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Safety Recommendation Details

Safety Recommendation P-01-002
Details
Synopsis: About 12:55 a.m. on 7/7/98, a natural gas explosion and fire destroyed a newly constructed residence in the south riding community in Loudoun County, Virginia. A family consisting of a husband and wife and their two children were spending their first night in their new home at the time of the explosion. As a result of the accident, the wife was killed, the husband was seriously injured, and the two children received minor injuries. Five other homes and two vehicles were damaged. The national transportation safety board determined that the probable cause of this accident was the corrosion and subsequent overheating and arcing at a splice in one of the conductors of the triplex electrical service line, which, because of inadequate separation between the electrical conductors and the gas service line, led to the failure of the gas service line and the subsequent uncontrolled release of natural gas that accumulated in the basement and was subsequently ignited. Precipitating the electrical service line failure was damage done to the electrical service line during installation of the gas service line and/or during subsequent excavation of the electrical line.
Recommendation: TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION (ORIGINALLY ISSUED TO RSPA): 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.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Pipeline
Location: Loudoun County, VA, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA98MP003
Accident Reports:
Natural Gas Explosion and Fire
Report #: PAR-01-01
Accident Date: 7/7/1998
Issue Date: 6/22/2001
Date Closed: 12/5/2016
Addressee(s) and Addressee Status: PHMSA (Closed - Acceptable Action)
Keyword(s): Excess Flow Valves

Safety Recommendation History
From: NTSB
To: PHMSA
Date: 12/5/2016
Response: We are pleased to learn that on October 14, 2016, you published the long-awaited final rules at the Federal Register. Because the final rule satisfies the intent of Safety Recommendation P-01-2 (improving natural gas distribution pipeline system safety), it is classified CLOSED—ACCEPTABLE ACTION.

From: NTSB
To: PHMSA
Date: 11/10/2016
Response: We are currently reviewing your August 17, 2016, letter regarding Safety Recommendation P-01-002 and hope to have a response to you soon.

From: PHMSA
To: NTSB
Date: 10/27/2016
Response: -From Marie Therese Dominguez, Administrator: On December 4, 2009, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a final rule titled "Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines" (DIMP), which required operators install excess flow valves (EFV) on service lines serving single-family residences. In November 2011, PHMSA published an advance notice of proposed rulemaking seeking comment on several issues related to the expanded use of EFV s in gas distribution systems, including expanding EFV use beyond single-family residences to cover all new and renewed gas service lines. PHMSA published a corresponding notice of proposed rulemaking in July 2015 seeking further comment on the requirement to install EFV s on all other customer services, regardless of classification. On October 7, 2016, PHMSA published a final rule titled "Pipeline Safety: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single Family Residences." The rule requires operators to install excess flow valves (EFV) on all new or replaced distribution service lines serving branched single-family residences, multifamily residences, and small commercial entities consuming gas volumes not exceeding 1,000 Standard Cubic Feet per Hour (SCFH), and to install curb valves (manual service-line shutoff valves), or EFV s, if supported by sound engineering analysis, on service lines with meter capabilities exceeding 1,000 SCFH. The installation of these valves would include the remaining customer classifications and pipelines not captured in PHMSA's DIMP final rule published on December 4, 2009. Therefore, with the publication of this rule, excess flow valves are required to be installed in all new and renewed gas service lines, which should satisfy NTSB Recommendation P-01-2. As a safety organization, we take our responsibility to address all recommendations seriously and will continue to work aggressively to close all open recommendations. We therefore request your consideration for closing Recommendation P-01-2. PHMSA will continue to work with your office in the future as we continue our efforts to ensure the safe, reliable, and environmentally sound operation of the Nation's pipeline transportation system.

From: PHMSA
To: NTSB
Date: 8/17/2016
Response: -From Marie Therese Dominguez, Administrator: PHMSA ·s Technical Advisory Group met by conference call on December 17, 2015, and voted to approve PHMSA's proposed changes to the pipeline safety regulations regarding excess flow valves published in the July 15, 2015, notice of proposed rulemaking (NPRM) titled " Pipeline Safety: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences." The NPRM proposed installing excess flow valves on all new or replaced distribution service lines serving branched single-family residences, multi-family residences, and small commercial entities consuming gas volumes not exceeding 1.000 Standard Cubic Feet per Hour (SCFH) and to install curb valves (manual service-line shutoff valves) for service lines with meter capabilities exceeding 1,000 SCFH. This would capture the remaining pipelines not covered under PHMSA's "Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines" (DIMP) final rule published on December 4, 2009. PHMSA anticipates publishing its final rule in late winter 2017.

From: NTSB
To: PHMSA
Date: 9/8/2015
Response: CC# 201500683: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) notice of proposed rulemaking (NPRM), Pipeline Safety: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences, published on July 15, 2015. In this notice, PHMSA is proposing to make changes to Title 49 Code of Federal Regulations (CFR) Part 192 to: 1. Expand the requirement to install excess flow valves (EFV) to include new or replaced service lines for single-family residences (SFR) with branched lines; multifamily installations, including duplexes, triplexes, and fourplexes with individual meter sets and known customer loads not exceeding 1,000 standard cubic feet per hour (SCFH); and small commercial customers with known loads not exceeding 1,000 SCFH. 2. Add a requirement for the use of manual service line shut-off valves (e.g., curb valves) for new or replaced service lines with meter capacities exceeding 1,000 SCFH. 3. Require operators to notify customers of their right to request the installation of an EFV on existing service lines within 90 days of first receiving gas at a particular location. 4. Delegate to the operator the question of who bears the cost of installing EFVs to service lines that are not being newly installed or replaced. The NTSB issued the following safety recommendation to PHMSA on June 22, 2001, as a result of an investigation of a natural gas explosion and fire in South Riding, Virginia, on July 7, 1998. 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) In response to the recommendation, on December 4, 2009, PHMSA amended the pipeline safety regulations to require the use of EFVs for new or replaced gas lines servicing SFRs, but did not include the broader coverage contained in the recommendation. The NTSB is pleased that PHMSA is now proposing to expand the requirements for installing EFVs to include service lines to multifamily dwellings and other structures. We understand that the expanded coverage is based on a comprehensive examination of the practical operating limits of EFVs and comments submitted in response to PHMSA’s November 25, 2011, advance notice of proposed rulemaking. To further enhance natural gas distribution safety on service lines having meter capacities above 1,000 SCFH, PHMSA proposes to require operators to install a manual service line shut-off valve (e.g., curb valve) on new or replaced service lines in such a manner that emergency personnel can access the valve. The NTSB is pleased that this proposed addition to the pipeline safety regulations goes beyond the original intent of the recommendation, to further ensure safety. We also are pleased that PHMSA is proposing to require the operator to inform customers of their right to request an EFV be installed on an existing service line. The NTSB supports the measures proposed in the NPRM and believes that they will improve the safety of natural gas distribution pipeline systems and appreciates the opportunity to comment on the notice.

From: NTSB
To: PHMSA
Date: 4/8/2015
Response: We are encouraged that, despite a 14-year delay, you have drafted a notice of proposed rulemaking (NPRM), titled Pipeline Safety: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences, to address the need for excess flow valves on those pipelines not covered by Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines. We note that the Office of Management and Budget is currently reviewing the NPRM, which is scheduled for publication later this year. Pending timely publication of the final rule, Safety Recommendation P-01-2 is classified OPEN—ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 1/22/2015
Response: -From Timothy P. Butters, Acting Administrator: PHMSA has drafted a Notice of Proposed Rulemaking (NPRM) titled "Pipeline Safety: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences." The NPRM proposes to require operators to install excess flow valves on all new or replaced distribution service lines serving branched single-family residences, multi-family residences, and small commercial entities consuming gas volumes not exceeding 1,000 Standard Cubic Feet per Hour (SCFH), and to install curb valves (manual service-line shutoff valves) for service lines with meter capabilities exceeding 1,000 SCFH. This rulemaking would capture the remaining service lines not covered under PHMSA's "Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines" (DIMP) final rule published on December 4, 2009. The NPRM is currently under review with the Office of Management and Budget (OMB), and our anticipated publication date is in 2015.

From: NTSB
To: PHMSA
Date: 1/3/2014
Response: We note that, to address the need for EFVs on those pipelines not covered by the Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines, PHMSA is drafting a notice of proposed rulemaking (NPRM), titled Pipeline Safety: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences, scheduled for publication in December 2013. We also note that the NPRM proposes expansion of Part 192 of the Hazardous Materials Regulations to include new or replaced distribution service lines serving branched single-family residences, multi-family residences, and small commercial entities consuming gas volumes not exceeding 1,000 standard cubic feet per hour (SCFH), and to require the use of curb valves (manual service-line shutoff valves) for those service lines with meter capacities exceeding 1,000 SCFH. Pending timely publication of the final rule, Safety Recommendation P-01-2 remains classified OPEN-ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 8/29/2013
Response: -From Cynthia L. Quarterman, Administrator: On December 4, 2009, PHMSA published its final rule titled “Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines” (DIMP). The DIMP rule addressed a significant portion of new and renewed gas service lines by requiring operators to install excess flow valves (EFV) on all new and replaced residential service lines serving single residences, as required by the PIPES Act of 2006. To capture pipelines not already covered under the DIMP rule, PHMSA drafted a Notice of Proposed Rulemaking (NPRM) titled “Pipeline Safety: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences.” The NPRM is tentatively scheduled for publication in December 2013. It proposes to expand Part 192 of the Hazardous Materials Regulations to include new or replaced distribution service lines serving branched single-family residences, multi-family residences, and small commercial entities consuming gas volumes not exceeding 1,000 Standard Cubic Feet per Hour (SCFH). The NPRM also proposes to require the use of curb valves (manual service-line shutoff valves) for those service lines with meter capacities exceeding 1,000 SCFH.

From: NTSB
To: PHMSA
Date: 2/16/2012
Response: Notation 8381: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) Advance Notice of Proposed Rulemaking (ANPRM) titled "Pipeline Safety: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences" that was published in the Federal Register on November 25, 2011. On June 22, 2001, the NTSB issued a safety recommendation to PHMSA 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. In response to that recommendation, PHMSA is seeking public comment on several issues relating to the expanded use of excess flow valves (EFVs) in gas distribution systems. PHMSA is also seeking comment from gas distribution system operators on their experiences with EFVs, particularly from a cost-benefit perspective. On July 7, 1998, a natural gas explosion occurred at a single-family residence in South Riding, Virginia, killing one person and injuring three others. The NTSB investigated the accident and determined that the cause of the explosion was a service line failure. The NTSB further concluded that an EFV would have stopped the flow of gas in the service limit thus preventing the explosion. Citing that conclusion, on June 22, 200 I, the NTSB made the following safety recommendation to PHMSA: Require that excess flow valves be installed on all new and renewed gas service lines, regardless of a customer's classification, when the operating conditions are compatible with readily available valves. (P-01-02) This safety recommendation is classified, "Open-Acceptable Response." On December 29, 2006, Congress enacted the Pipeline Inspection, Protection, Enforcement, and Safety Act of2006 (PIPES Act). The PIPES Act required PHMSA to mandate the installation of EFVs on single-family homes if (1) the service line was either installed or replaced after June 1, 2008; (2) the service line operated continuously throughout the year at 10 pounds per square inch gauge or more; (3) the service line had no history of contamination; (4) installation was not likely to cause a loss of service; and (5) an EFV meeting certain performance standards was commercially available. On December 4, 2009, PHMSA published in the Federal Register a final rule with minimum standards for gas distribution pipeline integrity management that included the mandatory installation requirement (Title 49 Code of Federal Regulations 192.383) for EFVs on single-family residences. The NTSB supported this action to protect single-family homes but was disappointed that branch service customers, apartment buildings, and commercial customers would not have the added safety and security of an EFV installed on their service lines despite the fact that EFVs designed for many of these applications were commercially available. In 2009, PHMSA issued the report titled Interim Evaluation: NTSB P-OI-02 Excess Flow Valves in Applications Other Than Service Lines Serving One Single-Family Residence. This report was the result of meetings that PHMSA held in June and August 2009 with the National Association of Regulatory Utility Commissioners, the National Association of Pipeline Safety Representatives, the International Association of Fire Chiefs (IAFC), the National Association of State Fire Marshals (NASFM), natural gas distribution operators, trade associations, manufacturers, and the Pipeline Safety Trust. PHMSA reviewed submitted incident reports that were dated March 2004 to December 2009; and PHMSA found that 148 out of914 accidents were located on a service line or meter/regulator set and the gas release was potentially severe enough to trigger an EFV had one been present. As stated in the ANPRM, “Of the 148 incidents deemed to be candidates for prevention by an EFV in the [PHMSA] report, 87 (59%) were serving customers other than single-family residences. Service lines serving other than a single-family residence represent approximately 30% of new and replaced natural gas service lines. Therefore, there is a much greater probability that failure of a service line other than a single-family residence will result in an incident.” Furthermore, these 87 incidents could have been prevented had the NTSB's safety recommendation been fully implemented by PHMSA. The NASFM and the IAFC both agree that the presence of an EFV is a critical factor in suppressing a gas leak at the site of an incident. The ability of the first responders to control the flow of natural gas is limited, and it is dependent on the arrival of gas company personnel if EFVs are not present. It is difficult enough for first responders to have to fight the fires, let alone to have the added burden of fighting an open gas leak.

From: NTSB
To: PHMSA
Date: 10/19/2011
Response: The NTSB is aware of ongoing efforts by PHMSA, industry, and governmental agencies regarding the issue of EFVs, including the publication of a final rule mandating integrity management of gas distribution pipelines and EFVs for single-family residences. We are pleased that, in the fall of 2011, PHMSA expects to publish an Advance Notice of Proposed Rulemaking requesting comment concerning technical feasibility, curb valve installations as EFV alternatives, benefit and cost factors, and whether to establish, enhance, and/or adopt technical standards or guidance for the EFVs, among other issues. We note that PHMSA is also seeking responses from operators regarding their experiences, practices, benefits, and costs related to EFV installation. The NTSB reminds PHMSA, however, that if the final rules are not revised as requested, this recommendation may be reclassified “unacceptable.” Accordingly, we urge PHMSA to amend its regulations to require EFVs on all new and renewed service lines for all gas service customers, regardless of their classification. In the interim, pending further updates from PHMSA, Safety Recommendation P-01-2 remains classified OPEN—ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 8/4/2011
Response: CC# 201100307: - From Cynthia L. Quarterman, Administrator: The safety recommendation P-01-2 recommends 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." PHMSA published a final rule on Gas Distribution Integrity Management Program on December 4, 2009. This rulemaking addresses the congressional mandate in the Pipeline Inspection, Protection, Enforcement and Safety Act of2006 (PIPES Act of2006) on integrity management of gas distribution pipelines and excess flow valve (EFV) requirements for single-family residences. In consideration of future rulemaking on larger application EFV s, PHMSA established a group of stakeholders, including representatives from NTSB, Fire Chiefs' and State Fire Marshals' Associations, to share their understanding, knowledge, experience, and capability with respect to the installation, operation, and maintenance of EFV s in service lines supplying commercial, industrial, and multi-residential natural gas users. Based on information provided by stakeholders, additional research and data evaluation, PHMSA has prepared an Interim Report (available in the EFV docket). This report includes stakeholder perspectives, operators' experience, the current availability of EFV s, technical challenges to design and operation of EFVs on remaining customers' service lines and our proposed next steps. PHMSA has drafted an Advanced Notice of Public Rulemaking (ANPRM) seeking comment on issues such as: technical feasibility, curb valve installations as EFV alternatives; benefit and cost factors; and whether to establish, enhance, and/or adopt technical standards or guidance for the EFVs. In addition, we are also seeking responses from operators to questions regarding their experiences, practices, benefits and costs in regard to excess flow valves. We expect this ANPRM to publish in the fall 2011.

From: NTSB
To: PHMSA
Date: 9/22/2009
Response: In its November 19, 2008, letter regarding the June 25, 2008, NPRM, the NTSB pointed out that 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. The PIPES Act further 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, effective 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, gauge, 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. Safety Recommendation P-01-2 was issued because the NTSB had determined in its investigation of the 1998 South Riding, Virginia, accident that the service line to the home had failed, an uncontrolled release of gas had accumulated in the basement, and the gas had subsequently ignited. 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 NTSB again urges PHMSA to amend its NPRM to require EFVs on all new and renewed service lines for all gas service customers regardless of their classification, as specified in the recommendation, when the operator’s conditions are compatible with readily available valves. If the final rules are not revised as requested, final classification of this recommendation may be unacceptable. Pending a response from PHMSA about this requested change, Safety Recommendation P-01-2 remains classified OPEN -- ACCEPTABLE RESPONSE. Safety Recommendations P-04-1 through -3, stated below, were issued on July 1, 2004, as a result of the NTSB’s investigation of the Enbridge pipeline rupture and crude oil release near Cohasset, Minnesota, on July 4, 2002.

From: PHMSA
To: NTSB
Date: 12/8/2008
Response: Letter Mail Controlled 12/10/2008 3:05:08 PM MC# 2080723: - From Rick Kowalewski, Acting Assistant Administrator and Chief Safety Officer: Safety recommendation P-01-02 asked 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. The PIPES Act requires PHMSA to prescribe minimum distribution integrity management standards by December 3 1, 2007. The Act also includes a requirement for gas distribution operators to install excess flow valves (EFVs) on lines serving single-family residences installed or entirely replaced beginning June 1,2008. This is one of PHMSA’s highest regulatory priorities. PHMSA issued an NPRM “Pipeline Safety: Integrity Management Program for Gas Distribution Pipelines” on June 25,2008. As noted above, we hope to finalize this rule by summer 2009. This notice includes mandatory installation of EFVs on new or replaced service lines on single residences as specified by the PIPES Act and recommended by the NTSB. The PHMSA Administrator requested cooperation from State Commissioners in reminding operators of their responsibilities under the statute to begin installing EFVs on June 1,2008. State pipeline safety agencies, which oversee most distribution operators, have been actively encouraging operators to begin these installations for some time. In addition, PHMSA issued an Advisory Bulletin on June 5,2008, advising operators of the statutory requirement to install EFVs on service lines.

From: NTSB
To: PHMSA
Date: 11/19/2008
Response: 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 pipeline operators have taken action to address problem compression couplings. The Public Utilities Commission of Ohio investigated four accidents from 2000 to 2003 and a number of additional leaks2 because of pullouts and leaks from compression couplings within riser^.^ The Commission is addressing the issue on an operator-by-operator basis and is considering a number of further actions, ranging from increasing the frequency of leak surveys to replacing risers where compression couplings are commonly located. In the 1990s, the Long Island Lighting Company (now KeySpan Energy Delivery) removed about 45,000 compression cou lings because of the increasing rate of leaks. The couplings had been installed in the 1950s. From 2005 to 2007, Washington Gas Company replaced about 175 miles of distribution main pipelines and 25,000 service lines because of increased leakage rates of compression couplings that had been installed between 1958 and 1974. The Minnesota Office of Pipeline Safety investigated a February 19, 2004, explosion and fire in Buffalo, Minnesota,' that caused no injuries or fatalities and a December 28, 2004, explosion that resulted in three deaths and one serious injury in Ramsey, Minnesota. Bot h accidents resulted from pullouts of service lines from compression couplings because of thermal contraction. The couplings, installed in 1967 and 1980, respectively, had insufficient pullout resistance. As a result of these accidents and the resulting analysis, more than 27,000 service lines were replaced because they might have had compression couplings with insufficient pullout resistance. The Kansas Corporation Commission investigated a December 11, 2005, explosion and fire in Shawnee, Kansas, that did not injure anyone but significantly damaged two townhouses.' A 7/8-inch plastic service line had pulled out of a compression coupling installed in 1984. A subsequent investigation revealed that of 11 compression couplings removed from the operator's system, 8 did not pass a tensile pull test. As a result, the Kansas Corporation Commission recommended that the operator remove about 1,000 couplings. The Railroad Commission of Texas investigated an October 16, 2006, explosion and fire in Wylie, Texas, that resulted in two deaths.' A 314-inch plastic service line had pulled out of a compression coupling that had been installed in 1979. The pullout resistance of the coupling had been insufficient. The Railroad Commission of Texas is also investigating a May 29, 2007, explosion and fire in Cleburne, Texas, that resulted in two deaths and injured four others. According to the Railroad Commission, the cause of the accident was a compression coupling that had been installed in 1963; it had leaked natural gas into a sewer. On November 6,2007, the Railroad Commission approved a memorandum requiring each distribution pipeline operator in Texas to replace all compression couplings at service risers if the couplings were not resistant to pullouts. On January 29, 2008, Board investigators expressed their concerns about compression couplings to PHMSA staff during a meeting. PHMSA issued an advisory bulletin on February 28, 2008, telling operators to develop a method of reducing the risk that their compression couplings might fail. (The bulletin was published in the Federal Register on March 4,2008.) The bulletin advises distribution pipeline operators to do the following: review procedures for using pullout-proof compression couplings in accordance with the manufacturer's recommendations, ensure that leak survey procedures are followed and that surveys are properly conducted, review the qualifications for personnel performing leak surveys, improve record-keeping for the detection of trends and problems with existing compression couplings, and consider a full replacement plan. Although the advisory bulletin should help utilities identify possible future problems, the Safety Board is concerned because the bulletin is only advisory; thus operators are not required to implement its suggestions. The Safety Board believes that if the mandated integrity management rules for distribution pipeline systems do not include specific guidance on how to identify and address problem compression couplings, the potential failure risks of such compression couplings will remain unidentified and compression couplings will continue to fail and compromise public safety. Therefore, the Safety Board believes that the integrity management program for a distribution line with compression couplings needs to specifically address the risks posed by the couplings, as addressed in PHMSA's 2008 advisory bulletin. Directional Drilling According to PHMSA, excavation damage is a leading cause of reportable distribution line incidents. On the basis of data from PHMSA's pipeline incident database, the number of reported significant incidents attributed to excavation damage decreased from 80 in 2003 to 60 in 2007. This decrease is likely due in part to the recommended safe practices identified in the Common Ground Alliunce Best Practices Manual and to the focus by government and industry organizations on preventing excavation accidents. Despite these improvements, the Safety Board remains concerned about the unique risks posed by directional drilling. On July 21, 1997, a transmission pipeline ruptured and released natural gas in Indianapolis, ~ndiana.T~h e 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. The Safety Board determined that the probable cause of this accident was the failure of the pipeline operator 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. As a result of its investigation, the Safety Board issued the following safety recommendation to the Research and Special Programs Administration (RSPA) on April 28, 1999: 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. (P-99-1) RSPA responded with an advisory bulletin (ADB-99-04) on August 23, 1999, which cautions operators to review and, if necessary, amend their damage prevention programs to minimize the risks associated with directional drilling. RSPA explained in the bulletin that it had issued the bulletin because directional drilling had caused several pipeline incidents. RSPA recommended full compliance with the one-call notification process and thorough surveys of proposed directional drilling sites to locate potential conflicts. RSPA also recommended that operators get information about conducting directional drilling safely from trade associations and technical publications. Because of the advisory bulletin, the Safety Board classified Safety Recommendation P-99-1 "Closed-Acceptable Action" on October 27, 1999. On Friday May 16, 2008, about 5:35 p.m., an explosion and fire occurred at a residence in McKinney, Texas. Immediately afterward, explosions and fires also occurred at the two houses on either side of the first home. The accident killed one person and injured two others. The Railroad Commission of Texas investigated the accident and found that a contractor of the pipeline owner had hit a distribution pipeline with a directional boring rig.'' This most recent accident again underscores the potential risks of directional drilling. Again, because of the temporary impact of an advisory bulletin, the measures in the bulletin that are meant to mitigate the risks of directional drilling are less likely to be permanently implemented than are specific mandated protocols. The Safety Board notes that the NPRM does not address directional drilling; the Board believes that the NPRM can be strengthened if an operator must include in the integrity management plan specific guidance for minimizing the risk of damage to pipelines from directional drilling. Oversight The Safety Board believes that to ensure effective risk-based integrity management programs are employed throughout the pipeline industry, PHMSA must establish an aggressive oversight program that thoroughly examines each operator's decision-making process for each element of its integrity management program. The Safety Board appreciates the opportunity to comment on this proposed rulemaking. Should you require any additional information or clarification, please contact us. 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 to address problem compression couplings. The Public Utilities Commission of Ohio investigated four accidents from 2000 to 2003 and a number of additional leaks because of pullouts and leaks from compression couplings within risers. The Commission is addressing the issue on an operator-by-operator basis and is considering a number of further actions, ranging from increasing the frequency of leak surveys to replacing risers where compression couplings are commonly located. In the 1990s, the Long Island Lighting Company (now KeySpan Energy Delivery) removed about 45,000 compression couplings because of the increasing rate of leaks. The couplings had been installed in the 1950s. From 2005 to 2007, Washington Gas Company replaced about 175 miles of distribution main pipelines and 25,000 service lines because of increased leakage rates of compression couplings that had been installed between 1958 and 1974. The Minnesota Office of Pipeline Safety investigated a February 19, 2004, explosion and fire in Buffalo, Minnesota, that caused no injuries or fatalities and a December 28, 2004, explosion that resulted in three deaths and one serious injury in Ramsey, Minnesota. Both accidents resulted from pullouts of service lines from compression couplings because of thermal contraction. The couplings, installed in 1967 and 1980, respectively, had insufficient pullout resistance. As a result of these accidents and the resulting analysis, more than 27,000 service lines were replaced because they might have had compression couplings with insufficient pullout resistance. The Kansas Corporation Commission investigated a December 11, 2005, explosion and fire in Shawnee, Kansas, that did not injure anyone but significantly damaged two townhouses. A 7/8-inch plastic service line had pulled out of a compression coupling installed in 1984. A subsequent investigation revealed that of 11 compression couplings removed from the operator’s system, 8 did not pass a tensile pull test. As a result, the Kansas Corporation Commission recommended that the operator remove about 1,000 couplings. The Railroad Commission of Texas investigated an October 16, 2006, explosion and fire in Wylie, Texas, that resulted in two deaths. A 3/4-inch plastic service line had pulled out of a compression coupling that had been installed in 1979. The pullout resistance of the coupling had been insufficient. The Railroad Commission of Texas is also investigating a May 29, 2007, explosion and fire in Cleburne, Texas, that resulted in two deaths and injured four others. According to the Railroad Commission, the cause of the accident was a compression coupling that had been installed in 1963; it had leaked natural gas into a sewer. On November 6, 2007, the Railroad Commission approved a memorandum requiring each distribution pipeline operator in Texas to replace all compression couplings at service risers if the couplings were not resistant to pullouts. On January 29, 2008, Board investigators expressed their concerns about compression couplings to PHMSA staff during a meeting. PHMSA issued an advisory bulletin on February 28, 2008, telling operators to develop a method of reducing the risk that their compression couplings might fail. (The bulletin was published in the Federal Register on March 4, 2008.) The bulletin advises distribution pipeline operators to do the following: review procedures for using pullout-proof compression couplings in accordance with the manufacturer’s recommendations, ensure that leak survey procedures are followed and that surveys are properly conducted, review the qualifications for personnel performing leak surveys, improve record-keeping for the detection of trends and problems with existing compression couplings, and consider a full replacement plan. Although the advisory bulletin should help utilities identify possible future problems, the Safety Board is concerned because the bulletin is only advisory; thus operators are not required to implement its suggestions. The Safety Board believes that if the mandated integrity management rules for distribution pipeline systems do not include specific guidance on how to identify and address problem compression couplings, the potential failure risks of such compression couplings will remain unidentified and compression couplings will continue to fail and compromise public safety. Therefore, the Safety Board believes that the integrity management program for a distribution line with compression couplings needs to specifically address the risks posed by the couplings, as addressed in PHMSA’s 2008 advisory bulletin. Directional Drilling According to PHMSA, excavation damage is a leading cause of reportable distribution line incidents. On the basis of data from PHMSA’s pipeline incident database, the number of reported significant incidents attributed to excavation damage decreased from 80 in 2003 to 60 in 2007. This decrease is likely due in part to the recommended safe practices identified in the Common Ground Alliance Best Practices Manual and to the focus by government and industry organizations on preventing excavation accidents. Despite these improvements, the Safety Board remains concerned about the unique risks posed by directional drilling. On July 21, 1997, a transmission pipeline ruptured and released natural gas in Indianapolis, Indiana. 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. The Safety Board determined that the probable cause of this accident was the failure of the pipeline operator 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. As a result of its investigation, the Safety Board issued the following safety recommendation to the Research and Special Programs Administration (RSPA) on April 28, 1999: 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. (P 99-1) RSPA responded with an advisory bulletin (ADB-99-04) on August 23, 1999, which cautions operators to review and, if necessary, amend their damage prevention programs to minimize the risks associated with directional drilling. RSPA explained in the bulletin that it had issued the bulletin because directional drilling had caused several pipeline incidents. RSPA recommended full compliance with the one-call notification process and thorough surveys of proposed directional drilling sites to locate potential conflicts. RSPA also recommended that operators get information about conducting directional drilling safely from trade associations and technical publications. Because of the advisory bulletin, the Safety Board classified Safety Recommendation P-99-1 “Closed—Acceptable Action” on October 27, 1999. On Friday May 16, 2008, about 5:35 p.m., an explosion and fire occurred at a residence in McKinney, Texas. Immediately afterward, explosions and fires also occurred at the two houses on either side of the first home. The accident killed one person and injured two others. The Railroad Commission of Texas investigated the accident and found that a contractor of the pipeline owner had hit a distribution pipeline with a directional boring rig. This most recent accident again underscores the potential risks of directional drilling. Again, because of the temporary impact of an advisory bulletin, the measures in the bulletin that are meant to mitigate the risks of directional drilling are less likely to be permanently implemented than are specific mandated protocols. The Safety Board notes that the NPRM does not address directional drilling; the Board believes that the NPRM can be strengthened if an operator must include in the integrity management plan specific guidance for minimizing the risk of damage to pipelines from directional drilling. Oversight The Safety Board believes that to ensure effective risk-based integrity management programs are employed throughout the pipeline industry, PHMSA must establish an aggressive oversight program that thoroughly examines each operator’s decision-making process for each element of its integrity management program. The Safety Board appreciates the opportunity to comment on this proposed rulemaking. Should you require any additional information or clarification, please contact us.

From: NTSB
To: PHMSA
Date: 3/18/2008
Response: The Safety Board notes that Section 9 of the Pipeline Inspection, Protection, Enforcement, and Safety Act (the PIPES Act) of 2006 requires PHMSA to prescribe minimum distribution integrity management standards by December 31, 2007. The PIPES Act also includes a requirement for gas distribution operators to install EFVs on lines serving single-family residences that will be installed or entirely replaced beginning June 1, 2008. Implementation of the provisions of the PIPES Act to require installation of EFVs on lines serving only single-family residences will not fully address the recommendation. The Board is aware that PHMSA is working on this issue; we would appreciate receiving an update on the rulemaking effort. The Board urges PHMSA to require EFVs for all new and renewed service lines, regardless of customer classification, when the operating conditions are compatible with readily available valves, as recommended. Safety Recommendation P-01-2 is classified OPEN -- ACCEPTABLE RESPONSE, pending publication of the final rule.

From: PHMSA
To: NTSB
Date: 7/31/2007
Response: Letter Mail Controlled 8/8/2007 2:24:08 PM MC# 2070395: - From Stacey L. Gerard, Assistant Administrator and Chief Safety Officer: The PIPES Act requires PHMSA to prescribe minimum distribution integrity management standards by December 3 1,2007. The Act also includes a requirement for gas distribution operators to install EFVs on lines serving single-family residences installed or entirely replaced beginning June 1,2008. This is another one of PHMSA’s Top 10 regulatory initiatives. PHMSA has developed an NPRM, which we plan to issue this fall. This distribution integrity management NPRM will include mandatory installation of EFV on new or replaced service lines on single residents as specified by the Act and recommended by NTSB.

From: PHMSA
To: NTSB
Date: 4/14/2006
Response: In its 4/14/2006 report to Congress, "National Transportation Safety Board (NTSB) and DOT Office of Inspector General (OIG): PHMSA had been considering requiring excess flow valves (EFVs) and held public meetings in June and September 2005. The National Association of Regalatory Utility Commissioners (NARUC) conducted EFV studies and found that State regulators have serious objections to an across-the-board Federal requirement. PHMSA is considering, as part of the Distribution Integrity Management Program (DIMP), requiring operators to use risk-analysis to determine the need to install these valves and providing as criteria risk factors operators should use to determine if this mitigation measure is needed, on-a case by case basis. This issue will be addressed in the planned DWP rulemaking in 2006.

From: PHMSA
To: NTSB
Date: 2/28/2005
Response: In its 2/28/2005 report to Congress, "Open Statutory Mandates Regarding Pipeline and Hazardous Materials Safety," the DOT wrote: RSPA is considering incorporating requirements for EFVs in upcoming integrrty management rule for gas distribution pipeline. NTSB does not agree with that approach. Regulatory determination will be made by the end of January 2005.

From: NTSB
To: PHMSA
Date: 11/29/2004
Response: The Safety Board notes that RSPA is considering incorporating requirements for EFVs in the upcoming gas distribution pipeline integrity management rule and has discussed this concept with the National Association of Pipeline Safety Representatives and the American Gas Association. The Board does not agree with this approach; the requirement for EFVs should not be linked or contingent on the progress of the gas distribution pipeline integrity management rule. The Board has advocated the installation of these devices for more than two decades, and we have continued to investigate accidents involving both residential and commercial establishments that would have benefited from the protection offered by EFVs. The Board, therefore, urges RSPA to initiate rulemaking requiring EFVs as outlined in the Board's recommendation, without the issue being encumbered with the gas distribution pipeline integrity management rule. Although we do not agree with the approach outlined, because RSPA is actively working on this issue, Safety Recommendation P-01-2 will remain classified OPEN -- ACCEPTABLE RESPONSE. Safety Board staff welcomes the opportunity to participate at the December 13, 2004, meeting at which the cost benefit report conducted by the Volpe Center will be discussed and additional information on the application of EFVs on gas service lines solicited.

From: PHMSA
To: NTSB
Date: 9/3/2004
Response: Letter Mail Controlled 9/10/2004 8:10:58 AM MC# 2040556 - Samuel G. Bonasso, Deputy Administrator: This is the Research and Special Programs Administration's (RSPA) updated response to the National Transportation Safety Board (NTSB) Safety Recommendation P-01-2, which requires that excess flow valves (EFV) be installed in all new and renewed gas service lines. Enclosed is our updated response and a copy of the draft report, "A Benefit/Cost Analysis of the National Transportation Safety Board's Safety Recommendation P-01-2 (September 2003)." RSPA is considering incorporating requirements for excess flow valves in the upcoming gas distribution pipeline integrity management rule. We have discussed this concept with the National Association of Pipeline Safety Representatives (NAPSR) and the American Gas Association (AGA). The benefit/Cost report will be discussed and additional information on the application of EFVs on gas service lines will be solicited at a public meeting scheduled the week of December 13, 2004. We urge NTSB to participate in this public meeting and will continue to keep you informed of our progress. RSPA requests the NTSB continue to classify the recommendation as "OPEN - Acceptable Action" based on the actions we are taking to resolve this recommendation. If we can be of further assistance, please contact me or James Wiggins, Director of Policy and Program Support, at (202) 366-4831.

From: NTSB
To: PHMSA
Date: 6/14/2002
Response: While the Safety Board would be pleased to discuss the results of the study with RSPA, and is always open to consider alternative approaches, we continue to believe that EFV installation should be required in these particular service lines. Accordingly, Safety Recommendation P-01-2 is classified OPEN -- ACCEPTABLE RESPONSE pending the outcome of RSPA's actions and further information from RSPA on this issue.

From: PHMSA
To: NTSB
Date: 4/23/2002
Response: Letter Mail Controlled 05/07/2002 10:27:21 AM MC# 2020456 - From Ellen G. Engleman, Administrator, RSPA: RSPA has enlisted the Volpe National Transportation Systems Center (VNTSC) to provide an analysis of the state of EFV technology, standards, and deployment and to examine current costs and benefits. This report is expected to be completed by summer 2002. Based on this study and after consultation with NTSB, the gas distribution industry, and the public, RSPA will determine if there are circumstances for which it will be beneficial to require mandatory installation of excess flow valves (EFV) on new and renewed gas service lines for residential and commercial customers.