NTSB Safety Recommendation P-98-036

NTSB safety recommendation P-98-036.

THE NTSB RECOMMENDS THAT THE RSPA: REVISE 49 CODE OF FEDERAL REGULATIONS PART 195 TO INCLUDE PERFORMANCE MEASURES FOR THE ADEQUATE CATHODIC PROTECTION OF LIQUID PIPELINES.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1998-11-18

Adopted Date: 1998-11-06

Overall Date Closed: 2002-07-22

Synopsis: ON SATURDAY, 8/24/96, ABOUT 3:26 P.M., AN 8-INCH-DIAMETER STEEL LPG (LIQUEFIED PETROLEUM GAS) PIPELINE TRANSPORTING LIQUID BUTANE, OPERATED BY KOCH PIPELINE COMPANY, LP (KOCH), RUPTURED NEAR LIVELY, TEXAS, SENDING A BUTANE VAPOR CLOUD INTO A SURROUNDING RESIDENTIAL AREA. THE BUTANE VAPOR IGNITED AS TWO AREA RESIDENTS IN A PICKUP TRUCK DROVE INTO THE VAPOR CLOUD. THE PEOPLE DIED AT THE ACCIDENT SITE FROM THERMAL INJURIES. ABOUT 25 FAMILIES WERE EVACUATED FROM THE AFFECTED AREA. KOCH ESTIMATED ITS DIRECT PIPELINE LOSSES, INCLUDING THE LOSS OF PRODUCT FROM THE LINE, TO BE ABOUT $217.000. OTHER PROPERTY LOSSES INCLUDED DAMAGE TO THE ROADWAY UNDER WHICH THE RUPTURE OCCURRED & DAMAGE TO A PICKUP TRUCK, A MOBILE HOME, SEVERAL OUTBUILDINGS, & ADJACENT WOODLANDS.

Probable Cause: The failure of Koch to adequately protect its pipeline from corrosion.

Ntsbnumber: DCA96FP007

Report Number: PAR-98-02-SUM

Addressee Name: RSPA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2002-07-22

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-03-19

Communication Type: NPRM Response

Communication Contents: Notation 7338: The National Transportation Safety Board has reviewed the Notice of Proposed Rulemaking (NPRM) that would add Subpart H, covering corrosion control, to the existing 49 CFR Part 195. The Safety Board is pleased that corrosion control requirements are being improved and consolidated in a separate subpart. The Safety Board has investigated numerous hazardous liquid pipeline accidents in which corrosion played a significant role. On September 9, 1987, as a result of its investigation of a July 8, 1986, hazardous liquid pipeline accident at Mounds View, Minnesota, the Safety Board recommended that the Research and Special Programs Administration (RSPA): P-87-24 Revise 49 Code of Federal Regulations Part 195 to include criteria, similar to those found in Part 192, against which liquid pipeline operators can evaluate their cathodic protection systems. Because RSPA took no action on this recommendation, the Safety Board, on January 23, 1996, classified Safety Recommendation P-87-24 “Closed-Unacceptable Action.” Unfortunately, external corrosion continues to account for a significant number of petroleum product pipeline accidents. On November 18, 1998, as a result of its investigation of an August 24, 1996, hazardous liquid pipeline accident near Lively, Texas, the Safety Board issued the following safety recommendations to RSPA: P-98-35 Revise 49 Code of Federal Regulations Part 195 to require pipeline operators to determine the condition of pipeline coating whenever pipe is exposed and if degradation is found, to evaluate the coating condition of the pipeline. P-98-36 Revise 49 Code of Federal Regulations Part 195 to include performance measures for the adequate cathodic protection of liquid pipelines. In its April 12, 1999, response to the Safety Board regarding these two safety recommendations, RSPA stated that it was rewriting the corrosion regulations for hazardous liquid pipelines and that it would further explore the issue of requiring that the pipeline coating be examined whenever a buried pipeline is exposed for any reason. RSPA also noted that it was developing criteria and performance measures for adequate cathodic protection of hazardous liquid pipelines and that it would include these in the revised corrosion regulations. Pending the adoption and publication of new regulations, the Safety Board, on November 30, 1999, classified these two recommendations “Open Acceptable Response.” In April 200, RSPA provided an update indicating that the subject NPRM would be issued in the year 2000. The proposed Section 195.565 would require that an operator exposing any portion of a buried pipeline examine the exposed portion for evidence of external corrosion if the pipe is bare or if the coating is deteriorated. The section would not, however, require the operator to conduct any further examination or evaluation of the pipeline if no corrosion damage requiring remedial action (Sec. 195.583) is observed underneath the deteriorated coating. The Safety Board is concerned that even if no significant corrosion damage is observed underneath disbonded coating at a particular excavation location, a similar disbonded condition could exist at other locations along the pipeline, and these locations could have significant damage or could provide suitable sites for future corrosion. Therefore, the Safety Board believes that if the exposed portion of the pipeline shows indications of damaged or disbonded coating, the operator should take appropriate action to determine the condition of the coating at other locations on the pipeline, especially at locations adjacent to these with identified coating problems. The Safety Board thus believes that the proposed Subpart H, section 195.565, should be revised to address this issue and to meet the intent of Safety Recommendation P-98-35. As noted in the NPRM, while the proposed Section 195.567 would require that an operator comply with one or more of the applicable criteria for cathodic protection cited in Section 6 of NACE Standard RP0169-96, it would also allow the use of alternative criteria as provided by paragraph 6.2.1 of the NACE standard. That is, an operator could continue using its existing “successfully applied” criteria so long as those criteria achieve corrosion control “comparable” to that which would be achieved by the criteria described in paragraph 6.2.2 of the NACE standard. In the NPRM, RSPA states its view that protection criteria, in order to be considered both successful and comparable, would have to result in the absence of corrosion leaks or metal loss due to corrosion on the pipeline between inspections or test. The Safety Board is comfortable with this interpretation and endorses its incorporation into the final rule. RSPA has invited comments on whether the entire NACE Standard RP0169-96 should be considered as an alternative to the proposed Subpart H. In the view of the Safety Board, NACE Standard RP0169-96 often is not specific or stringent enough. For example, the NACE standard does not explicitly state that each underground structure should have cathodic protection, nor does it require that cathodic protection be provided within a specified period of time after installation. Also, the NACE Standard refers to several other standards (for example, in the coatings section). The OPS may or may not have input into the revision of these other standards, and it must consider any difficulty it may experience in maintaining adequate requirements. Section 195.555 identifies the pipelines that are covered by the proposed Sections 195.557, 195.559, and 195.561. The Safety Board notes that because of the applicable date clauses, these sections may not cover some older pipelines. Considering the number of pipeline accidents that have involved older pipe, the Safety Board urges RSPA to apply Sections 195.559 and 195.561 to all pipelines, regardless of age, or, as an alternative, to require more frequent inspections of older pipelines. Further, the Safety Board believes that the requirement in section 195.559 (like the previous section 195.242 that it replaces) that an operator install a cathodic protection system “not later than one year after completing the construction” is not always appropriate. For example, in an aggressive corrosive environment, an unprotected pipe can corrode in less than 1 year. Because construction of a pipeline may take more than a year, the Safety Board believes that an operator should be required to install and operate a cathodic protection system within a reasonable but specified period of time after a pipe is buried, considering its environment. Section 195.587, requires the operator to keep records related to: • Examination of a buried pipeline when exposed (195.565). • Cathodic protection monitoring/test data (195.569 (a)). • Evaluation data of active corrosion on unprotected pipelines (195.569 (c)). • Internal corrosion coupon/monitoring data (195.577 (c)). • Internal corrosion inspection data when a pipe is removed from a pipeline (195.577 (d)). These records must be kept for as long as the pipeline remains in service. Because good historical data are necessary to identify potential corrosion problems and/or to determine the effectiveness of any implemented solution to an observed corrosion problem, the Safety Board supports this record-keeping requirement. The Safety Board appreciates the opportunity to comment on this proposed rulemaking. If additional clarification of information is needed regarding our comments, feel free to contact us.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-04-18

Communication Type: Official Correspondence

Communication Contents: The Safety Board is aware of the reported action that has been taken on these issues and appreciates the RSPA update. Specifically, RSPA reports that in accordance with its risk-based regulatory philosophy, it intends to incorporate a process into its regulations to validate pipe integrity, especially in high-consequence areas. RSPA staff provided a briefing to Safety Board staff on a new initiative to examine effective methods to maintain pipeline integrity in high-consequence areas. In addition, RSPA has issued a Notice of Proposed Rulemaking (NPRM) concerning pipeline integrity management for pipeline operators who operate 500 or more miles of hazardous liquid pipelines. On September 13, 2000, the Safety Board provided its comments regarding this NPRM. On December 1, 2000, RSPA issued its rule for operators who operate 500 or more miles of hazardous liquid pipelines. The Board is also aware that RSPA plans to issue NPRMs covering the balance of operators of hazardous liquid pipelines, as well as operators of natural gas transmission pipelines. The Safety Board is also aware that on December 8, 2000, RSPA issued a NPRM to address P-98-35 and -36. The Safety Board is reviewing the NPRM and expects to provide comments in the near future. The Board notes that your April 24, 2000, letter did not provide specific information on Safety Recommendations P-87-26, P-90-29, P-95-2, and P-98-34 through -36. We are aware, however, through staff contact of some ongoing activity with respect to these recommendations; these recommendations are currently classified "Open--Acceptable Response." The Safety Board would appreciate specific information on actions taken by RSPA to meet these safety recommendations so that RSPA's progress on these issues can be evaluated.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-07-22

Communication Type: Official Correspondence

Communication Contents: RSPA has taken action as requested, Safety Recommendations P-98-35 and -36 are classified "Closed--Acceptable Action."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-11-30

Communication Type: Official Correspondence

Communication Contents: THE SAFETY BOARD UNDERSTANDS THAT RSPA PLANS TO MAKE THE APPROPRIATE AMENDMENTS TO 49 CFR, AS REQUESTED, FOR ALL THESE RECOMMENDATIONS. PENDING THE PUBLICATION OF THE FINAL RULES, P-98-35 THROUGH -38 HAVE BEEN CLASSIFIED "OPEN--ACCEPTABLE RESPONSE." THE BOARD WOULD APPRECIATE PERIODIC UPDATES ON THE STATUS OF THESE AMENDMENTS.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-05-20

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 05/23/2002 9:15:00 AM MC# 2020529 On December 27,2001, RSPA issued a final rule updating the corrosion control standards for hazardous liquid and carbon dioxide pipelines (66 FR 66994). The changes are based on a review of the adequacy of the present standards compared to similar standards for gas pipelines and acceptable corrosion practices. The changes are intended to improve the clarity and effectiveness of the present standards and to reduce the potential for pipeline accidents due to corrosion. The corrosion rule addresses NTSB Recommendations P-98-35 and P-98-36. The revised Section 195.565 requires pipeline operators to determine the condition of pipeline coating whenever pipe is exposed and, if degradation is found, to evaluate the coating condition of the pipeline. Section 195.567 of the rule requires that cathodic protection comply with one or more of the applicable criteria and other considerations for cathodic protection contained in section 6 of the NACE Standard RPOl69-96, Control of External Corrosion on Underground or Submerged Metallic Pipeline Systems.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-04-12

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 7/28/99 1:05:21 PM MC# 990814 RSPA IS DEVELOPING CRITERIA AND PERFORMANCE MEASURES FOR ADEQUATE CATHODIC, PROTECTION OF HAZARDOUS LIQUID PIPELINES. RSPA WILL INCLUDE PERFORMANCE MEASURES FOR ADEQUATE CATHODIC PROTECTION OF LIQUID PIPELINES IN THE REVISED CORROSION REGULATIONS. RSPA IS DEVELOPING REGULATIONS IN CONSULTATION WITH PIPELINE COMPANY SPECIALISTS AND REPRESENTATIVES OF TECHNICAL STANDARDS COMMITTEES, INCLUDING NACE INTERNATIONAL, THE LEADING ASSOCIATION OF 9 CORROSION PROFESSIONALS. IN EARLY APRIL, RSPA WILL ISSUE A NOTICE OF PUBLIC MEETING TO BE HELD ON 4/28/99, IN SAN ANTONIO, TEXAS, TO RECEIVE PUBLIC COMMENTS ON PIPELINE CORROSION PROTECTION AND PERFORMANCE MEASURES. RSPA EXPECTS TO PROPOSE REVISED CORROSION REGULATIONS FOR HAZARDOUS LIQUID PIPELINES DURING THE SUMMER 1999 THAT WILL THOROUGHLY ADDRESS PERFORMANCE MEASURES FOR CATHODIC PROTECTION. A MATRIX OF POSSIBLE CHANGES IN THE HAZARDOUS LIQUID CORROSION REGULATIONS IS ENCLOSED. PENDING ADOPTION OF THE NEW CORROSION REGULATIONS, WE REQUEST THAT P-98-36 BE CLASSIFIED AS "OPEN--ACCEPTABLE RESPONSE."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2000-04-24

Communication Type: Official Correspondence

Communication Contents: Corrosion Control: Following a pipeline incident near Lively, Texas, NTSB Safety Recommendation P-98-34 urged RSPA to require Koch Pipeline Company to "evaluate the integrity of its HVL pipeline, including the condition of the coating, and rehabilitate the pipeline as necessary." In late 1999, I approved a final rule to require operators to undertake this kind of evaluation. NTSB Safety Recommendation P-98-35 and P-98-36 suggested that the hazardous liquid pipeline regulations be revised to require operators to investigate for corrosion and to determine the condition of coating whenever pipe is exposed for any reason, and that the regulations include performance measures for cathodic protection (NTSB Safety Recommendations P-98-35 and P-98-36). As discussed at the most recent meeting of our staffs, corrosion is the second leading cause of reported gas and hazardous liquid pipeline incidents. We are considering the need to modernize and clarify our corrosion control regulations. We have held two public meetings and several group meetings with corrosion experts from industry and state regulatory agencies. Participants at these meetings have emphasized the importance of considering safety data, risk, and cost/benefit when assessing the need to change the regulations. RSPA is now reviewing and considering the comments. We expect to publish a Notice of Proposed Rulemaking in 2000 to modernize and clarify the corrosion control regulations. RSPA believes this action will fully address the issues in NTSB Safety Recommendations P-98-35 and P-98-36.