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From:
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NTSB
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To:
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PHMSA
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Date:
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11/19/2008
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Response:
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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.
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