Federal Register / Vol. 89, No. 222 / Monday, November 18, 2024 / Notices 90827 

1See Jeremy Faissat et al., ‘‘Pipeline Hard Spots: 

How Hard is Hard?,’’ Pipeline Technology Conf. 

2021 (Apr. 1, 2021), https://www.pipelineconference.com/abstracts/pipeline-hard-spots-howhard-hard; see also Rosen Group, Presentation, 

‘‘Hard Spot Assessment & Integrity Analyses,’’ slide 

6 (Dec. 13, 2022), https://primismeetings.phmsa.dot.gov/archive/Day_1_AM_1050_

Hard_Spot_Assessment_-_Integrity_Analysis.pdf 

(National Tube pipe). 

2The three hardness units—HRC, HB and HV10— 

can be converted using a standard conversion table. 3API Specification 5L, ‘‘Specification for Line 

Pipe,’’ section 9.10.6, (46th ed., Apr. 2018) 

(incorporated by reference under 49 CFR 192.7 and 

195.3). 4 49 CFR 192.3 defines a ‘‘hard spot’’ as ‘‘an area 

on steel pipe material with a minimum dimension 

greater than two inches (50.8 mm) in any direction 

and hardness greater than or equal to Rockwell 35 

HRC (Brinell 327 HB or Vickers 345 HV10).’’ 

5Zoe H. Shall, Presentation, ‘‘PRCI Efforts on 

Hard Spots: Past, Present, and Future,’’ slide 15 

(Dec. 13, 2022), https://primismeetings.phmsa.dot.gov/archive/Day_1_AM_1020_

PRCI_Efforts_on_Hard_Spots_Dec_2022.pdf. 

6 Gery Bauman & Mary McDaniel, Presentation, 

‘‘Recent Case Study hard Spts and NTSB 

Recommendation P–22–3,’’ slide 20 (Dec. 13, 2022), 

https://primis-meetings.phmsa.dot.gov/archive/ 

MtgHome.mtg@mtg=161.html; see generally, 

PHMSA, ‘‘Class Location Special Permits: FAQs,’’ 

FAQ 34 (June 16, 2010) (providing that hard spots 

are a safety condition that may reduce the 

toughness of pipe body), https://

view.officeapps.live.com/op/ 

view.aspx?src=https%3A%2F%2F

www.phmsa.dot.gov%2Fsites

%2Fphmsa.dot.gov%2Ffiles%2Fdocs%2Ftechnicalresources%2Fpipeline%2Fclass-location-specialpermits%2F64051%2Ffaqsclass-location-specialpermits20180726.docx&wdOrigin=BROWSELINK. 

DEPARTMENT OF TRANSPORTATION 

Pipeline and Hazardous Materials 

Safety Administration 

[Docket No. PHMSA–2024–0176] 

Pipeline Safety: Identification and 

Evaluation of Potential Hard Spots—InLine Inspection Tools and Analysis 

AGENCY: Pipeline and Hazardous 

Materials Safety Administration 

(PHMSA), Department of 

Transportation. 

ACTION: Notice; issuance of advisory 

bulletin. 

SUMMARY: PHMSA is issuing this 

advisory bulletin to notify pipeline 

owners and operators of the importance 

of evaluating their pipeline facilities for 

the existence and potential threat of 

hard spots in the pipe body. That 

susceptibility comes from the plate and 

pipe manufacturing and is broader than 

previously understood; recent data and 

incident investigations indicate that 

hard spots could affect multiple 

pipelines manufactured prior to 1970. 

Hard spots, if not identified and 

mitigated, pose a threat to the integrity 

of the pipeline from interacting threats 

such as coating degradation, soil 

chemistry, and/or increased hydrogen 

exposure, which can result in hydrogeninduced cracking. Pipeline owners and 

operators should consider expanding 

their hard spot threat evaluation to all 

pipe manufactured prior to 1970, 

regardless of manufacturer; collecting 

and analyzing data associated with hard 

spot magnetic flux leakage in-line 

inspection tools; and following industry 

best practices when conducting in-line 

inspection data analysis. 

FOR FURTHER INFORMATION CONTACT: Max 

Kieba, Director, Engineering & Research 

Division, at 202–420–9169 or 

Max.Kieba@dot.gov. 

SUPPLEMENTARY INFORMATION: 

I. Background 

The purpose of this advisory bulletin 

is to notify owners and operators of gas, 

hazardous liquid, and carbon dioxide 

pipelines of the importance of 

evaluating their pipeline facilities for 

the existence and potential threat of 

hard spots in the pipe body. A major 

tenet of PHMSA’s pipeline safety 

oversight program is that pipeline 

operators must know and understand 

their pipeline systems, and use 

appropriate technologies and 

procedures to address risks to prevent 

pipeline failures while considering the 

inherent limitations of such technology. 

PHMSA prescribes factors that must be 

addressed to mitigate risk and conducts 

inspections to ensure adequate 

measures are carried out effectively. 

A hard spot is a defect that is created 

at the time the steel plates are rolled 

during the pipe manufacturing process. 

The creation of hard spots in 

manufacturing is not attached to the inservice product. Even where a pipe may 

have an intended service at the time of 

manufacture, the intended service may 

change after manufacture. A localized 

increase in hardness produced during 

the hot rolling of steel plates as a result 

of localized cooling can form a hard 

spot. Localized hardening may also 

occur through the unintentional 

quenching during the manufacturing 

process or by cold work. Although hard 

spots are more prevalent in plate-formed 

pipe, seamless pipe can also be 

susceptible to hard spots when poor 

controls in the manufacturing process 

result in material property variations, 

including hardness.1

Hardness can be measured in any 

condition, at any time, and is 

determined by measuring the depth of 

an indentation made by a calibrated 

indentation device. There are three 

industry standards that address 

hardness testing: (1) ASTM E92 

Standard Test Methods for Vickers 

Hardness of Metallic Materials; (2) 

ASTM E10–18 Standard Test Methods 

for Brinell Hardness of Metallic 

Materials; and (3) ASTM E18–22 

Standard Test Methods for Rockwell 

Harness of Metallic Materials. Hard 

spots found by in-line inspection (ILI) 

analysis can be verified through the use 

of calibrated devices that press a 

specific tool into the plate’s surface and 

then measure the resulting width or 

depth of the indentation.2 American 

Petroleum Institute (API) Specification 

5L states that ‘‘[a]ny hard spot larger 

than 50 mm (2.0 in) in any direction 

shall be classified as a defect if its 

hardness exceeds 35 HRC, 345 HV10 or 

327 HBW, based upon individual 

indentations.’’ 3 4 However, recent 

improvements in technology have 

revealed incidents on hard spots with 

lower hardness measures. 

Hard spots generally form on the 

surface of pipe and, by themselves, can 

be considered a stable threat. 

Unfortunately, hard spots can become 

unstable when the threat is activated by 

a change in service conditions such as 

coating degradation, effects of soil 

chemistry, and/or influence of the 

cathodic protection hydrogen film. The 

presence of hydrogen can result in 

hydrogen-induced cracking due to 

hydrogen accumulation at inclusions, 

impurities, and lattice structure 

irregularities in the presence of stress on 

the steel (e.g., from operating pressures). 

Typically, coatings insulate hard spots 

from exposure to hydrogen generated by 

the cathodic protection system, but 

coatings can deteriorate over time. 

Recent Pipeline Research Council 

International (PRCI) research indicates 

that the level of cathodic protection may 

also contribute to hydrogen cracking.5

PHMSA has previously discussed, in 

public meetings and workshops, the 

threat evaluations of pipelines 

constructed with pipe manufactured by 

A.O. Smith Corporation (A.O. Smith) 

from 1948 through 1952 due to the 

pipe’s susceptibility to hard spot related 

hydrogen cracking.6 In the past 20 years, 

the following five incidents highlight 

hydrogen-induced cracking of hard 

spots. All but one of the incidents 

occurred on pipe manufactured by A.O. 

Smith. 

• On July 18, 2013, a 30-inch natural 

gas pipeline ruptured in Natchitoches, 

Louisiana. The pipe was manufactured 

in 1952 by A.O. Smith. Evidence 

suggested the failure was caused by 

hydrogen-induced cracking in a hard 

spot that was previously reinforced with 

a Type A sleeve. The leak, in this 

instance, was repaired with a Type B 

sleeve. 

• On January 14, 2015, a 30-inch 

natural gas pipeline ruptured in 


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90828 Federal Register / Vol. 89, No. 222 / Monday, November 18, 2024 / Notices 

7NTSB, Pipeline Investigation Report PIR–22/02, 

‘‘Enbridge Inc. Natural Gas Transission Pipeline 

Rupture and Fire, Danville Kentucky, Aug. 1, 2019’’ 

(Aug. 15, 2022), https://www.ntsb.gov/ 

investigations/AccidentReports/Reports/ 

PIR22002.pdf. 

8 Information and presentations for this December 

2022 public meeting are available at https://primismeetings.phmsa.dot.gov/archive/MtgHome.mtg@

mtg=161.html. 

9Rosen Group, Presentation, ‘‘Hard Spot 

Assessment & Integrity Analyses’’ (Dec. 13, 2022), 

https://primis-meetings.phmsa.dot.gov/archive/ 

Day_1_AM_1050_Hard_Spot_Assessment_-_

Integrity_Analysis.pdf. 10NTSB, PIR–22/02 at 29. 

Brandon, Mississippi. The pipe was 

manufactured in 1952 by A.O. Smith. 

The failure was caused by hydrogeninduced cracking in a hard spot greater 

than two inches in length, previously 

reinforced with a Type A sleeve. 

Hardness testing could not be performed 

with the sleeve in place. 

• On August 1, 2019, a 30-inch 

natural gas pipeline ruptured in 

Danville, Kentucky. The pipe was 

manufactured in 1957 by A.O. Smith. 

The failure was caused by hydrogeninduced cracking in a hard spot. 

Hardness testing by the National 

Transportation Safety Board (NTSB) 

identified the origin hard spot was 5.85 

inches by 3 inches, and had hardness 

values between 362 and 381 Brinell. 

Hardness readings extended through the 

pipe wall. 

• On February 13, 2022, an 18-inch 

natural gas pipeline ruptured in Perry 

County, Mississippi. The pipe was 

manufactured in 1950 by A.O. Smith. 

The failure was caused by hydrogeninduced cracking in a hard spot. 

Metallurgical testing found hardness 

values between 35 to 45 Rockwell, and 

was measured at approximately 0.6-inch 

by 2.5-inch. 

• On March 8, 2023, a 30-inch natural 

gas pipeline ruptured in Fauquier 

County, Virginia. The pipe was 

manufactured in 1957 by Bethlehem 

Steel. The failure was caused by 

hydrogen-induced cracking in a hard 

spot. Post incident ILI identified six 

hard spot features, and hardness values 

were confirmed from four features that 

ranged from 192–208 Brinell, which was 

slightly harder than base hardness 

(approximately 170 to 180 Brinell). In 

this instance, the operator did conduct 

a re-analysis of its data that resulted in 

updated results to identify the presence 

of additional hard spots. 

The NTSB conducted an investigation 

following the August 1, 2019, Danville, 

Kentucky, incident, and made findings 

and recommendations regarding 

identification and evaluation of hard 

spots.7 Specifically, the NTSB issued 

recommendation P–22–003 to PHMSA 

to ‘‘[a]dvise natural gas transmission 

pipeline operators of the possible data 

limitations associated with hard spot 

magnetic flux leakage in-line inspection 

tools and analyses used in hard spot 

management programs and reinforce the 

need to follow industry best practices 

when conducting in-line inspection data 

analysis.’’ 

Following the NTSB investigation 

into the Danville incident, PHMSA 

reviewed accident data and information 

regarding hard spots and the 

appropriate methodologies and 

technologies for detecting hard spots. 

PHMSA met with industry and 

technology companies to gather more 

information regarding hard spot 

management programs; communicate 

the results of the data analysis; and 

discuss appropriate ILI technologies for 

different anomalies, including hard spot 

detection. Additionally, PHMSA hosted 

an informational three-day public 

meeting in December 2022, in Houston, 

Texas, to discuss topics relevant to the 

pipeline industry.8 One topic in 

particular included a discussion of both 

the NTSB’s findings and hard spot 

safety concerns. PHMSA presented an 

overview of the NTSB’s PIR–22/02 

report into the Danville incident. During 

the December 2022 meeting, PHMSA 

invited stakeholders to present 

information related to hard spot 

methodologies/technologies used for 

detecting hard spots and discussed the 

circumstances of this incident. PHMSA 

has continued to meet with technology 

companies to review hard spot studies 

and hard spot management programs. 

As a result of the studies and 

communications, PHMSA has identified 

more pipe manufacturers and pipe 

manufacture vintages that could have 

issues with hard spots. In addition to 

A.O. Smith pipe, Bethlehem Steel 

Corporation, Kaiser Steel Corporation, 

National Tube Supply, Consolidated 

Pipe & Supply, Youngstown Sheet and 

Tube, United States Steel, Claymont 

Steel, and Republic Steel have been 

identified as manufacturers with 

manufacture dates as recent as 1970 

whose pipe may experience hard spots.9

In addition, new technologies and 

advancements in ILI have resulted in 

the ability to learn more using 

previously obtained ILI data. For 

example, in the August 2019 Danville, 

Kentucky, hard spot failure, the NTSB 

investigation determined that the initial 

2011 ILI data analysis had identified 16 

hard spots in the relevant line section 

yet the 2019 re-analysis of the 2011 data 

identified 441. The NTSB attributed this 

discrepancy in identifications to 

significant improvements in computer 

hardware, software, and data analysis.10

PHMSA and researchers have found that 

older data can be re-analyzed, and 

previously unidentified hard spots can 

be identified. It is important when 

analyzing the possibility of hard spots to 

verify the capabilities of the tool and 

verify the data collected. PHMSA 

believes that data verification should 

not be limited in scope and should 

include a thorough review of all 

relevant data. 

PHMSA provides this advisory 

bulletin to help gas, hazardous liquid, 

and carbon dioxide pipeline owners and 

operators and the public understand the 

threat of hard spots and how to better 

comply with the existing requirements 

under federal pipeline safety 

regulations. Guidance and advisory 

bulletins are not substantive rules; are 

not meant to bind the public in any 

way; and do not assign duties, create 

legally enforceable rights, or impose 

new obligations that are not otherwise 

contained in those regulations. 

II. Advisory Bulletin (ADB–2024–01) 

To: Owners and Operators of Gas, 

Hazardous Liquid, and Carbon Dioxide 

Pipeline Systems. 

Subject: Identification and Evaluation 

of Potential Hard Spots—In-line 

Inspection Tools and Analysis. 

Advisory: PHMSA is issuing this 

advisory bulletin to advise gas, 

hazardous liquid, and carbon dioxide 

pipeline owners and operators of new 

information regarding the potential for 

the presence of hard spots in pipelines, 

and their associated safety and 

environmental risks of leaks or ruptures. 

This advisory alerts operators of 

advancements in knowledge of hard 

spot susceptibility, most notably that 

what was once considered to be an issue 

confined to a single manufacturer (A.O. 

Smith) of specific, limited 

manufacturing years, is now understood 

to include potentially other 

manufacturers and manufacturing years. 

Additionally, the presence of hydrogen 

may result in hydrogen-induced 

cracking due to hydrogen accumulation 

at inclusions, impurities, and lattice 

structure irregularities in the presence 

of stress on the steel. For pipelines, the 

stress is typically operational pressure. 

Typically, coatings isolate hard spots 

from exposure to hydrogen generated by 

the cathodic protection system, but 

coatings can and do deteriorate over 

time. Recent PRCI research indicates 

that the level of cathodic protection and 

the chemistry of the surrounding soil 

may contribute to hydrogen cracking. 


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Federal Register / Vol. 89, No. 222 / Monday, November 18, 2024 / Notices 90829 

New technologies and advancements 

in ILI have resulted in the ability to 

better identify features associated with 

hard spots. Additionally, PHMSA and 

researchers have found that significant 

improvements in computer hardware, 

software, and data analysis have 

enabled the use of older data to be reanalyzed, and previously unknown 

features identified. It is important to 

verify the capabilities of the tool and 

verify the data when analyzing for the 

possibility of hard spots. 

For these reasons, pipeline operators 

should consider taking the following 

actions to ensure pipeline safety: 

1. Review all design and construction 

records to ensure they are traceable, 

verifiable, and complete to determine 

whether enough information is available 

to identify the pipe manufacturer, the 

steel plate manufacturer, and the date of 

manufacturing. 

2. Review and determine whether or 

not the types of pipes in the system are 

susceptible to hard spots; 

3. Review and determine if known 

integrity issues have been experienced 

on those pipelines; 

4. Develop and implement an 

enhanced assessment program to 

establish the best approach to material 

hardness anomaly validations; 

5. Re-evaluate existing ILI data to 

support current feature identification; 

and 

6. Continue sharing information used 

to evaluate the identification of hard 

spots and the other factors that may 

contribute to the destabilization of hard 

spots in industry and public pipeline 

technical meetings and conferences. 

Issued in Washington, DC, on November 1, 

2024, under authority delegated in 49 CFR 

1.97. 

Alan K. Mayberry, 

Associate Administrator for Pipeline Safety. 

[FR Doc. 2024–26725 Filed 11–15–24; 8:45 am] 

BILLING CODE 4910–60–P 

DEPARTMENT OF TRANSPORTAION 

Office of the Secretary 

[Docket No. DOT–OST–2024–0003] 

Privacy Act of 1974; System of 

Records 

AGENCY: Office of the Departmental 

Chief Information Officer, Office of the 

Secretary of Transportation (DOT). 

ACTION: Notice of a modified system of 

records. 

SUMMARY: In accordance with the 

Privacy Act of 1974, the Department of 

Transportation (DOT), Office of the 

Secretary (OST), proposes to rename, 

update and reissue an existing system of 

records notice currently titled ‘‘DOT/All 

11, Integrated Personnel and Payroll 

System (IPPS).’’ The name of this 

system of records notice will be changed 

to ‘‘DOT/ALL 11, Consolidated 

Automated System for Time and Labor 

Entry (CASTLE).’’ The modified system 

of records notice (hereafter referred to as 

‘‘Notice’’) uses records in this system for 

fiscal operations related to payroll, 

attendance, leave, insurance, taxes, 

retirement, budget, and cost accounting 

programs. This system is also used to 

control and facilitate payment of 

salaries to DOT employees. 

DATES: Submit comments on or before 

December 18, 2024. The Department 

may publish an amended Systems of 

Records Notice considering any 

comments received. This modified 

system will be effective immediately 

upon publication. The routine uses will 

be effective December 18, 2024. 

ADDRESSES: You may submit comments, 

identified by docket number DOT–OST– 

2024–0003 by one of the following 

methods: 

• Federal e-Rulemaking Portal: 

https://www.regulations.gov. Follow the 

instructions for submitting comments. 

• Mail: Department of Transportation 

Docket Management, Room W12–140, 

1200 New Jersey Ave. SE, Washington, 

DC 20590. 

• Hand Delivery or Courier: West 

Building Ground Floor, Room W12–140, 

1200 New Jersey Ave. SE, between 9 

a.m. and 5 p.m. ET, Monday through 

Friday, except Federal holidays. 

• Instructions: You must include the 

agency name and docket number DOT– 

OST–2024–0003. 

• Instructions: You must include the 

agency name and docket number DOT– 

OST–2024–0003. All comments 

received will be posted without change 

to https://www.regulations.gov, 

including any personal information 

provided. You may review the 

Department of Transportation’s 

complete Privacy Act statement in the 

Federal Register published on April 11, 

2000 (65 FR 19477–78). 

Privacy Act: Anyone is able to search 

the electronic form of all comments 

received in any of our dockets by the 

name of the individual submitting the 

comment (or signing the comment, if 

submitted on behalf of an association, 

business, labor union, etc.). 

Docket: For access to the docket to 

read background documents or 

comments received, go to https://

www.regulations.gov or to the street 

address listed above. Follow the online 

instructions for accessing the docket. 

FOR FURTHER INFORMATION CONTACT: For 

questions, please contact Karyn 

Gorman, Departmental Chief Privacy 

Officer, Privacy Office, Department of 

Transportation, Washington, DC 20590; 

email: privacy@dot.gov; or 202–366– 

3140. 

SUPPLEMENTARY INFORMATION: 

Notice Updates 

This Notice includes both substantive 

changes and non-substantive changes to 

the previously published Notice. The 

substantive changes have been made to 

the system name, system location, 

system manager, authority for 

maintenance of the system, purpose of 

the system, categories of individuals 

covered by the system, categories of 

records in the system, routine uses 

maintained in the system, policies and 

practices for storage of record, policies 

and practices for retrieval, retention and 

disposal of the records in the system, 

and administrative, technical, and 

physical safeguards. Non-substantive 

changes have been made to record 

access procedures and contesting record 

procedures as well as revisions to align 

with the requirements of Office of 

Management and Budget Memoranda 

(OMB) A–108 and to ensure consistency 

with other Notices issued by the 

Department of Transportation. 

Background 

In accordance with the Privacy Act of 

1974, the Department of Transportation 

proposes to modify and re-issue an 

existing system of records titled ‘‘DOT/ 

ALL 11, Integrated Personal and Payroll 

System, (IPPS)’’ and change the name to 

‘‘Consolidated Automated System for 

Time and Labor Entry, (CASTLE).’’ This 

system of records covers records 

collected and maintained for the 

purposes of fiscal operations related to 

payroll, attendance, leave, insurance, 

taxes, retirement, budget, and cost 

accounting programs. This system is 

also used to control and facilitate 

payment of salaries to DOT employees. 

The following substantive changes have 

been made to the Notice: 

1. System Name: This Notice updates 

the system name to ‘‘Consolidated 

Automated System for Time and Labor 

Entry, (CASTLE)’’ from the previous 

system name of ‘‘DOT/ALL 11, 

Integrated Personal and Payroll System, 

(IPPS)’’. The update to the system name 

is to better align with the collection of 

personally identifiable information in 

the system and the purpose of the 

collection. This system is also used to 

facilitate payment of salaries of DOT 

employees. 

2. System Location: This Notice 

updates the system locations to notify 


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