NTSB Safety Recommendation P-05-005

NTSB safety recommendation P-05-005.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Require operators to install computer-based leak detection systems on all lines unless engineering analysis determines that such a system is not necessary.

Priority: CLASS II

Overall Status: Closed - Acceptable Alternate Action

Issued Date: 2005-12-23

Adopted Date: 2005-11-29

Overall Date Closed: 2010-05-06

Synopsis: In the pipeline industry, Supervisory Control and Data Acquisition (SCADA) systems are used to collect data from pipeline sensors in real time and display these data to humans who monitor the data from remote sites and remotely operate pipeline control equipment. This study was designed to examine how pipeline companies use SCADA systems to monitor and record operating data and to evaluate the role of SCADA systems in leak detection. The number of hazardous liquid accidents investigated by the National Transportation Safety Board in which leaks went undetected after indications of a leak on the SCADA interface was the impetus for this study. The Safety Board developed a survey to obtain data about the liquid pipeline industry’s use of SCADA systems with input from industry. In addition to obtaining survey data, the Safety Board visited 12 pipeline companies that had operating SCADA systems. Based on information from previous accidents investigated by the Board, survey results, and site visit results, the Safety Board’s review of SCADA systems in the hazardous liquid pipeline industry uncovered five areas for potential improvement: display graphics, alarm management, controller training, controller fatigue, and leak detection systems.

Ntsbnumber: 80595

Report Number: SS-05-02

Addressee Name: PHMSA

Addressee Status: Closed - Acceptable Alternate Action

Addressee Date Closed: 2010-05-06

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-12-23

Communication Type: NPRM Response

Communication Contents: PHMSA states in the NPRM that it plans to address Safety Recommendation P-05-4 in a separate action. PHMSA published a notice at 73 Federal Register 5 1697 on September 4, 2008, requesting comments on its intention to revise the incident report forms for gas transmission and gathering systems, gas distribution systems, and hazardous liquid pipeline systems. Additionally, in a letter addressed to the Safety Board dated September 17, 2008, regarding Safety Recommendation P-05-5, PHMSA summarized its policies and requirements for leak detection systems. With the letter, PHMSA enclosed a copy of its report to congress3 addressing leak detection systems and the development of more effective technologies. The report, which was mandated under the PIPES Act, was forwarded to Congress on June 23, 2008. The Board will address PHMSA's actions on Safety Recommendations P-05-4 and -5 in separate correspondence and encourages PHMSA to complete action on these recommendations promptly. Notation 8070: The National Transportation Safety Board has reviewed the Pipeline and Hazardous Materials Safety Administration’s (PHMSA’s) notice of proposed rulemaking (NPRM), “Control Room Management/Human Factors,” that was published at 73 Federal Register 53076 on September 12, 2008. PHMSA is proposing to revise the Federal pipeline safety regulations, 49 Code of Federal Regulations (CFR) Parts 192, 193, and 195, to address human factors and other components of control room management. Overview The Safety Board notes that the NPRM would implement new requirements for control room management at 49 CFR Parts 192, 193, and 195 for natural gas pipelines, liquefied natural gas (LNG) facilities, and hazardous liquid pipelines, respectively. Under the proposed requirements, each operator of a natural gas pipeline, LNG facility, or hazardous liquid pipeline with a controller and control room would have to establish and follow written control room management procedures. The procedures also would have to be integrated into the operator’s operations and maintenance manual, qualification program, and emergency plan, all of which are currently required under 49 CFR Parts 192, 193, and 195. The Safety Board further notes that in order to implement the proposed control room management procedures an operator would be required to do the following: define the roles and responsibilities of the controllers; provide controllers with accurate and timely system data; implement methods to prevent controller fatigue; ensure appropriate controller response to alarms and notifications when Supervisory Control and Data Acquisition (SCADA) systems are used; establish thorough and frequent communications among controllers, management, and field personnel when planning and implementing physical changes to pipeline/facility equipment and configuration; review control room procedures following any event that must be reported under existing regulations; establish and implement a training program that includes an annual review to identify potential improvements; have a qualification program for controllers; and conduct an annual validation by a senior executive for the operator verifying that adequate control room management procedures have been implemented and are being followed. The Safety Board supports the overall direction of the NPRM and believes that the NPRM is comprehensive and focuses on the major elements of effective control room management. The Board also commends PHMSA for proposing to apply the standards to both natural gas and hazardous liquid pipelines and LNG facilities. Still, the Board has more detailed comments to provide concerning the specific safety recommendations discussed in the NPRM and the proposed requirements pertaining to mitigation of controller fatigue. Safety Board SCADA Safety Recommendations The Safety Board notes that the NPRM references the five safety recommendations, Safety Recommendations P-05-1 through -5, issued to PHMSA as a result of the Board’s 2005 safety study titled Supervisory Control and Data Acquisition (SCADA) in Liquid Pipelines. The NPRM specifically addresses Safety Recommendations P-05-1, -2, and -3, which, respectively, pertain to the use of graphics for SCADA systems, alarm management, and controller training. The three recommendations also were directly incorporated into the Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006 (PIPES Act). These recommendations are listed below; a discussion of the related provisions in the NPRM follows. Require operators of hazardous liquid pipelines to follow the American Petroleum Institute’s Recommended Practice 1165 [API RP-1165] for the use of graphics on the SCADA screens. (P-05-1) The NPRM states that whenever a SCADA system is used, the operator must implement API RP-1165 in its entirety, unless the operator can adequately demonstrate that a provision of API RP-1165 is not applicable or is impracticable in the SCADA system used. Require pipeline companies to have a policy for the review/audit of alarms. (P-05-2) The NPRM, if implemented, would require that each operator using a SCADA system ensure appropriate controller response to alarms and notifications. Operators would be required to review SCADA operations at least once a week and review SCADA configuration and alarm management operations at least once each calendar year but at intervals not to exceed 15 months. Require controller training to include simulator or non-computerized simulations for controller recognition of abnormal operating conditions, in particular, leak events. (P-05-3) The NPRM proposed training provisions would require that training programs for controllers include the use of a simulator or noncomputerized (tabletop) method to enable controllers to recognize abnormal operating conditions, in particular leak and failure events. The Safety Board notes that under the NPRM, such simulations and tabletop exercises would include representative communications between controllers and individuals that operators expect to be involved during actual events. Further, controllers would also be required to participate in improving and developing tabletop or simulation training scenarios. The Safety Board believes that implementation of these proposed provisions will satisfy Safety Recommendations P-05-1, -2, and -3. Safety Recommendations P-05-4 and -5, the two remaining safety recommendations issued to PHMSA as a result of the SCADA study, are listed below. Change the liquid accident reporting form (PHMSA F 7000-1) and require operators to provide data related to controller fatigue. (P-05-4) Require operators to install computer-based leak detection systems on all lines unless engineering analysis determines that such a system is not necessary. (P-05-5) PHMSA states in the NPRM that it plans to address Safety Recommendation P-05-4 in a separate action. PHMSA published a notice at 73 Federal Register 51697 on September 4, 2008, requesting comments on its intention to revise the incident report forms for gas transmission and gathering systems, gas distribution systems, and hazardous liquid pipeline systems. Additionally, in a letter addressed to the Safety Board dated September 17, 2008, regarding Safety Recommendation P-05-5, PHMSA summarized its policies and requirements for leak detection systems. With the letter, PHMSA enclosed a copy of its report to Congress addressing leak detection systems and the development of more effective technologies. The report, which was mandated under the PIPES Act, was forwarded to Congress on June 23, 2008. The Board will address PHMSA’s actions on Safety Recommendations P-05-4 and -5 in separate correspondence and encourages PHMSA to complete action on these recommendations promptly. Controller Fatigue Mitigation Despite the many positive provisions included in the NPRM, the Safety Board does not believe the NPRM satisfactorily addresses mi

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-04-02

Communication Type: Official Correspondence

Communication Contents: The NTSB is currently reviewing the action taken by PHMSA on the above recommendations, identified in your letter, and expects to have a more substantive response back to you shortly. We apologize for the delay in responding regarding some of the recommendations; however, additional documentation was needed for these before their evaluation for closure could be completed. Action on Safety Recommendation R-89-53 (see enclosure) was completed on March 19, 2010.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-01-12

Communication Type: Official Correspondence

Communication Contents: On May 1, 2009, responding to PHMSA’s September 17, 2008, letter, the NTSB wrote the following: While PHMSA has expended some effort to address the requirements of Section 21 of the PIPES Act (Pipeline Inspection, Protection, Enforcement, and Safety), it has not identified any specific initiative to require operators to install computer-based leak detection systems as requested. Accordingly, pending implementation of the recommendation, Safety Recommendation P-05-5 is classified Open Unacceptable Response. The NTSB has reviewed your August 7, 2009, update and clarification and is encouraged by PHMSA’s plans for addressing this issue. The NTSB notes that PHMSA requires operators to (1) deploy an interconnected set of required layers of protection to detect and repair hazardous liquid pipeline leaks at the soonest possible time to mitigate any damages appropriately and (2) continuously improve the cumulative performance of these interlinked protections in leak detection. These protections include, but are not limited to, customized leak detection technology deployment, periodic risk-based assessment, and defect repair prioritized by environmental consequence, corrosion management, pipeline rights-of-way surveillance, public awareness leading to citizen identifications of leaks, emergency preparedness and response (including ongoing liaison with emergency responders), and lessons learned and applied from accident analyses and investigations. The NTSB understands that from 1997 to 2007, when PHMSA implemented its integrity management (IM) program, the median volume lost from hazardous liquid pipeline accidents dropped by more than half, from 200 to less than 100 barrels, and the number of pipeline accidents declined by over a third. PHMSA’s regulations require the prompt and remote detection of leaks through monitoring operational parameters and engineered leak detection systems for areas identified as having the greatest consequence in the event of a pipeline failure. Further, under the IM program, PHMSA is addressing existing leak detection system inadequacies with each operator by analyzing and evaluating each operator’s leak detection capabilities for individual pipeline systems. The NTSB notes that PHMSA conducted an analysis to determine the number of operators that operate less than 50 miles of pipeline, those that operate 50 to 250 miles of pipeline, and those that operate greater than 250 miles of pipeline. Currently, there are 421 hazardous liquid pipeline operators; 220 operate less than 50 miles of pipeline, 96 operate 50 to 250 miles of pipeline, and 105 operate more than 250 miles of pipeline. PHMSA reports that many of the operators in the higher mileage categories have configured their pipelines into networks, sometimes collecting material from multiple sources and delivering material to multiple destinations. Further, the engineering analysis that PHMSA has performed on many of the point-to-point pipeline systems has determined that a computer-based leak detection system is not necessary for these pipeline systems. PHMSA reports that it will expect operators to do the following: Use traditional line balancing processes, performed routinely at 1-hour intervals any time that material is flowing. Ensure open and regular communication between all active source and delivery points along the pipeline, either through verbal communication or through the use of SCADA technology. Perform the basic process of monitoring flow and pressure to detect large pipeline breaks for pipelines equipped with SCADA technology. Gear line balance processes involving the use of SCADA technology to find less obvious failures such as partial line breaks and smaller leaks not apparent in flow and pressure monitoring. Include communication and monitoring plans that apply to the entire pipeline system, not only to sections of the pipeline located inside a high consequence area, in operating and maintenance manuals. The NTSB understands that PHMSA intends to publish an advisory bulletin (AB) to inform operators of PHMSA’s expectations regarding pipeline leak detection systems on both network and less complex point-to-point pipeline systems. Operators with point-to-point pipeline systems will be required to perform an engineering analysis to determine whether a computerized leak detection system is necessary, and if a system is determined to be unnecessary, the operator will be required to perform a line balance at no greater than 1-hour intervals whenever material is flowing through the line. The NTSB would also like to know how PHMSA will define when a computerized leak detection system is determined to be unnecessary. Because PHMSA has identified an acceptable alternate process to meet the intent of the recommendation, Safety Recommendation P-05-5 is classified OPEN -- ACCEPTABLE ALTERNATE RESPONSE pending completion of the actions described above. The NTSB would appreciate receiving a copy of the AB when it has been published and information regarding the success of this alternative solution.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-05-06

Communication Type: Official Correspondence

Communication Contents: The NTSB notes that PHMSA addressed this issue by requiring operators, under its Integrity Management regulations, to deploy an interconnected set of required layers of protection to detect and repair hazardous liquid pipeline leaks at the soonest possible time, to mitigate any damages appropriately, and to continuously improve the cumulative performance of these interlinked protections in leak detection. These protections include, but are not limited to, customized leak detection technology deployment; periodic risk-based assessment; and defect repair prioritized by environmental consequence, corrosion management, pipeline rights-of-way surveillance, public awareness leading to citizen identifications of leaks, emergency preparedness and response (including ongoing liaison with emergency responders), and lessons learned and applied from accident analyses and investigations. The NTSB also notes that, on January 26, 2010, PHMSA published an advisory bulletin (ADB-10-01) informing operators of PHMSA’s expectations regarding pipeline leak detection systems on both network and less complex point-to-point pipeline systems. Any operator that has a point-to-point pipeline system is required to perform an engineering analysis to determine whether a computerized leak detection system is necessary, and, if a system is determined to be unnecessary, the operator is required to perform a line balance at no greater than 1-hour intervals whenever material is flowing through the line. The NTSB believes that ADB-10-01 will reinforce the integrity management requirements for hazardous liquid pipeline operators. Because PHMSA has implemented an acceptable alternate process that meets the intent of the recommendation, Safety Recommendation P 05 5 is classified CLOSED -- ACCEPTABLE ALTERNATE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2009-05-01

Communication Type: Official Correspondence

Communication Contents: The Safety Board has reviewed Mr. Kowalewski’s letter as well as the PHMSA report on leak detection systems, which was required by Section 21 of the Pipeline Inspection, Protection, Enforcement, and Safety (PIPES) Act. The letter provides a comprehensive overview of action completed as required by the Act and includes a discussion about what can be done to foster the development of more effective technologies. However, while many of the actions outlined in the letter will enhance leak detection and management, the Safety Board is disappointed that PHMSA has not identified any specific initiative to require operators to install computer-based leak detection systems. On August 8, 2006, the Safety Board classified Safety Recommendation P-05-5 Open Acceptable Response pending the results of the discussion of computer-based systems at a June 27, 2006, public meeting. On March 18, 2008, in response to PHMSA’s July 31, 2007, update to Safety Recommendations P-05-1 through -5, the Board advised that compliance with the PIPES Act would satisfy P-05-1 through -4 but that, to satisfy P-05-5, PHMSA needed to require operators to install computer-based leak detection systems; consequently, pending further action from PHMSA, Safety Recommendations P-05-1 through -5 were classified Open Acceptable Response. While PHMSA has expended some effort to address the requirements of Section 21 of the PIPES Act, it has not identified any specific initiative to require operators to install computer-based leak detection systems as requested. Accordingly, pending implementation of the recommendation, Safety Recommendation P-05-5 is classified OPEN -- UNACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-03-18

Communication Type: Official Correspondence

Communication Contents: The Safety Board appreciates PHMSA’s comprehensive overview of action either underway or planned for implementation of these recommendations. The Board has reviewed the requirements of the PIPES Act, which, when implemented, will satisfy Safety Recommendations P-05-1 through -4. Section 19 of the PIPES Act requires implementation of Safety Recommendations P-05-1 through -3 by June 1, 2008, and implementation of Section 20 of the Act will satisfy Safety Recommendation P-05-4, as it requires PHMSA to amend the accident report form by December 31, 2007. Section 21 of the PIPES Act, as stated below, requires PHMSA to submit a report on leak detection systems with discussion about what can be done to foster development of more effective technologies. The Safety Board reminds PHMSA that to satisfy Safety Recommendation P-05-5, it needs to require operators to install computer-based leak detection systems. Not later than December 31, 2007, the Secretary of Transportation shall submit to Congress a report on leak detection systems utilized by operators of hazardous liquid pipelines. The report shall include a discussion of the inadequacies of current leak detection systems, including their ability to detect ruptures and small leaks that are ongoing or intermittent, and what can be done to foster development of better technologies as well as address existing technology inadequacies. The Safety Board is aware that the public comment period for PHMSA’s report was extended through January 18, 2008, and that PHMSA is currently compiling these comments before submitting the report to Congress. Because PHMSA is working to address the recommendations, Safety Recommendations P-05-1 through -5 are classified OPEN -- ACCEPTABLE RESPONSE, pending the completion of these efforts.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2006-08-08

Communication Type: Official Correspondence

Communication Contents: The Safety Board notes that PHMSA's pipeline integrity regulations require operators to have a means of detecting leaks to protect high consequence areas. However, the regulations stop short of mandating computer-based leak detection systems, even to protect high consequence areas. PHMSA's first round of inspections of integrity management programs revealed that 46 percent of operators did not properly or adequately use prevention and mitigation measures, including leak detection. PHMSA plans more inspections that will include more detailed examinations of leak detection. In addition, PHMSA works include discussion of mandated, computer-based leak detection at its June 27, 2006, public meeting. Pending further response from PHMSA, Safety Recommendation P-05-5 is classified OPEN -- ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2007-07-31

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 8/8/2007 2:24:08 PM MC# 2070395 - From Stacey L. Gerard, Assistant Administrator/ Chief Safety Officer: PHMSA has completed our CCERT project, discussed above in response to P-99-12, which covered various human factor control room issues. In January 2007, PHMSA submitted a report to Congress on the project that identified several areas for enhancing safety including improved graphics on SCADA screens, alarms, and training. The Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006 (Act) requires PHMSA to issue regulations by June 1, 2008 that require operators to use the American Petroleum Institute’s Recommended Practice 1165, to review and audit alarm systems, and to develop training standards that include the recognition of abnormal operating conditions. The Act also requires PHMSA to submit a report to Congress on leak detection systems used by operators of hazardous liquid pipelines by December 3 1,2007. We are actively working on this report and intend to meet this deadline. PHMSA plans to include control room issues in a "Prevention Through People" regulatory effort that will incorporate the concepts of integrity management programs into risk-based regulations addressing human factors. PHMSA has begun work on this regulatory effort and expects to complete it this year. It will address both the Congressional direction and NTSB recommendations on use of graphics, review of alarms, controlling training, and fatigue. On May 23,2007 PHMSA held a public workshop that addressed best practices in addressing fatigue, man-machine interface, and qualifications and training and we are currently reviewing the workshop data. PHMSA has also begun work on a project to add data elements to accident reporting forms to capture information regarding the impact of fatigue on safety. PHMSA has ccnsistent!y pushed the hazardous liquid operators through integrity management to shore up the adequacy of their leak detection capabilities.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-03-12

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 3/16/2010 3:16:24 PM MC# 2100099 - From Cynthia L. Quarterman, Administrator: I am sending you this letter in response to the National Transportation Safety Board’s (NTSB) safety recommendation P-05-5 issued to the Pipeline and Hazardous Materials Safety Administration (PHMSA) on December 23, 2005. The NTSB issued this recommendation as a result of the study entitled Supervisory Control and Data Acquisition Systems (SCADA) in Liquid Pipelines, Report No. SS - 05/02, recommending PHMSA require operators to install computer-based leak detection systems on all lines unless engineering analysis determines that such a system is not necessary. Pipeline leak detection is one of the many layers of protection in PHMSA’s holistic approach to protecting people and the environment. Operators are required to deploy an interconnected set of required layers of protection to detect and repair hazardous liquid pipeline leaks at the soonest possible time to mitigate any damages appropriately. Pipeline operators are continuously improving the cumulative performance of these interlinked protections in leak detection. These protections include but are not limited to: customized leak detection technology deployment, periodic risk-based assessment and defect repair prioritized by environmental consequence, corrosion management, pipeline rights-of-way surveillance, public awareness leading to citizen identifications of leaks, emergency preparedness and response - including ongoing liaison with emergency responders, and lessons learned and applied from accident analyses and investigations. Over a 10-year period (1997-2007), during which PHMSA implemented the integrity management (IM) program, the median volume lost from hazardous liquid pipeline accidents dropped by more than half, from 200 to less than 100 barrels. At the same time, the number of pipeline accidents declined by over a third. Requirements in our regulations emphasize prompt and remote detection of leaks through monitoring operational parameters and engineered leak detection systems for areas identified as having the greatest consequence in the event of a pipeline failure. Under the IM rule, PHMSA addresses existing leak detection system inadequacies with each operator by analyzing and evaluating each operator's leak detection capabilities for individual pipeline systems. PHMSA conducted an analysis to determine the number of operators that operate less than 50 miles of pipeline, 50 to 250 miles of pipeline, and greater than 250 miles of pipeline. Currently, there are a total of 421 hazardous liquid pipeline operators and 220 operate less than 50 miles of pipeline, 96 operate 50 to 250 miles of pipeline, and 105 operate more than 250 miles of pipeline. Many of the operators fitting the higher mileage categories have configured their pipelines into networks, sometimes collecting material from multiple sources and delivering material to multiple destinations. Conversely, the engineering analysis performed on many of the point-to-point pipeline systems has determined that installing a computer-based leak detection system is not necessary. However, PHMSA expects these operators to use traditional line balancing processes, performed routinely at one hour intervals any time that material is flowing. In addition, operators must ensure open and regular communication between all active source and delivery points along the pipeline, either through verbal communication or through the use of SCADA technology. Pipelines equipped with SCADA technology still need to perform the basic process of monitoring flow and pressure to detect large pipeline breaks. The line balance processes involving the use of SCADA technology are geared to find less obvious failures such as partial line breaks and smaller leaks not apparent in flow and pressure monitoring. Pipeline operators are required to have these communication and monitoring plans in their operating and maintenance manuals. These manuals apply to the entire pipeline system, not just sections of the pipeline located inside a high consequence area. To address this safety recommendation PHMSA published an advisory bulletin to inform operators of PHMSA’s expectations regarding pipeline leak detection systems, on both network and less complex point-to-point pipeline systems. An operator with point-to-point pipeline systems must perform an engineering analysis to determine if a computerized leak detection system is necessary. If the analysis determines that a computerized leak detection system is unnecessary, the operator will be required to perform a line balance at no greater than one hour intervals whenever material is flowing through the line.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2006-04-26

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 4/27/2006 9:59:08 AM MC# 2060218 4-26-06: - From Stacey L. Gerard, Assistant Administrator/ Chief Safety Officer: The integrity management rule for hazardous liquid pipelines requires operators to have a means to detect leaks on its pipeline system. To the extent an operator uses a computer-based leak detection system, the operator's system must comply with API Recommended Practice 1130. Forty-six percent of PHMSA's first round of inspections of integrity management programs revealed inadequate use of prevention and mitigation measures, including leak detection, in the program elements. As a result, our second round of inspections will include a more detailed examination of leak detection than the first round. In addition, we will include discussion of mandated use of computer-based leak detection at the public meeting on the CCERT Project this coming summer. This discussion will enable us to provide a more informed response to this recommendation at a later date. We request the classification of this response to recommendation P-05-5 as "Open-Acceptable Action." -Stacey L. Gerard, (202) 366-4433

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2008-09-17

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 10/31/2008 12:28:18 PM MC# 2080656 - From Rick Kowalewski, Acting Assistant Administrator/ Chief Safety Officer: This letter provides an updated response and requests the National Transportation Safety Board (NTSB) close Safety Recommendation P-05-5. Safety Recommendation P-05-5 recommends Pipeline and Hazardous Materials Safety Administration (PHh4SA) require operators to install computer-based leak detection systems on all lines unless engineering analysis determines that such a system is not necessary. Section 21 of the Pipeline Inspection, Protection, Enforcement, and Safety Act required PHMSA to submit a report on leak detection systems with discussion about what can be done to foster development of more effective technologies. A draft version of this report was posted for public comment in January 2008 before the final report was sent to the Congress on June 23,2008. A copy of this report is enclosed for your records. PHMSA requires operators to deploy an interconnected set of required layers of protection to detect and repair hazardous liquid pipeline leaks at the soonest possible time to mitigate any damages appropriately. Pipeline operators are continuously improving the cumulative performance of these interlinked protections in leak detection. These protections include but are not limited to: customized leak detection technology deployment, periodic risk-based assessment and defect repair prioritized by environmental consequence, corrosion management, pipeline rights-of-way surveillance, public awareness leading to citizen identifications of leaks, emergency preparedness and response - including ongoing liaison with emergency responders, and lessons learned and applied from accident analyses and investigations. Requirements in our regulations emphasize prompt and remote detection of leaks through monitoring operational parameters and engineered leak detection systems for areas identified as having the greatest consequence in the event of a pipeline failure. Under the Integrity Management (IM) rule, PHMSA addresses existing leak detection system inadequacies with each operator by analyzing and evaluating each operator's leak detection capabilities for individual pipeline systems. PHMSA encourages, and in some cases requires, more timely and comprehensive adoption and application of currently available technology commensurate with the system-specific needs of each operator. PHMSA has also funded Research and Development projects designed to improve leak detection effectiveness and efficiency through development of new technology, new national consensus leak detection standards, and operational best practices. Over the past few years, PHMSA and the industry have invested over $5 million in research and development for six leak detection technology projects. These projects focused on providing cost effective means of external leak detection using land-based systems, airborne technology and underwater technology. We have continued to work with our stakeholders on improving sensitivity of technologies to detect small pipeline leaks. We are developing and refining technology currently proven by other industries in order to apply it to leak detection for hazardous liquid, gas transmission and distribution pipelines. The Airborne Light Detection and Ranging (LIDAR) Pipeline Inspection System (ALPIS) is an example of collaborative technology development PHMSA is conducting to improve the industry’s capability to detect leaks. The ALPIS is an airborne remote sensing system for detecting natural gas and hazardous liquid pipeline leaks. It will be capable of working with helicopters, fixed wing aircraft, or unmanned aircraft. The system uses differential LIDAR to detect the presence of hydrocarbons in the atmosphere. The data collected with ALPIS can be incorporated into Geographic Information Systems to map leak detection information. PHMSA is collaborating with other Federal agencies and stakeholders on the Sensor Enabled Nextgen Technology to develop an enhance surveillance system to detect leaks and prevent infrastructure damage in an aerial surveillance environment. This initiative will apply technology developed for space exploration and military defense to further enhance the safety of the general public and our pipeline infrastructure. The objective is to utilize advance sensor technology on manned aircraft with a view towards use of an Unmanned Aerial Vehicle or satellite to survey pipeline rights-of-way once that technology becomes cost-effective. As stated in the enclosed report, our analyses indicate that hazardous liquid pipeline spills are trending downward. We believe this is due in part to the number of pipeline repairs performed on anomalies prior to failure that are discovered as a result of the internal inspections required by our IM rule, the many layers of protection described in this report as well as the many efforts of our stakeholders. PHMSA has provided strong leadership for this effort through our IM regulatory program and research to assure the safety and reliability of the Nation’s pipeline system. PHMSA requests the NTSB classify Safety Recommendation P-05-5 as Closed-Acceptable Action.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2009-08-07

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 8/13/2009 11:44:38 AM MC# 2090516 - From Cynthia Douglass, Acting Deputy Administrator: This letter provides an updated response and requests the National Transportation Safety Board (NfTSB) change the status of Safety Recommendation P-05-5 to Open-Acceptable Response. Safety Recommendation P-05-5 recommends the Pipeline and Hazardous Materials Safety Administration (PHMSA) require operators to install computer-based leak detection systems on all lines unless engineering analysis determines that such a system is not necessary. Pipeline leak detection is one of the many layers of protection in PHMSA's holistic approach to protecting people and the environment. Operators are required to deploy an interconnected set of required iayers of protection to detectS&d repair hhzardousliqu.idpipelini: leak's'at the soonest possible time to mitigate any damages 'appropr?ately: Pipeline operators are continuously improving the cumulative performance'of these interliiiked protections in leak detection. These protections include but are not limited to: customized leak detection technology deployment, periodic risk-based assessment and defect re-p air prioritized by environmental conseauence. A corrosion management, pipeline rights-of-way surveillance, public awareness leading to citizen identifications of leaks, emergency preparedness and response - including ongoing liaison with emergency responders, and lessonsle&ed and applied from accident analyses and investigations. Over a 10-year period 1997-2007, during which PHMSA implemented the integrity management (IM) program, the median volume lost from hazardous liquid pipiiine accidents dropped by more than half, from 200 to less than 100 barrels. At the same time, the number of pipeline accidents declined by over a third. Requirements in our regulations emphasize prompt and remote detection of leaks through monitoring operational parameters and engineered leak detection systems for areas identified as having'the greatest &sequence in the event of a pipeline failure. Under the IM rule, PHMSA addresses existing leak detection system inadequacies with each operator by analyzing and evaluating each operator's leak detection caiabilities'for individual pipeline systems. PHMSA,conducted axi an'alysis to determineithe number of opekators that operate less than 50 miles of pipeline, 50 to 2 ater than 250 miles of pipeline. Cuirently, operators and 220 operate less than 50 miles of pipeline, 96 operate 50 to 250 miles of pipeline, and 105 operate more than 250 miles of pipeline. Many of the operators fitting the higher mileage categories have configured their pipelines into networks, sometimes collecting material from multiple sources and delivering material to multiple destinations. Conversely, the engineering analysis performed on many of the point-to-point pipeline systems has determined that installing a computer-based leak detection system is not necessary. However, PHMSA expects these operators to use traditional line balancing processes, performed routinely at one hour intervals any time that material is flowing. In addition, operators must ensure open and regular communication between all active source and delivery points along the pipeline, either through verbal communication or through the use of Supervisory Control and Data Acquisition (SCADA) technology. Pipelines equipped with SCADA technology still need to perform the basic process of monitoring flow and pressure to detect large pipeline breaks. The line balance processes involving the use of SCADA technology are geared to find less obvious failures such as partial line breaks and smaller leaks not apparent in flow and pressure monitoring. Pipeline operators are required to have these communication and monitoring plans in their operating and maintenance manuals. These manuals apply to the entire pipeline system, not just sections of the pipeline located inside a high consequence area. PHMSA will publish an advisory bulletin to inform operators of PHMSA's expectations regarding pipeline leak detection systems, on both network and less complex point-to-point pipeline systems. An operator with point-to-point pipeline systems must perform an engineering analysis to determine if a computerized leak detection system is necessary. If the analysis determines that a computerized leak detection system is unnecessary, the operator will be required to perform a line balance at no greater than one hour intervals whenever material is flowing through the line. PHMSA requests the NTSB classify Safety Recommendation P-05-5 as "Open-Acceptable Response." If you have questions, please feel free to contact me at 202-366-4433.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2010-03-15

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 3/16/2010 1:16:29 PM MC# 2100096 - From Cynthia L. Quarterman, Administrator: I greatly appreciated meeting with you last month concerning the National Transportation Safety Board's (NTSB) recommendations to the Pipeline and Hazardous Materials Safety Administration (PHMSA). I look forward to meeting with you again, along with staff, on Tuesday, March 16th. Your recommendations, based on lessons learned from accident investigations, provide valuable safety information to our programs. We are committed toconsidering each of the recommendations and implementing those that are positive improvements in safety. I have been meeting with PHMSA's hazmat and pipeline safety programs to assess our actions on the NTSB recommendations. We are addressing these safety issues by taking actions to assure that the "unacceptable actions" are moved into the "open-acceptable" category and to achieve a "closed-acceptable" in a timely manner on as many recommendations as possible. I recognize that a number of "open-acceptable" recommendations are works in progress and maytake a year or more to complete. You indicated your interest in getting these issues resolved as well. As you requested, I asked our pipeline and hazmat staff to compile a copy of outstanding letters to the NTSB that request a change in the classification of a recommendation. I have attached a copy of those letters and am hopeful you and I can successfully resolve a number of these issues. In addition, I have askedour Chief Safety Officer, Cindy Douglass, and our Associate Administrators, Jeff Wiese for Pipeline Safety and Magdy El-Sibaie for Hazardous Materials Safety, to meet with your staff to help us better understand each recommendation and to clarify the actions the NTSB considers necessary for closure. Again, I look forward to meeting with you on these safety concerns and believe that, together, we will make a positive difference in the safe transportation of hazardous materials, including those transported by pipelines.