NTSB Safety Recommendation P-99-001

NTSB safety recommendation P-99-001.

THE NTSB RECOMMENDS THAT THE RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION: WHEN REVIEWING PIPELINE OPERATOR SAFETY PROGRAMS, ENSURE THAT THE OPERATORS' DAMAGE PREVENTION PROGRAMS INCLUDE ACTIONS TO PROTECT THEIR FACILITIES WHEN DIRECTIONAL DRILLING OPERATIONS ARE CONDUCTED IN PROXIMITY TO THOSE FACILITIES.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1999-04-28

Adopted Date: 1999-04-20

Overall Date Closed: 1999-10-27

Synopsis: ABOUT 2:33 P.M. ON 7/21/97, A 20-INCH-DIAMETER STEEL NATURAL GAS TRANSMISSION PIPELINE OWNED AND OPERATED BY CITIZENS GAS & COKE UTILITY COMPANY (CITIZENS GAS) RUPTURED AND RELEASED NATURAL GAS NEAR AN INTERSECTION ADJOINING THE CHARTER POINTE SUBDIVISION IN INDIANAPOLIS, IN. THE GAS IGNITED AND BURNED, KILLING ONE RESIDENT AND INJURING ANOTHER. ABOUT 75 RESIDENTS REQUIRED TEMPORARY SHELTER. SIX HOMES WERE DESTROYED, AND ABOUT 65 OTHERS SUSTAINED DAMAGE SIGNIFICANT ENOUGH TO BE DOCUMENTED BY THE LOCAL INVESTIGATION TEAM.

Probable Cause: The National Transportation Safety Board determined that the probable cause of this accident was the failure of Citizens Gas and Miller to have adequate controls in place to ensure that directional drilling operations carried out in the proximity of existing underground facilities would not cause damage to those facilities.

Ntsbnumber: DCA97FP005

Report Number: PAB-99-02

Addressee Name: RSPA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 1999-10-27

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-11-19

Communication Type: NPRM Response

Communication Contents: Notation 8060: 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 Federal Regulations Part 192, to require operators of gas distribution pipelines to develop and implement integrity management programs. Proposed Regulatory Approach The NPRM 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. PHMSA 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 single-family 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 pipeline operators have taken action t

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2001-04-18

Communication Type: Official Correspondence

Communication Contents: THE SAFETY BOARD APPRECIATES THE UPDATE ON ACTIONS TO IMPLEMENT P-97-14 THROUGH -24 AND P-99-1. WITH RESPECT TO P-99-1, THE SAFETY BOARD NOTES THAT ON 10/27/99, BASED ON INFORMATION PROVIDED IN THE RSPA LETTER OF 8/6/99, P-99-1 WAS CLASSIFIED "CLOSED--ACCEPTABLE ACTION."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-10-27

Communication Type: Official Correspondence

Communication Contents: THE SAFETY BOARD IS PLEASED TO NOTE THAT RSPA REVISED ITS INSPECTION FORM FOR HAZARDOUS LIQUID PIPELINES TO SPECIFICALLY EXAMINE HOW OPERATORS MONITOR TRENCHLESS TECHNOLOGY OPERATIONS IN THE VICINITY OF UNDERGROUND PIPELINES. THE "LOCATING AND MARKING PIPELINES (DAMAGE PREVENTION)" SECTION ON THIS FORM NOTES THE CRITICALITY OF LOCATING BURIED PIPE AND OF THE QUALIFICATIONS OF PERSONNEL PERFORMING THIS WORK, WHETHER EMPLOYED BY THE OPERATOR OR BY CONTRACT SERVICES SUCH AS A LINE LOCATING COMPANY, A CORROSION SURVEY COMPANY, OR PIPELINE SURVEYORS. FURTHER, WE UNDERSTAND THAT RSPA IS MAKING SIMILAR CHANGES TO THE NATURAL GAS INSPECTION FORM AND, IN THE INTERIM, IS PROVIDING SUPPLEMENTAL INSPECTION GUIDANCE TO NATURAL GAS INSPECTORS. BECAUSE RSPA HAS TAKEN ACTION AS REQUESTED, P-99-1 HAS BEEN CLASSIFIED "CLOSED--ACCEPTABLE ACTION."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1999-08-06

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 8/18/99 10:12:36 AM MC# 990903 RSPA REVISED ITS INSPECTION FORM FOR HAZARDOUS LIQUID PIPELINES TO SPECIFICALLY EXAMINE HOW OPERATORS MONITOR TRENCHLESS TECHNOLOGY OPERATIONS IN THE VICINITY OF UNDERGROUND PIPELINES. ATTACHMENT 1 IS A COPY OF THE SECTION OF THE INSPECTION FORM RELATING TO "LOCATING AND MARKING PIPELINES (DAMAGE PREVENTION)." THIS SECTION NOTES THE CRITICALITY OF LOCATING BURIED PIPE, AND THE QUALIFICATION OF PERSONNEL PERFORMING THIS WORK, WHETHER EMPLOYED BY THE OPERATOR OR BY CONTRACT SERVICE (E.G. LINE LOCATE COMPANY, CORROSION SURVEY COMPANY, PIPELINE SURVEYORS). RSPA REVISED THIS SECTION OF THE INSPECTION FORM BECAUSE RECENT ACCIDENTS HAVE DEMONSTRATED THE NEED FOR ADDITIONAL DILIGENCE WHEN DIRECTIONAL DRILLING IS USED IN PROXIMITY TO A PIPELINE. FURTHER, THE FORM NOW DIRECTLY ASKS WHETHER THE OPERATOR'S DAMAGE PREVENTION PROGRAM INCLUDES ACTIONS TO PROTECT ITS FACILITIES WHEN DIRECTIONAL DRILLING OPERATIONS ARE CONDUCTED IN PROXIMITY TO THE FACILITIES. RSPA IS CURRENTLY MAKING SIMILAR CHANGES TO THE NATURAL GAS INSPECTION FORM. IN THE MEANTIME, RSPA IS PROVIDING SUPPLEMENTAL INSPECTION GUIDANCE TO THE NATURAL GAS INSPECTORS. RSPA ISSUED AN ADVISORY BULLETIN TO INFORM PIPELINE OPERATORS OF THE HAZARDS OF DIRECTIONAL DRILLING AND WAYS TO PROTECT THEIR UNDERGROUND FACILITIES. BECAUSE FACILITIES ARE AT DIFFERENT DEPTHS DUE TO VARYING REGULATORY REQUIREMENTS AND BUSINESS PRACTICES, THIS ADVISORY EMPHASIZES THE POSSIBILITY OF DAMAGING UNDERGROUND FACILITIES WITHOUT BEING AWARE OF IT. THE ADVISORY BULLETIN (ATTACHMENT 2) ALSO PROVIDES INFORMATION ON THE INSPECTION FORM DISCUSSED ABOVE. RSPA BELIEVES THESE ACTIONS FULLY ADDRESS NTSB RECOMMENDATION P-99-1. WE REQUEST THAT THIS RECOMMENDATION BE CLASSIFIED AS "CLOSED--ACCEPTABLE ACTION."

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 2000-04-24

Communication Type: Official Correspondence

Communication Contents: On June 30, 1999, RSPA co-sponsored a public meeting in Washington, DC, to present a report on damage prevention best practices. The report was developed by over 160 volunteers representing a broad spectrum of damage prevention stakeholders who worked for almost a year to produce a report on best practices in damage prevention, known as the Common Ground Study. This report covered virtually every aspect of damage prevention from design and planning, through locating and safe excavation practices. It has become the manual of choice for those involved in damage prevention. We are gratified that you were able to join us to present this report to Transportation Secretary Rodney Slater. RSPA is now facilitating the establishment of a non-profit organization to advance underground damage prevention, consistent with the cooperative spirit of the Common Ground team. RSPA held a public meeting on October 28, 1999, in Baltimore, Maryland, to elaborate the elements of an effective non-profit organization, including possible mission statements, goals, functions, guiding principles, and organizational structure. NTSB's Jack Fox participated in this event. On February 17, 2000, a broad-based coalition of industry leaders in the pipeline and underground damage prevention communities met to launch the teams that will develop and staff the new organization. RSPA believes that with the support of Congress and the U.S. Department of Transportation (DOT), we can provide the necessary resources to initiate the creation of a self-sustaining private sector non-profit organization and ensure the participation of all affected stakeholders. We believe this organization will provide an effective forum for information sharing among all stakeholders in damage prevention. This will include regular interaction with the affected industries in the damage prevention community. We believe the organization can contribute to creative solutions to underground damage prevention issues and to our attempts to respond fully to a number of "Open" NTSB Safety Recommendations, including P-97-14 through 24, and P-99-1. In addition, RSPA has been deploying a national damage prevention public education campaign, known as the Dig Safely campaign. This effort dates back to October 1996, when we formed the Damage Prevention Quality Action Team (DAMQAT). This team included a broad spectrum of representatives: professional excavators, one-call centers, insurance, telecommunications, operators of hazardous liquid, natural gas transmission and distribution lines as well as state pipeline safety agencies, and RSPA's OPS. The DAMQAT conducted an extensive examination of the problem, including a nationwide survey of 1500 respondents from the excavator, facility operator, and public works communities, as well as the general public. DAMQAT used the results of the national survey to develop a "tag line," a message, and a design for education campaign materials. These materials included a safety video, print ads for trade publications, a radio public service announcement, brochures, and bill inserts. These were field tested for six months in three states, Virginia, Georgia, and Alabama. Pre-pilot and post-pilot surveys enabled the team to judge the effectiveness of the materials. Data collected from the three states indicate a sharp increase in recognition of the four basic messages of the campaign: call before you dig, wait the required time, observe the marks, and dig with care. All three states reported a decline in excavation-related damage to underground facilities. In addition, DAMQAT commissioned a training manual for those who want to use the campaign materials. It contains general information on how to conduct a damage prevention campaign, as well as the safety video, and two CD ROMS which contain all the campaign artwork. DAMQAT team members have conducted over thirty Dig Safely training sessions nationwide. Another six are scheduled and more are being planned. The DAMQAT was recently renamed the Dig Safely Team, is expanding its membership and hopes to include other interested parties such as locators, cable TV, electricity, water and sewer. Some of the materials will be translated into Spanish for distribution in areas with a significant Spanish speaking population. The Dig Safely Campaign has been officially endorsed by DOT, the American Petroleum Institute, One Call Systems International, the Association of Oil Pipelines, and the National Telecommunications Damage Prevention Council. The National Energy Board of Canada is considering recommending to the Canadian Government that they adopt the campaign.