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Pipeliners Podcast host Russel Treat flies solo in this episode discussing the 2019-2020 NTSB “Most Wanted List.” Russel dissects the open safety recommendations published by the NTSB, specifically the safety notices for pipeline operators, gas utilities, PHMSA, and vendors.

In addition to listening to the podcast, take the time to review the information and resources in the episode show notes and on the NTSB website at NTSB.gov.

NTSB Most Wanted List: Show Notes, Links, and Insider Terms

  • NTSB (National Transportation Safety Board) is a U.S. government agency responsible for the safe transportation through Aviation, Highway, Marine, Railroad, and Pipeline. The entity investigates incidents and accidents involving transportation and also makes recommendations for safety improvements.
  • HCA (High-Consequence Areas) are defined by PHMSA as a potential impact zone that contains 20 or more structures intended for human occupancy or an identified site. PHMSA identifies how pipeline operators must identify, prioritize, assess, evaluate, repair, and validate the integrity of gas transmission pipelines that could, in the event of a leak or failure, affect HCAs.
  • ILI (Inline Inspection) is a method to assess the integrity and condition of a pipe by determining the existence of cracks, deformities, or other structural issues that could cause a leak.
  • A Hydrostatic Pressure Test is a method to use pressure to evaluate the strength of a pipe and determine the presence of leaks.
  • Integrity Management (Pipeline Integrity Management) is a systematic approach to operate and manage pipelines in a safe manner that complies with PHMSA regulations.
  • MAOP (maximum allowable operating pressure) was included in a bulletin issued by PHSMA informing owners and operators of gas transmission pipelines that if the pipeline pressure exceeds MAOP plus the build-up allowed for operation of pressure-limiting or control devices, the owner or operator must report the exceedance to PHMSA on or before the fifth day following the date on which the exceedance occurs. If the pipeline is subject to the regulatory authority of one of PHMSA’s State Pipeline Safety Partners, the exceedance must also be reported to the applicable state agency.
  • Chromosome karyotype refers to a test to identify and evaluate the size, shape, and number of chromosomes in a sample of body cells to help identify malformities.
  • PermaLock® mechanical tapping tee assemblies are used by gas utility companies to connect a service line to the main gas line.
    • The NTSB issued a notice to Honeywell regarding the incorrect installation of the tapping tees. This followed a 2017 incident in Millersville, Pa. that resulted in an accident involving a natural gas explosion and fire. [Read the NTSB Notice]
  • The San Bruno or PG&E Incident in September 2010 refers to a ruptured pipeline operated by the Pacific Gas & Electric Company. The rupture created a crater near San Bruno, California, caused an explosion after natural gas was released and ignited, and resulted in fires causing loss to life and property. [Read the full NTSB Accident Report]
  • The Merrimack Valley gas explosion in Massachusetts in September 2018 was the result of excessive pressure build-up in a natural gas pipeline owned by Columbia Gas that led to a series of explosions and fires. [Read the preliminary NTSB Accident Report]
    • NTSB included a reference to the incident in the “Most Wanted List.” The open recommendation asks for a response from the state of Massachusetts to “eliminate the professional engineer licensure exemption for public utility work and require a professional engineer’s seal on public utility engineering drawings.”

NTSB Most Wanted List: Full Episode Transcript

Russel Treat:  Welcome to the Pipeliners Podcast, episode 62, sponsored by EnerSys Corporation, providers of POEMS, the Pipeline Operations Excellent Management System, compliance and operations software for the pipeline control center. Find out more about POEMS at enersyscorp.com.

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Announcer:  The Pipeliners Podcast, where professionals, Bubba geeks, and industry insiders share their knowledge and experience about technology, projects, and pipeline operations. Now your host, Russel Treat.

Russel:  Thanks for listening to the Pipeliners Podcast. We appreciate you taking the time, and to show that appreciation, we’re giving away a customized YETI tumbler to one listener each episode. This week, our winner is Corie Allemand with Siemens. Congratulations, Corie, your YETI is on its way. To learn how you can win this prize pack, stick around to the end of the episode.

This week on the Pipeliners Podcast, I’m going to be doing a bit of soliloquy, meaning it’s just me. It’s been awhile since we did a regulatory update. I recently came across something that’s new to me and I wanted to share with the audience, so let’s get about doing that.

This week, we’re going to be talking about the NTSB’s Most Wanted List. I need to give you a little background. Some of you may know about this. It’s a new discovery for me and I found it fascinating.

The NTSB’s the National Transportation Safety Board. The NTSB is the entity that investigates any type of transportation accident. That includes aircraft, rail car, highway, and others, and of course it includes pipeline.

What they do is they look for what are the root causes of accidents, and then they make recommendations related to safety improvements.

What’s interesting about their recommendations is some of those recommendations are directed to the regulatory authorities, like in the case of pipelines, the Pipeline Hazardous Material Safety Administration, or PHMSA. They also make recommendations that can be addressed to state agencies or operators, even product vendors if that’s appropriate.

I went through and looked at the open recommendations. Open would mean nothing’s been implemented formally in industry yet, typically meaning that this stuff is making its way through the rulemaking process. These NTSB recommendations frequently become rulemakings in the regulatory authorities.

I thought it’d be instructive to review what’s on the list. We’ll link up on the show notes a link to the NTSB’s Most Wanted List. Of course, their Most Wanted List covers all the domains of transportation, but there’s a significant portion of that dedicated to pipeline. Before we dive into the details, let me just give you a couple of things about what the NTSB says about its Most Wanted List.

They use this as an advocacy tool, and it identifies the top safety improvements that the NTSB believes can be made to prevent accidents, minimize injuries, and save lives in the future. It’s also their road map for lessons learned. They talk about the road map from lessons learned to lives saved, meaning we get better with safety and we improve things.

Again, I did a little bit of reviewing. There’s currently 32 — I say currently. I’m looking at a document that the NTSB released December 11th. Of those 32 recommendations, 7 are directives specifically to pipeline operators, 3 are directed to state agencies, 2 are directed to a single vendor, and then the remainder are directed to PHMSA.

I wanted to run through these. I’m not going to talk about those things directed specifically to state agencies or specifically to operators. If you’re interested in that you can certainly go to the show notes page, link through, and look that stuff up. I think what’s more meaningful is those things that are directed to PHMSA in particular.

I reviewed it. Most of it that’s directed to PHMSA, which is about 20 items, are somewhere in the rulemaking cycle. Some of these date back all the way to the San Bruno incident. Some of them are relatively recent.

The first thing that I want to look at, these all have numbers. All of these numbers can be looked up and you can find a whole lot more information about where’s the status of this recommendation in the process.

The first one is P-11-010. It is a recommendation to PHMSA to require operators of natural gas transmission and distribution pipelines to equip their SCADA systems with tools to assist at recognizing and pinpointing the location of leaks, including line breaks, which I would call a rupture.

This is interesting to me because there was recently a white paper that was done — there’s been a number of these papers done — where industry looked at what is the state of the art in leak detection.

One of the conclusions, where leak detection is already a regulatory requirement in liquids, it’s more problematic particularly if you look at CPM or Computational Pipeline Modeling, which is something you would attach to the SCADA system.

It’s more problematic in natural gas because the nature of natural gas and how it moves through a system and how it holds pressure is very different than what you get in a hydrocarbon liquid.

To me, this is an interesting recommendation. It has some pretty significant implications I think for the transmission and distribution operators.

I think that given where technology is and where it’s headed and the rate that it’s advancing that if you’re operating a gas line, I think some time in the next 5 to 10 years, you can reasonably expect that you’re going to have to have some kind of leak detection on that natural gas line. To me, that’s an interesting recommendation. It’s something that’s going to actually help to drive technology to support addressing it.

The next recommendation is P-11-011 and that’s to amend 49 CFR 192.935C. This is the requirement for automatic shut-off and remote control valves in the high-consequence areas, also in Class 3 and Class 4 locations.

This is a big deal for the gas utilities. I think I’ve talked about this in some of the other podcasts. While this on the surface of it is certainly a reasonable requirement, one of the challenges you have is that to execute automatic shut-off or remote control isolation requires you to address the issue of what the system is there to do.

Most gas utilities, most distribution systems were designed and implemented primarily to install deliverability. Deliverability is sometimes different or in conflict with automatic shutdown. If I have a line break in a segment of pipe, and I’ve got a power plant coming off of that segment, I don’t necessarily want to turn the power plant off when I isolate the line break.

That’s just one example. There are many others that causes this while on the surface to be reasonable, in practice and application can be quite challenging. Again, certainly that’s coming down the pike and we’re going to see other response.

The next one’s P-11-014. This is a requirement to delete the grandfathering exemption and now require all gas pipelines, even those constructed before 1970, to be subjected to a hydrostatic pressure test. I think that you’re going to see there’s many other rule-making that’s also related to hydrostatic testing in gas pipelines.

The other recommendation kind of related to this but related to new pipe is that if there’s construction-related defects, you can only consider those defects stable if you perform a post-construction, hydrostatic test and at least 1.25 times the maximum allowable operating pressure. Again, you’re seeing an increasing level of focus on validating and verifying that the pipe will hold the pressure it’s designed to hold.

Several of these recommendations are integrity specific and they relate to analysis of various kinds of defects, such as cracks and dents and etc. This actually gets outside of my particular expertise.

I’m going to try and get one of the guys I know who’s an ILI expert to come on and talk about some of the details around and some of the challenges around implementing these recommendations around various kinds of defects and their interactions. There’s a number of recommendations in that domain.

Also, there’s a recommendation — this is P-12-004 — that requires that in cases where determination about a pipeline threat cannot be obtained within a 180 days following an inspection, written notice is required to PHMSA with an expected date when adequate information will come available. Creating some accountability about acting within a time frame, or if that time frame’s exceeded communicating to the regulatory authority about what’s the plan and when can that be resolved.

There’s also a recommendation, which is P-14-001, that’s expanding the definition of an HCA to include high-traffic roadways. That would be the way I’d define it. They use a little bit different language in the recommendation.

Incorporating highways with high traffic as identified sites that establish a high-consequence area, pretty much anytime you’re crossing an interstate or other main roadway, you’re going to consider that an HCA.

There’s a couple of recommendations here related to the pipeline mapping system, improving accuracy, and including HCA identification in the National Pipeline Mapping System.

From my standpoint, I think that’s a really great initiative. It’s certainly helpful to first responders and others that need to be aware of critical infrastructure that’s in their domain of responsibility.

I don’t have a lot of knowledge about the integrity requirements as I mentioned earlier but there’s quite a few of them. About half of these recommendations are integrity related. These recommendations deal with not just particular types of threats but also threat interactions.

I recently did an episode with PRCI where they were talking about their data repository. There’s a couple of people I’ve been talking to about getting them on to talk about what’s going on with artificial intelligence in the domain of pipeline integrity.

I actually think this is a really fascinating subject. In fact, if any of the listeners know of somebody you think could talk to this, I’d welcome the opportunity to get them on and have them as a guest. I think this is something the industry would be very interested in. [Reach out to Russel Treat on LinkedIn with a recommendation.]

There’s certainly a belief that by using artificial intelligence and by maturing that technology, we should be able to get to a level of zero incidents or zero releases coming out of our inspection programs. Certainly, getting guidance around interactions and risk assessment and consequence of failure calculations and so forth would be helpful.

One of the recommendations, which is P-15-013, directs PHMSA to update guidance for performing calculations related to these kinds of risk assessments. Again, interesting direction and certainly this is an area where technology’s going to add a lot of value to what we’re doing.

In a related way, there’s a recommendation — this is P-15-017 — which is directing PHMSA to create a program to use the data collected in response to some of the other safety recommendations, to evaluate the relationship between incident occurrences and inappropriate elimination of threats, interactive threats, and risk assessment approaches.

Basically, they’re directing the agency to do some research, provide a program such that they can look at what’s being done in the area of risk assessment and evaluation of threats and how that approach is or is not contributing to incidents.

Again, this kind of information in that pipe of information becoming publicly available to not just the operator community but the vendor community — and I should say appropriately available — is going to be very valuable in terms of developing these algorithms and approaches to automate this analysis.

Kind of an aside, I looked at a technology and this has been a long time ago. This was in the early ’90s. I looked at an image analysis technology that was related to chromosome karyotyping. I know it’s a big word.

The interesting thing at that time, this was looking for genetic defects in chromosomes. The way this was done is an especially trained laboratory analyst would look through an electron microscope at blood samples, looking to identify these malformed chromosomes. Pretty painstaking. The accuracy level was in the 65 to 70 percent range.

I was working with a company that was taking image analysis technology that had been developed at NASA to do satellite imagery and was applying it to this application. Over the course of about 10 years, they matured that technology to where they had better than a 99 percent accuracy rate, and they increased their throughput of analysis by something like 20 to 1.

I expect we’re going to see that kind of lift or better in what we’re doing in ILI analysis. It’s basically the same kind of science just applied in a different way. Certainly, these regulatory initiatives can drive that or facilitate it, help move that along.

Another notable couple of recommendations also in the integrity domain are going to now require that all natural gas pipelines be inspectable, either through inline inspection or through some other kind of method where inline inspection cannot happen.

Again, this is in the integrity domain. I can’t really speak to where those stand in the rule-making process. Certainly, if you’re operating a natural gas system, that’s something you ought to be looking at is how we’re going to make sure we have the ability to inspect everything.

Some of the more recent recommendations relate to dents, and in particular dents created by third parties. PHMSA is being directed to work with trade and standard organizations to modify dent acceptance criteria to count for all the factors that could lead to pipe failures caused by dents, and to get that new standard, new criteria out so that it can be incorporated into the operators’ integrity management programs.

There’s also a sister requirement or recommendation if you will that requires operators to either repair all excavated dent defects, or to install local leak detection at each location where a dent is not repaired.

This is interesting because it leads to the question of what is a dent and how is that kind of feature different than other kinds of features. Again, this is going through process. It’s coming at us.

There are several recommendations, one directed at PHMSA and two directed at Honeywell related to the PermaLock mechanical tapping tee assembly and its implementation and use, primarily to make sure that gas distribution operators, the gas utilities are using best practices in their integrity management programs, and they’re using the specified tools and methods to correctly utilize that system. That’s interesting.

There’s a number of recommendations that are related to the recent incident in Massachusetts where there was an overpressure incident. Some of these are related to the process and control procedures as you’re implementing a change or update in a gas distribution utility.

Most notably, they’re calling for the Commonwealth of Massachusetts to eliminate the professional engineer licensure exemption for public utility work and to require a professional engineer seal on any utility drawings.

To me, it’s interesting. I personally got registered as a PE about five, six years after I got out of university. I held my license for a number of years. I eventually let it lapse because I just wasn’t sealing any drawings.

However, the thing you learn about this issue around why would I want to require a professional engineer seal, and how would I know that that professional engineer had the appropriate experience — expertise related to utilities. I think that’s a big question.

One of the things you learn as an engineer is there’s what I learned in school, there’s what I get certified in. Then for many disciplines of engineering, there’s specialized knowledge that really goes well beyond what I would learn in a PE.

Now, of course, if I have a PE and I seal drawings, one of the things you’re painfully aware of is that you have a certain level of fiduciary responsibility and accountability related to executing that seal. I expect that we’re going to see a fairly energetic industry response to this recommendation.

I believe there’s certainly some valid reasons why this recommendation is being made. I think the practical implications of putting it into practice are challenging, I’ll just say it that way.

Anyways, if you want to know more about this NTSB Most Wanted List, download the PDF from the show notes and you can read about them in more detail.

Where these recommendations might impact your operations, I would encourage you to do some additional research, look at the details of the recommendations, where they’re coming from. Take a look at your own organizations and see where you might need to be looking at your internal processes and procedures.

Hopefully, you find this helpful. I certainly did. There was a number of things that are in these recommendations that, frankly, I wasn’t aware of. I tend to follow the stuff on the control room and leak detection side more closely.

This was really a great single place to go and look and see all the things that the NTSB is pushing for. It helps you understand at least at a high level what’s happening in the rule-making process and why those things are coming through the rule-making process.

I found it very instructive for me to take a few minutes and download the document, read through it. Hopefully, you found it helpful as well.

I hope you enjoyed this week’s episode of the Pipeliners Podcast and our conversation about the NTSB’s “Most Wanted” pipeline safety recommendations.

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Russel:  If you have ideas, questions, or topics you’d be interested in, please let me know on the Contact Us page at PipelinersPodcast.com, or reach out directly to me on LinkedIn. Thanks for listening. I’ll talk to you next week.

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Transcription by CastingWords

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