NTSB Safety Recommendation Letter P-82-042

Page 1Official PDFNATIONAL TRANSPORTATION SAFETY BOARD Y WASHINGTON, D.C, ISSUED: October 5, 1982 ------------------- ----,----_______..__ Forwarded to: ~ _ _ _ _ _ _ ", Honorable Howard Dugoff Administrator Research and Special Programs SAFETY RECOMMENDAT I ON (S) Administration U.S. Department of Transportation Washington, D.C. 20590 P-82-42 4 The National Transportation Safety Board has reviewed the Notices published by t h e Materials Transportation Bureau (MTB) of t h e U.S. Department of Transportation: "Petiti.on f o r Waiver" and "Grant of Waiver," Docket No. 82-3W, Notices Nos. 1 and 2, which appeared a t 41 FR 16248 and 4 1 FR 20715 on A p r i l 15, 1982, and May 13, 1982, respectively. Both Notices concerned t h e r e p a i r of g i r t h weld d e f e c t s i n approximately 635 miles of 42-inch diameter gas transmission p i p e l i n e constructed by t h e Northern Border P i p e l i n e Company (Company). This p i p e l i n e s e c t i o n was constructed i n 1981 through t h e S t a t e s of Montana, North Dakota, Minnesota, and Iowa. The Notices a l s o concerned 1, possible r e p a i r of d e f e c t s i n approximately 181 miles (of pipeline) t o be constructed i n 1982." A s reported i n Notice No. 1, t h e weld d e f e c t s were not detected by t h e Company's x-ray technicians responsible f o r q u a l i t y assurance, but r a t h e r when an a u d i t of t h e weld x-rays w a s performed a f t e r t h e pipe was buried. The Safety Board is concerned t h a t important i s s u e s r a i s e d by t h e a u d i t were not pursued by t h e MTB before t h e waiver was granted, f o r example: 1. Why were these weld flaws not detected and corrected immediately a f t e r they were x-rayed? 2. Why did weld flaws occur only i n t h e e a s t e r n s e c t o r and not i n t h e western s e c t o r of t h i s p i p e l i n e ? 3. Were the x-ray technicians properly q u a l i f i e d and adequately experienced? 4. Were the welders properly q u a l i f i e d f o r t h e procedures used? 5. Did t h e Company employ enough q u a l i f i e d inspectors t o assure t h a t a l l welding was done i n compliance with i t s standards? 3549#

Page 2- 2 - It is apparent t h a t i n constructing t h e 635-mile p i p e l i n e , the Company d i d not perform adequately t h e inspection and t e s t i n g required by 49 CFR 192.241(c), nor d i d it meet t h e applicable provisions of t h e 15th Edition of API Standard 1104, "Standard f o r Welding Pipe Lines and Related F a c i l i t i e s . " It is a matter of concern t o t h e Safety Board t h a t t h e Office of t h e Federal Inspector, which is responsible f o r assuring compliance with t h e Federal s a f e t y requirements by t h e Company, did not d e t e c t these v i o l a t i o n s during i t s monitoring of t h e Company's construction and t h a t t h e MTB apparently has not pursued any inquiry i n t o t h i s matter. Further, i n granting t h e requested waiver, t h e MTB d i d n o t r e q u i r e any a c t i o n t o address, i n f u t u r e construction, those areas of noncompliance by t h e Company or t o improve t h e q u a l i t y of compliance monitoring by t h e Federal Inspector. The Safety Board b e l i e v e s t h a t such a c t i o n was urgently needed t o minimize t h e p o s s i b i l i t y of f u t u r e p i p e l i n e construction containing flawed g i r t h welds or o t h e r defects. The Safety Board i s aware t h a t t h e 1st remaining "to be b u i l t " miles of p i p e l i n e construction covered by t h e waiver already have been completed. Nevertheless, t h e Safety Board b e l i e v e s t h a t t h e answers t o t h e above questions should have been of p r i o r i t y concern t o t h e MTB and should have d i c t a t e d t h a t t h e MTB r e q u i r e changes i n t h e q u a l i t y control program established f o r the construction of t h e remaining 181 m i l e s of p i p e l i n e r a t h e r than grant a waiver i n advance of a demonstrated need. Therefore, t h e National Transportation Safety Board recommends t h a t t h e Research and Special Programs Administration: Discontinue t h e p r a c t i c e of granting waivers prospectively which permits t h e r e p a i r r a t h e r then t h e replacement of d e f e c t i v e welds on p i p e l i n e s y e t t o be constructed. (Class 11, P r i o r i t y Action) (P-82-42) BURNETT, Chairman, GOLDMAN, Vice Chairman, McADAMS, BURSLEY, and ENGEN, Members, concurred i n t h i s recommendation. By: @&&& J i m Burnett Chairman /#