciates the expedited response from the NTSB regarding these safety recommendations. We take our responsibility to the safety recommendations put forth by the NTSB seriously and work hard to fulfill the requirements of the recommendations. Should you require further information or assistance, please feel free to contact me.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-12-11

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 12/18/2002 3:01:52 PM MC# 2021044 - From Ellen G. Engleman, Administrator: In Safety Recommendation P-98-2, NTSB asked RSPA to determine the extent of the susceptibility to premature brittle-like cracking of older plastic piping (beyond that piping marketed by Century Utility Products, Inc.) that remain in use for gas service nationwide. To directly address the issue of the susceptibility of older plastic piping to brittle-like cracking, RSPA invited pipeline operators, industry trade organizations, and States to participate in a special committee. In May 1999 a meeting was convened with representatives from the RSPA, the American Gas Association (AGA), the American Public Gas Association (APGA), the Plastics Pipe Institute, the Gas Research Institute, and Industry. The group was referred to as the .Joint Government-Industry Plastic Pipe Study Committee. This Committee reviewed the knowledge base within the pipeline industry and determined that the data necessary to definitely identify all polyethylene pipe did not exist. It was found that gas operators have not maintained data on the manufacturer(s) of the plastic pipe installed in their systems through the years. Although the data available was limited, the Committee identified several types of polyethylene pipe materials that are known to exhibit a susceptibility to brittle-like cracking, including: · Century Utility Products, Inc. products. · Low-ductile inner wall "Aldyl A" piping manufactured by E. I. Dupont Company prior to 1973. · Polyethylene gas pipe designated PE 3306. (As a result of poor performance this designation was removed from ASTM D-25 13.) This finding led to the formation of the Plastic Pipe Database Committee (PPDC) to develop a process for gathering data on future plastic pipe failures. It was at this time that the NTSB and the States (including members from the National Association of Pipeline Safety Representatives (NAPSR) and the National Association of Regulatory Commissioners (NARUC)) were invited to participate. The PPDC is coordinating the creation of a database of in-service plastic piping material failures with the objective of identifying trends in the performance of these materials. The AGA manages the database on behalf of the PPDC. As of January 25, 2002, approximately 140 companies were actively participating in the program. According to the AGA, these companies operate about 55% of all installed plastic main and about 70% of all installed plastic service lines in the United States. The PPDC has requested that the AGA and the APGA encourage additional participation, focusing on companies that may have declined to participate because they have had few, if any, plastic material failures. The PPDC is also seeking data from individual States that have instituted data collection efforts. The data will allow the RSPA, the PPDC, and the gas system operators to identify failure trends that may be susceptible to brittle-like cracking and to further understand the phenomenon. The data supplied by participants in the PPDC initiative will be analyzed to determine the frequency and causes of plastic material failures unrelated to third-party damage and will provide an accurate picture of the performance of plastic pipe. RSPA is also pleased to announce two research projects, funded in September 2002, which should advance our ability to map and locate plastic pipe. These projects will include developing a 3D digital mapping system for detecting steel and plastic underground utilities and leaks in all types of soil, and developing magnetic plastic polyethylene gas pipe that is easier to locate. In the next few months, RSPA will solicit white papers for additional research projects in the areas of improved material performance and enhanced operations, controls, and monitoring. RSPA believes that the continuing data collection efforts of the PPDC along with RSPA's commitment to identify and fund research in areas specifically addressing NTSB Safety Recommendations will keep these issues active and eventually meet the full intent of P-98-2. Based on the information provided above, RSPA requests that NTSB Safety Recommendation P-98-2 be reclassified as "CLOSED-Acceptable Action."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-02-03

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 2/23/2010 3:26:19 PM MC# 2100063 - From Cynthia L. Quarterman, Administrator: In response to NTSB Recommendation P-98-2, PHMSA issued three advisory bulletins on March 11, 1999; November 26, 2002; and September 6, 2007. These advisory bulletins notified operators and states of possible safety problems associated with plastic pipe and alerted operators concerning the need to monitor the pipe's performance and to take necessary action(s) to remedy problems. In addition, PHMSA is developing new regulatory requirements for pipeline distribution systems under its Distribution Integrity Management Program (DIMP) rulemaking. In an NPRM published June 25, 2008, PHMSA proposed to require all operators to report data on failures that occur in plastic pipe and appurtenances. PI-IMSA would collect and analyze the failure information and communicate its conclusions to distribution system operators for inclusion in the operators' integrity management programs. Enhanced data collection and analysis will significantly improve operators' ability to identify and address potential integrity issues related to plastic pipe. PHMSA plans to issue a final rule by the end of 2009. In addition, the Plastic Pipe Database Committee (PPDC), a voluntary group administered by American Gas Association (AGA), monitors in-service performance of plastic pipe. This information is voluntarily submitted and shared only among AGA members, although PPDC includes representatives of PHMSA, states, the American Public Gas Association, and the National Transportation Safety Board. The PPDC has agreed to ask its voluntary participants to allow their names to be included in the quarterly report. This would allow regulators to recognize those operators who have a proactive approach to the data gathering and dissemination critical to the PPDC. The Committee has also consented to expand the scope of the database to collect and report all leaks/failures associated with plastic pipe systems (jurisdictional gathering, transmission, distribution [mains and services]).

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-03-15

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 3/16/2010 1:16:29 PM MC# 2100096 - From Cynthia L. Quarterman, Administrator: I greatly appreciated meeting with you last month concerning the National Transportation Safety Board's (NTSB) recommendations to the Pipeline and Hazardous Materials Safety Administration (PHMSA). I look forward to meeting with you again, along with staff, on Tuesday, March 16th. Your recommendations, based on lessons learned from accident investigations, provide valuable safety information to our programs. We are committed toconsidering each of the recommendations and implementing those that are positive improvements in safety. I have been meeting with PHMSA's hazmat and pipeline safety programs to assess our actions on the NTSB recommendations. We are addressing these safety issues by taking actions to assure that the "unacceptable actions" are moved into the "open-acceptable" category and to achieve a "closed-acceptable" in a timely manner on as many recommendations as possible. I recognize that a number of "open-acceptable" recommendations are works in progress and maytake a year or more to complete. You indicated your interest in getting these issues resolved as well. As you requested, I asked our pipeline and hazmat staff to compile a copy of outstanding letters to the NTSB that request a change in the classification of a recommendation. I have attached a copy of those letters and am hopeful you and I can successfully resolve a number of these issues. In addition, I have askedour Chief Safety Officer, Cindy Douglass, and our Associate Administrators, Jeff Wiese for Pipeline Safety and Magdy El-Sibaie for Hazardous Materials Safety, to meet with your staff to help us better understand each recommendation and to clarify the actions the NTSB considers necessary for closure. Again, I look forward to meeting with you on these safety concerns and believe that, together, we will make a positive difference in the safe transportation of hazardous materials, including those transported by pipelines.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-12-08

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 12/10/2008 3:05:08 PM MC# 2080723 - From Rick Kowalewski, Acting Assistant Administrator/ Chief Safety Officer: Safety recommendation P-98-02 asked that PHMSA determine the extent of susceptibility to premature brittle-like cracking of older plastic piping that remains in use for gas service nationwide. The Plastic Pipe Database Committee, which includes representatives from PHMSA, NTSB, American Gas Association, American Public Gas Association, Plastics Pipe Institute, Gas Research Institute, industry, and State regulators, recently completed collecting data and preparing a table for in-service plastic piping material failures. The data collected from 2001 to present, on the Nation’s natural gas distribution systems includes both actual failure information and negative reports submitted voluntarily by participating pipeline operating companies. The data indicates the susceptibility of additional specific materials to brittle-like cracking. Based on the findings. On September 6,2007, PHMSA issued an updated notification of the susceptibility of premature brittle-like cracking of vintage plastic pipe. Additionally, our Gas Distribution Integrity Management Program Report found need for the American Society for Testing and Materials (ASTM) to consider enhancing performance testing for plastic pipe fittings. ASTM is currently addressing these issues. Further, PI-IMSA has also gone beyond the recommendation and is considering requiring operators to report by telephone or through PHMSA’s website suspect older plastic pipe resulting from failure as part of a distribution. Integrity management program. We issued an NPRM ‘‘Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines" on June 25,2008, and hope to finalize this rulemaking by summer 2009.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2009-10-16

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 10/22/2009 3:09:01 PM MC# 2090655 - From John D. Porcari, Deputy Secretary of Transportation: In response to NTSB Recommendation P-98-2, PHMSA issued three advisory bulletins on March 11, 1999; November 26,2002; and September 6,2007. These advisory bulletins notified operators and states of possible safety problems associated with plastic pipe and alerted operators concerning the need to monitor the pipe's performance and to take necessary action(s) to remedy problems. In addition, PHMSA is developing new regulatory requirements for pipeline distribution systems under its Distribution Integrity Management Program (DIMP) rulemaking. In an NPRM published June 25,2008, PHMSA proposed to require all operators to report dataon failures that occur in plastic pipe and appurtenances. PI-IMSA would collect and analyze the failure information and communicate its conclusions to distribution system operators for inclusion in the operators' integrity management programs. Enhanced data collection and analysis will significantly improve operators' ability to identify and address potential integrity issues related to plastic pipe. PHMSA plans to issue a final rule by the end of 2009. In addition, the Plastic Pipe Database Committee (PPDC), a voluntary group administered by American Gas Association (AGA), monitors in-service performance of plastic pipe. This information is voluntarily submitted and shared only among AGA members, although PPDC includes representatives of PHMSA, states, the American Public Gas Association, and the National Transportation Safety Board. The PPDC has agreed to ask its voluntary participants to allow their names to be included in the quarterly report. This would allow regulators to recognize those operators who have a proactive approach to the data gathering and dissemination critical to the PPDC. The Committee has also consented to expand the scope of the database to collect and report all leaks/failures associated with plastic pipe systems (jurisdictional gathering, transmission, distribution [mains and services]).

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-03-17

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 9/17/1999 3:30:10 PM MC# 990813 - From Kelley S. Coyner, Administrator: RSPA recognizes NTSB's concern regarding the susceptibility to brittle-like cracking failures of the plastic pipe systems installed prior to 1980. Technical committee f17 of the American Society for Testing and Materials (ASTM) is currently establishing now acceptance standards in standards ASIM D2513 and D2837 to ensure that plastic pipe used in gas service has superior long-term serviceability. The membership of this committee is drawn from a variety of plastic pipe interests, including gas transmission and distribution pipeline operators, state and Federal regulatory personnel, plastic pipe manufacturers and vendors and engineering consultants. Based on research sponsored by the Gas Research Institute at the University of Pennsylvania, the consensus of the ASTM F17 committee members is that the current acceptance criteria in ASTM D2513 will provide a life expectancy of at least 50 years, unless the plastic pipe is subjected to excessive loading that causes stress intensification. Although strength loss due to aging alone has not been widely reported, RSPA technical staff is actively participating in the ASTM technical committee to develop methods to determine the susceptibility to brittle-like failures in the plastic pipe manufactured and installed prior to 1980. RSPA will evaluate the need for regulations addressing older plastic piping system after a review of the committee's findings. RSPA is evaluating various approaches to develop an understanding of the brittle-like cracking phenomenon and the susceptibility of older plastic pipe to brittle-like cracking failures, including random testing of field sample pipe. In addition, RSPA has published an advisory bulletin addressing the potential for premature brittle-like failures of older plastic pipe. RSPA believes the advisory bulletin, coupled with the efforts of the ASTM technical committees, will fully address this recommendation. RSPA requests that P-98-2 be classified as "Open--Acceptable Action."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2007-07-31

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 8/8/2007 2:24:08 PM MC# 2070395 - From Stacey L. Gerard, Assistant Administrator/ Chief Safety Officer: The Plastic Pipe Database Committee includes representatives from PHMSA, NTSB, American Gas Association, American Public Gas Association, Plastics Pipe Institute, Gas Research Institute, industry, and State regulators. The committee recently completed collecting data for in-service plastic piping material failures, and is now creating a table documenting the results. The committee plans to complete this table by April 2007. Additionally, the Gas Distribution Integrity Management Program Report found need for the American Society for Testing and Materials (ASTM) to consider enhancing performance testing for plastic pipe fittings. ASTM is currently addressing these issues. PHMSA plans to seek comments on some plastic pipe issues in its gas distribution integrity management rulemaking, which it plans to issue this fall. PHMSA has developed an advisory bulletin to address vintage plastic pipes that it plans to issue later this summer.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-07-13

Communication Type: Official Correspondence

Communication Contents: [via email from Cheryl.Whetsel@rspa.dot.gov] The Plastic Pipe Database Committee (PPDC), with representatives from RSPA, the National Transportation Safety Board, the American Gas Association (AGA), the American Public Gas Association (APGA), the Plastics Pipe Institute, the Gas Research Institute, industry, and the States, continue to coordinate a database of in-service plastic piping material failures with the objective of identifying areas of concern in the performance of these materials. Once an area of significant concern is identified, the committee would recommend what additional work should be done to further determine if a definitive susceptibility exists to brittle-like cracking. AGA manages the database on behalf of the PPDC. As of January 25, 2003, approximately 156 companies were actively participating in the program. According to the AGA, these companies operate about 61% of all installed plastic main and about 69% of all installed plastic service lines in the United States. These percentages reflect both the number of participants and the yearly total plastic mains and services in the U.S. The PPDC has requested that AGA and APGA encourage additional participation, focusing on companies that may have declined to participate because they have had few, if any, plastic material failures. The PPDC has also sought data from individual States, specifically New York and Texas, that have instituted data collection efforts, and is seeking to further complement the data base with DOT-reportable incident data involving plastic material failures submitted by companies that do not participate in the data collection effort. It was determined that the New York state data are duplicative, since most of the operators in New York already send in data to the PPDC database. The Texas data are collected annually, and are of limited use to the PPDC, as they do not contain the minimum information required for meaningful analysis by the PPDC. As a result of this effort, two historically known types of susceptible materials were identified in addition to the three named above; they are Delrin insert tap keys and Plexco service tee Celon (polyacetal) cap, both showing brittle-like failures due to over-tightening of the cap. In summary, the PPDC database will allow RSPA, the PPDC, and the gas system operators to point to possible failure trends that may be susceptible to brittle-like cracking and to further understand the phenomenon. The data supplied by participants in the PPDC initiative will be analyzed to determine the frequency and causes of plastic material failures unrelated to third-party damage and will provide an accurate preliminary picture of the performance of plastic pipe Data are still being collected from the participating operators and the PPDC has determined that at least 5 years worth of data must be collected. This is because the primary indicators of plastic material failure are leaks found through periodic leak surveys. Since the regulation-mandated period for leak surveys runs as a 5-years in certain portions of the operators' surveys, the data collected must at least cover this period to ensure the entire gas system is covered. The data collection started on January 25, 2001. Therefore, to complete the database, data must be collected till January 25, 2006.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2005-02-28

Communication Type: Official Correspondence

Communication Contents: In its 2/28/2005 report to Congress, "Open Statutory Mandates Regarding Pipeline and Hazardous Materials Safety," the DOT wrote: Database of in-service plastic piping material failures is being developed. Data collection will continue until January 2006.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2006-04-14

Communication Type: Official Correspondence

Communication Contents: In its 4/14/2006 report to Congress, "National Transportation Safety Board (NTSB) and DOT Office of Inspector General (OIG): At PHMSA's request, representatives of NTSB, American Gas Association, American Public Gas Association, Plastic Pipe Institute, Gas Research Institute, and industry and State regulators joined together to form the Plastic Pipe Database Committee to collect and review plastic piping data. The first complete cycle of data is now available from operators' reports on leaks. PHMSA assembled the Gas Distribution Integrity Management Team to define how integrity management can be impbented for gas distribution pipeline operators. The Distribution Team Report is now complete. One of the recommendations in the report states that the American Society for Testing and Materials should enhance performance test protocols for plastic pipe fittings, to incorporate protocols for evaluation of older plastic dated issues and to add requirements for permanent marking of pipes. PHMSA plans to recommend inclusion of brittle-like cracking on older plastic pipe in the Distribution integrity management guidance.