NTSB Safety Recommendation P-11-008

NTSB safety recommendation P-11-008.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Require operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to provide system-specific information about their pipeline systems to the emergency response agencies of the communities and jurisdictions in which those pipelines are located. This information should include pipe diameter, operating pressure, product transported, and potential impact radius. (Supersedes Safety Recommendation P-11-001)

Priority: CLASS II

Overall Status: Closed - Acceptable Alternate Action

Issued Date: 2011-09-26

Adopted Date: 2011-09-12

Overall Date Closed: 2018-02-21

Synopsis: On September 9, 2010, about 6:11 p.m. Pacific daylight time,1 a 30-inch-diameter underground natural gas transmission pipeline (which is identified by the company as Line 132), owned and operated by Pacific Gas and Electric Company (PG&E), ruptured in a residential area in San Bruno, California. The accident killed eight people, injured many more, and caused substantial property damage. The rupture on Line 132 occurred near mile point 39.28, at the intersection of Earl Avenue and Glenview Drive in San Bruno. About 47.6 million standard cubic feet of natural gas were released as a result of the rupture. The released natural gas was ignited after the rupture; the subsequent explosion created a crater about 72 feet long by 26 feet wide, and the resulting fire destroyed 38 homes and damaged 70. A ruptured pipe segment about 28 feet long was found about 100 feet away from the crater.

Probable Cause: The National Transportation Safety Board determines that the probable cause of the accident was the Pacific Gas and Electric Company's (PG&E) (1) inadequate quality assurance and quality control in 1956 during its Line 132 relocation project, which allowed the installation of a substandard and poorly welded pipe section with a visible seam weld flaw that, over time grew to a critical size, causing the pipeline to rupture during a pressure increase stemming from poorly planned electrical work at the Milpitas Terminal; and (2) inadequate pipeline integrity management program, which failed to detect and repair or remove the defective pipe section.

Ntsbnumber: DCA10MP008

Report Number: PAR-11-01

Addressee Name: PHMSA

Addressee Status: Closed - Acceptable Alternate Action

Addressee Date Closed: 2018-02-21

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2012-07-25

Communication Type: Recommendation Reiteration

Communication Contents: From the report of the Enbridge Incorporated, Hazardous Liquid Pipeline Rupture and Release in Marshall, Michigan July 25, 2010 (adopted July 10, 2012 and published July 25, 2012): Firefighters were dispatched to investigate an outdoor odor in response to a 911 call received on the evening of July 25. The caller to 911 said that there was a strong odor of either natural gas or crude oil near the airport along 17 Mile Road. Firefighters searched the area with combustible gas indicators and examined nearby industrial business areas and two natural gas facilities on Division Drive. The firefighters were unfamiliar with the odors associated with crude oil and were unable to identify the source. Over the course of the 14 hours following the first call to report the outdoor odor, seven more calls to 911 reported strong natural gas or petroleum odors in the same area. The 911 operators repeatedly informed the callers that the fire department had been dispatched to investigate the issue, but the 911 operators did not contact the pipeline operator or advise the public of health and safety risks. The 911 operators never dispatched the fire department in response to the subsequent calls even though these calls occurred over several hours, indicating an ongoing problem. The actions of both the first responders and the 911 operators are consistent with a phenomenon known as confirmation bias, in which decision makers search for evidence consistent with their theories or decisions, while discounting contradictory evidence. Although there was evidence available to the first responders that something other than natural gas was causing noticeable odors in the Marshall area, they discounted that evidence, largely because it contradicted their own findings of no natural gas in the area. Similarly, the 911 operators, with the evidence from the first responders of no natural gas in the area, discounted subsequent calls regarding the strong odors in the Marshall area. Those calls were inconsistent with their own views that the problem causing the odors was either nonexistent or had been resolved. Although Enbridge had provided training to emergency responders in the Marshall area in February 2010, the firefighters’ actions showed a lack of awareness of the nearby crude oil pipeline: they did not search along the Line 6B right-of-way, and they did not call Enbridge. The NTSB concludes that had the firefighters discovered the ruptured segment of Line 6B and called Enbridge, the two startups of the pipeline might not have occurred and the additional volume might not have been pumped. The NTSB reviewed Enbridge’s PAP, which was intended to inform the affected public, emergency officials, and public officials about pipelines and facilitate their ability to recognize and respond to a pipeline rupture. Although RP 1162 requires operators to communicate with audiences every 1 to 3 years, Enbridge mailed its public awareness materials to all audiences annually. However, even with more frequent mailings, this accident showed that emergency officials and the public lacked actionable knowledge. Public knowledge of pipeline locations and the hazards associated with the materials transported is critical for successful recognition and reporting of releases, as well as the safe response to pipeline ruptures. The transportation of hazardous materials by pipeline is unlike hazardous materials transportation by railroad or highway because a pipeline is a permanent fixture. A pipeline presents a unique challenge to awareness because it is often buried. When pipeline releases occur, a properly educated public can be the first to recognize and report the emergency. The NTSB found that Enbridge conducted annual informal assessments and participated in the PAPERS survey every 2 years. A review of the 2009 PAPERS survey responses showed that of those who responded only 23 percent of the affected public and 47 percent of emergency officials responded that they were “very well informed” about pipelines in their community. Although the Enbridge program plan stated that effectiveness reviews were to be conducted, no specific guidelines or measurements for the evaluations were defined. Enbridge’s failure to have a process for using these survey results for improvements demonstrated a lack of commitment to improving the quality of its program. Therefore, the NTSB concludes that Enbridge’s review of its PAP was ineffective in identifying and correcting deficiencies. The NTSB further concludes that had Enbridge operated an effective PAP, local emergency response agencies would have been better prepared to respond to early indications of the rupture and may have been able to locate the crude oil and notify Enbridge before control center staff tried to start the line. In May 2011, Enbridge revised its public awareness plan and created a public awareness committee that includes a performance metrics subcommittee. According to the committee charter, the committee meets four times a year and is responsible for an annual review of the PAP and the program performance measures. In July 2011, PHMSA conducted an audit of Enbridge’s PAP. PHMSA identified several deficiencies in Enbridge’s program evaluation and effectiveness reviews and required that Enbridge correct the deficiencies. Although Enbridge and PHMSA have taken these actions, the NTSB is concerned that pipeline operators do not provide emergency officials with specific information about their pipeline systems. The brochures that Enbridge mailed did not identify its pipeline’s location. Instead, the brochures directed the audiences to pipeline markers and to PHMSA’s National Pipeline Mapping System. In the NTSB’s 2011 report of the natural gas transmission pipeline rupture and fire in San Bruno, California, the NTSB made the following safety recommendation to PHMSA: (P-11-8) In its response letter to the NTSB, PHMSA stated that it had an emergency responder forum to identify pipeline emergencies for which emergency responders need to know how to adequately prepare and respond. This safety recommendation was classified “Open—Acceptable Response.” Although PHMSA has held the emergency responder forum, no rulemaking has been initiated. Therefore, the NTSB reiterates Safety Recommendation P-11-8 to PHMSA. Because system-specific pipeline information is critical to the safe response to pipeline incidents, the NTSB is also concerned about the emergency officials’ lack of awareness of Enbridge’s pipeline. Therefore, the NTSB recommends that the International Association of Fire Chiefs and the National Emergency Number Association inform their members about the circumstances of the Marshall, Michigan, pipeline accident and urge their members to aggressively and diligently gather from pipeline operators system-specific information about the pipeline systems in their communities and jurisdictions.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2011-12-07

Communication Type: NPRM Response

Communication Contents: Notation 8360: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) Advance Notice of Proposed Rulemaking (ANPRM), “Pipeline Safety: Safety of Gas Transmission Pipelines,” that was published in the Federal Register on August 25, 2011. PHMSA is considering whether changes to the regulations governing the safety of gas transmission pipelines are needed, and is inviting comments on 14 specific topic areas in 2 broad categories—integrity management-related requirements and nonintegrity management requirements. In the area of integrity management, PHMSA is seeking comments and information about revising the definition of high consequence areas (HCA), including more prescriptive language, and placing additional restrictions on the use of specific pipeline assessment methods. In the nonintegrity management area, PHMSA is seeking information and comments about strengthening or expanding requirements for the spacing of mainline valves; installation of remotely operated or automatically operated valves; and corrosion control of steel pipelines, gas gathering lines, and underground gas storage facilities. The NTSB believes that the regulations for gas transmission pipelines can and should be improved and supports the overall intent of the ANPRM. However, the publication of the ANPRM 5 days before the NTSB public meeting on the Pacific Gas and Electric Company (PG&E) natural gas transmission pipeline rupture in San Bruno, California, precluded any mention in the ANPRM of the safety recommendations the NTSB adopted at the public meeting held on August 30, 2011, and issued on September 26, 2011. As a result of the Board Meeting, the NTSB issued 13 safety recommendations (P-11-8 through P-11-20) to PHMSA to improve the safety of natural gas transmission pipelines. The NTSB believes PHMSA should seek comments and information related to its safety recommendations to PHMSA issued as a result of the San Bruno investigation to take certain regulatory actions. In the ANPRM, PHMSA is also seeking information that would be relevant to Safety Recommendation P-93-9 the NTSB issued as a result of its accident investigation of an explosion and fire of a natural gas pipeline from a salt dome storage cavern in Brenham, Texas, on April 7, 1992. The accident resulted in 3 fatalities and 21 injuries. Safety Recommendation P-93-9 was classified “Closed—Unacceptable Action” on July 27, 1998, after a rulemaking proceeding to regulate underground gas storage was terminated in 1997. The NTSB supports PHMSA’s intention to reconsider regulating underground gas storage and is pleased PHMSA is revisiting this issue by seeking information and comment in this ANPRM. In support of our position, the NTSB is providing the following table listing the NTSB’s responses (that is, previously issued safety recommendations) to certain specific questions posed by PHMSA in the ANPRM: PHMSA’s ANPRM Questions NTSB’s Responses (Safety Recommendations) K.1. Should PHMSA develop Federal standards governing the safety of underground gas storage facilities? If so, should they be voluntary? If so, what portions of the facilities should be addressed in these standards? Develop safety requirements for storage of highly volatile liquids and natural gas in underground facilities, including a requirement that all pipeline operators perform safety analyses of new and existing underground geologic storage systems to identify potential failures, determine the likelihood that each failure will occur, and assess the feasibility of reducing the risk; require that operators incorporate all feasible improvements. (P-93-9) K.6. What standards are used for emergency shutdowns, emergency shutdown stations, gas monitors, local emergency response communications, public communications, and O&M Procedures? Require operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to provide system-specific information about their pipeline systems to the emergency response agencies of the communities and jurisdictions in which those pipelines are located. This information should include pipe diameter, operating pressure, product transported, and potential impact radius. (P-11-8) L.1. Are there standards used by the pipeline industry to guide management processes including management of change? Do standards governing the management of change process include requirements for IM procedures, O&M manuals, facility drawings, emergency response plans and procedures, and documents required to be maintained for the life of the pipeline? Require operators of natural gas transmission and distribution pipelines and hazardous liquid pipelines to ensure that their control room operators immediately and directly notify the 911 emergency call center(s) for the communities and jurisdictions in which those pipelines are located when a possible rupture of any pipeline is indicated. (P-11-9) PHMSA’s ANPRM Questions NTSB’s Responses (Safety Recommendations) B.4. What measures, if any, should operators be required explicitly to implement? Should they apply to all HCAs, or is there some reasonable basis for tailoring explicit mandates to particular HCAs? Should additional preventative and mitigative measures include any or all of the following: Additional line markers (line-of-sight); depth of cover surveys; close interval surveys for cathodic protection (CP) verification; coating surveys and recoating to help maintain CP current to pipe; additional right-of-way patrols; shorter ILI run intervals; additional gas quality monitoring, sampling, and in-line inspection tool runs; and improved standards for marking pipelines for operator construction and maintenance and one-calls? Require that all operators of natural gas transmission and distribution pipelines equip their supervisory control and data acquisition systems with tools to assist in recognizing and pinpointing the location of leaks, including line breaks; such tools could include a real-time leak detection system and appropriately spaced flow and pressure transmitters along covered transmission lines. (P-11-10) Amend Title 49 Code of Federal Regulations 192.935(c) to directly require that automatic shutoff valves or remote control valves in high consequence areas and in class 3 and 4 locations be installed and spaced at intervals that consider the factors listed in that regulation. (P-11-11) M.4. Are there any standards that exist that PHMSA could adopt or from which PHMSA could adapt concepts for Quality Management System (QMS)? Amend Title 49 Code of Federal Regulations 199.105 and 49 Code of Federal Regulations 199.225 to eliminate operator discretion with regard to testing of covered employees. The revised language should require drug and alcohol testing of each employee whose performance either contributed to the accident or cannot be completely discounted as a contributing factor to the accident. (P-11-12) Issue immediate guidance clarifying the need to conduct postaccident drug and alcohol testing of all potentially involved personnel despite uncertainty about the circumstances of the accident. (P-11-13) N.2. Should PHMSA repeal the MAOP exemption for pre-1970 pipelines? Should pre-1970 pipelines that operate above 72% SMYS be allowed to continue to be operated at these levels without increased safety evaluations such as periodic pressure tests, in-line inspections, coating examination, CP surveys, and expanded requirements on interference currents and depth of cover maintenance? N.3. Should PHMSA take any other actions with respect to exempt pipelines? Amend Title 49 Code of Federal Regulations 192.619 to delete the grandfather clause and require that all gas transmission pipelines constructed before 1970 be subjected to a hydrostatic pressure test that incorporates a spike test. (P-

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: We note that, rather than requiring pipeline operators to provide the recommended information to emergency response agencies, you have taken several actions to improve these agencies’ abilities to deal with a pipeline emergency, including the following: • Participating in the development of a national consensus standard, American Petroleum Institute Recommended Practice 1174, “Emergency Preparedness and Response for Hazardous Liquid Pipeline Operations.” • Fostering ongoing projects like the Pipeline Emergency Responders Initiative, which is a pipeline emergency preparedness program that brings together pipeline operators, public safety officials, and other organizations at the state level to share relevant information, train emergency responders, and improve emergency response capabilities. • Improving user interfaces and developing mobile applications for your National Pipeline Mapping System (NPMS) to make information about the product being transported, pipe diameter, and other useful basic information about pipelines more readily available to emergency responders. • Publishing a primer, in conjunction with the Federal Emergency Management Agency, titled “Pipelines and Hazard Mitigation for Emergency Management,” which educates emergency responders on how pipelines operate, the common products they transport, and potential risks of pipeline incidents and how to mitigate them. • Developing “A Guide for Communicating Emergency Response Information for Natural Gas and Hazardous Liquids Pipelines.” These actions are an alternative response that satisfies Safety Recommendation P-11-8, which is classified CLOSED--ACCEPTABLE ALTERNATE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: We understand that you continue to pursue multiple actions to address this recommendation, and that you require pipeline operators (except for operators of distribution and gathering pipelines) to submit geospatial data, attributes, metadata, public contact information, and a transmittal letter to the National Pipeline Mapping System (NPMS) program. Further, you continue to review public comments on your July 30, 2014, proposal, “Request for Revision of a Previously Approved Information Collection—National Pipeline Mapping System Program,” as well as to work with various industry partners and groups, hold public meetings, and issue notices on this subject. We would appreciate periodic updates on the status of these efforts. Pending completion of these actions, Safety Recommendation P-11-8 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2014-01-03

Communication Type: Official Correspondence

Communication Contents: We are encouraged by PHMSA’s actions to address Safety Recommendation P-11-8, including its publishing Advisory Bulletin (ADB) 10-08, Pipeline Safety: Emergency Preparedness Communications, and a request to require pipeline (other than distribution line and gathering line) facility operators to provide information and geospatial data; conducting a public awareness workshop and inspections of the pipeline operators’ public awareness plans; analyzing the results of those inspections to develop a guide for effective communications between pipeline operators and emergency responders; establishing and supporting the establishment of working groups to address communication issues for, and the training of, emergency responders, among other efforts. We support PHMSA’s plans (1) to convene a public awareness working group to identify gaps in the requirements for pipeline operators to communicate with local emergency response agencies and (2) to identify any additional changes that need to be made to federal regulations, based on the group’s findings. Pending completion of these actions, Safety Recommendation P-11-8 remains classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2015-04-08

Communication Type: Official Correspondence

Communication Contents: We understand that you are pursuing multiple actions to address this recommendation, and that you require pipeline operators (except for operators of distribution and gathering pipelines) to submit geospatial data, attributes, metadata, public contact information, and a transmittal letter to the National Pipeline Mapping System program. We note that you are currently reviewing public comments on your July 30, 2014, proposal Request for Revision of a Previously Approved Information Collection?National Pipeline Mapping System Program [79 Federal Register 58863 (Tuesday, September 30, 2014)], regarding your plans to revise the collection of additional pipeline information (for example, accuracy of pipeline maps, pipe diameter, operating pressure, pipe grade, leak detection, pipe material, and many other details). We further note that you plan to review each additional data element to determine how it is classified We understand that you convened a Public Awareness Program Working Group to analyze weaknesses in pipeline operator communications with emergency response agencies, and that you will make the group’s findings available to the public and to the API as input for potential revision to Recommended Practice 1162, Public Awareness Programs for Pipeline Operators. Finally, we note that you will review the findings to determine whether federal regulations regarding such communications also need revising. Pending completion of these actions, Safety Recommendation P-11-8 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2012-04-24

Communication Type: Official Correspondence

Communication Contents: The NTSB is aware that PHMSA issued Advisory Bulletin (ADB) PHMSA-2010-0307, Pipeline Safety: Emergency Preparedness Communications. We note that, in December 2011, PHMSA held an emergency responder forum that brought together leaders of the emergency responder community from the Federal and state governments, the public, and the pipeline industry to begin development of a strategy and action plan for improving emergency responders’ ability to prepare for, and respond to, pipeline emergencies. The forum evaluated available resources and current regulatory requirements, drew lessons from recent pipeline accidents, and looked for potential gaps in information that emergency responders need to adequately prepare for, and respond to, natural gas and hazardous liquid pipeline emergencies. PHMSA plans to use this information to address Safety Recommendation P-11-8; accordingly, the recommendation is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2013-01-11

Communication Type: Official Correspondence

Communication Contents: The NTSB is aware that PHMSA issued Advisory Bulletin (AB) PHMSA-2010-0307, Pipeline Safety: Emergency Preparedness Communications, and that, in December 2011, PHMSA held an emergency responder forum to begin development of a strategy and action plan for improving emergency responders’ ability to prepare for, and respond to, pipeline emergencies. Because PHMSA is developing language for a rule that will address Safety Recommendation P-11-8, the recommendation is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2017-11-13

Communication Type: Official Correspondence

Communication Contents: -From Howard R. Elliott, Administrator: PHMSA requests the NTSB consider this recommendation "Closed-Acceptable Alternate Action." PHMSA addressed this recommendation through multiple alternative actions that supports ongoing collaboration with pipeline operators and continual information sharing near pipelines. Through several actions, we seek to prevent pipeline incidents and improve pipeline emergency response through collaboration, engagement and training. PHMSA achieved this by enhancing resources for emergency responder, communities, and pipeline operators. Actions include: • August 2017, PHMSA initiated a partnership with the National Volunteer Fire Council to raise pipeline awareness and disseminate information out to over 700,000 volunteer fire service members across the.country (representing 69 percent of all firefighters in the country) on an ongoing basis. • September 2013, PHMSA established a Public Awareness Program Working Group (P APWG), a collaborative stakeholder group, to discuss public awareness improvements and how pipeline safety information is delivered to emergency responders and other affected stakeholders. The group reviewed pipeline awareness data and information from various sources, performed a "strengths, weaknesses, opportunities, and threats" (SWOT) analysis, and issued findings for stakeholder consideration. On May 16, 2016, the PAPWG issued its SWOT analysis final report (https://primis.phmsa.dot.gov/comm/PublicAwareness/docs/PAPWG%20SWOT%20Analysis%20Report-FINAL%2005-16-16.pdf). The SWOT report findings may be considered as the American Petroleum Institute (API) convenes an industry-wide task group to rewrite the API Recommended Practice (RP) 1162, Public Awareness Programs for Pipeline Operators. The rewrite may be complete and published by the end of 2019. • PHMSA participated in the development of national consensus standards, API RP 1174: Emergency Preparedness and Response for Hazardous Liquid Pipeline Operations, published in December 2015. This practice seeks to promotes the continual improvement of emergency planning and response processes, including identification and mitigation of associated risks and implementation of changes from lessons learned. • Fostering ongoing initiatives like the Pipeline Emergency Responders Initiative (PERI, https://www.phmsa.dot.gov/pipeline/safety-awareness-and-outreach/PERI), which is a pipeline emergency preparedness program that brings together stakeholders in various states to include pipeline operators, public safety officials, and other organizations at the state level to share relevant information, train emergency responders and improve emergency response capabilities. This effort, initiated in Georgia (http://www.gmagassection.org/GasSectionSite/media/PDF/GPERI-FACT-SHEET.pdf), is expanding nationally in the following states: Alabama, South Carolina, Oklahoma, Louisiana and more. • PHMSA continues to improve the National Pipeline Mapping System (NPMS, www.npms.phmsa.dot.gov) by enhancing user interfaces and developing mobile apps to make the system more user-friendly. The NPMS is an online pipeline mapping system that includes product transported, pipe diameter (an optional field reported by approximately 75% of pipeline operators), and other basic information about pipelines that is useful to emergency responders. In 2015, PHMSA improved the NPMS by including pipeline operator emergency contact information. • In January 2015, PHMSA co-published a primer titled "Pipelines and Hazard Mitigation for Emergency Management" (https://www.fema.gov/medialibrary/ assets/documents/101688). with the Federal Emergency Management Agency . (FEMA). The goal of this primer is to provide emergency managers, planners, and others involved with developing hazard mitigation plans with the knowledge and understanding of how pipelines operate, the common products that may be transported through transmission and distribution pipeline systems, the potential impacts (risks) of pipeline incidents, and mitigation strategies they can implement to reduce these risks. • PHMSA funded the development of "A Guide for Communicating Emergency Response Information for Natural Gas and Hazardous Liquids Pipelines" (https://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Pipeline/hmcrprpt014.pdf) through the Hazardous Materials Cooperative Research Program. The guide (1) includes the appropriate emergency response content that should be provided to emergency responders, (2) recommends effective means of disseminating the guidance by pipeline operators to recipient emergency response organizations and by those emergency response organizations to sub-units, and (3) recommends strategies for implementing and exercising the emergency response plan. The guide was published by the Transportation Research Board in 2014.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-08-17

Communication Type: Official Correspondence

Communication Contents: -From Marie Therese Dominguez, Administrator: PHMSA is pursuing multiple actions to address this recommendation. We are pleased that NTSB was encouraged by the publication of ADB-10-08: "Pipeline Safety: Emergency Preparedness Communications." In September 2013, PHMSA convened a collaborative stakeholder group called the Public Awareness Program Working Group (PAPWG). The mission of PAPWG was to review pipeline awareness data and information from various sources, identify relevant topical review areas, and perform a ''strengths, weaknesses, opportunities, and threats" (SWOT) analysis of those areas. On May 16, 2016, PAPWG issued a SWOT analysis on gaps in the requirements for pipeline operators to communicate with the affected emergency response stakeholder audience. The final report is available to the public here: https://primis.phmsa.dot.gov/comm/PublicAwareness/docs/PAPWG%20SWOT%20Analysis %20Report-FINAL%2005-16-16.pdf. In addition, PHMSA held a Public Awareness Workshop on July 13, 2016, to bring pipeline safety stakeholders, including the American Petroleum Institute (API), together to review the findings from the P APWG SWOT Report and explore future actions that can be taken to expand public awareness and stakeholder engagement efforts. On August 5, 2016, API staff invited PHMSA representatives to participate on an AP1 RP 1162 Ad Hoc Team that will use the Pipeline Public Awareness SWOT report and input from Ad hoc team members to develop specific recommendations for enhancing API RP 1162 by January 2017. Currently, pipeline operators (except for operators of distribution and gathering pipelines) are required to submit geospatia1 data, attributes, metadata, public contact information, and a transmittal letter to the National Pipeline Mapping System (NPMS) program. Emergency responders have access to data on pipe diameter (an optional submission, but submitted by approximately 75 percent of pipeline operators) and product transported. On July 30, 2014, PHMSA published the Federal Register notice, "Request for Revision of a Previously Approved Infonnation Collection- National Pipeline Mapping System Program," inviting public comment on our intent to request OMB approval to revise and renew an information collection currently under OMB Control Number 2 137-0596. The information collection proposes additional information such as: improved positional accuracy of pipeline maps, pipe diameter (currently optional; would now be required), operating pressure, pipe grade, percent of specified minimum yield strength, leak detection, pipe coating, pipe material, pipe join method, year of construction/installation, class location, high consequence "could affect" areas, onshore/offshore designation, inline inspection capability, year of last inline inspection/direct assessment, year and pressure of original and last hydrostatic test, detail on commodities transported, locations of special permits issued by PHMSA, pipe wall thickness, and seam type. On August27, 2015, PHMSA issued a second 60-day notice and comments were received and analyzed. PHMSA published the 30-day notice on June 22, 2016, and PHMSA is now in the process of reviewing each additional data element to determine classification.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2013-08-29

Communication Type: Official Correspondence

Communication Contents: -From Cynthia L. Quarterman, Administrator: PHMSA proposes to close this recommendation. On November 3, 2010, PHMSA published Advisory Bulletin “ADB-10-08: Pipeline Safety: Emergency Preparedness Communications,” which advised operators of gas and hazardous liquid pipeline facilities that they must make their pipeline emergency response plans available to local emergency response officials. PHMSA recommended that operators provide their emergency response plans to officials through their required liaison and public awareness activities. Additional actions include: • Conducted a Public Awareness Workshop on June 19-20, 2013 that brought together pipeline safety public awareness stakeholders to discuss general findings from recent Federal and State public awareness inspections; gain perspective on public awareness challenges and successes; and identify ways to strengthen pipeline safety public awareness, including pipeline safety preparedness and response for local emergency response and public safety agencies. • Completing Federal inspections of pipeline operators’ public awareness plans. PHMSA is analyzing the results of these inspections. Pipeline operator public awareness plans are required by 49 CFR 192.616 and 49 CFR 195.440. Operators must develop and implement public awareness programs that follow the guidance provided by the American Petroleum Institute (API) Recommended Practice (RP) 1162, "Public Awareness Programs for Pipeline Operators" (incorporated by reference in Federal regulations). • Provided funding for a research project through the Hazardous Materials Cooperative Research Program to develop a guide for effective communication between pipeline operators and emergency responders. The guide will be available in August 2013. • Established a Pipeline Emergency Response Working Group of emergency responders, pipeline operators, and regulators to serve as a forum for discussing strategies for institutionalizing pipeline safety knowledge in the emergency response community. The working group meets regularly to discuss goals and methods of implementation. • Supported the formation of a working group of pipeline operators, emergency responders, and regulators in Georgia to create a statewide strategy. The strategy establishes and sustains effective two-way communication between emergency responders and the pipeline industry, develops a comprehensive training program for emergency responders to better understand the risks associated with pipeline facilities and to know how to properly respond to a pipeline incident, and develops a model that will work for Georgia and be transferrable to other States. • Published a request for the renewal of an information collection that would require each operator of a pipeline facility (except for distribution lines and gathering lines) to provide PHMSA with contact information and geospatial data on their pipeline system. The data will be incorporated into the National Pipeline Mapping System (NPMS) to support various regulatory programs, pipeline inspections, and authorized external customers. The update informs the NPMS of any changes to the data over the previous year and allows PHMSA to maintain and improve the accuracy of the information. Further, PHMSA plans is to convene a Public Awareness (PA) Working Group that will leverage the results of the efforts described above and issue findings on gaps in the requirements for pipeline operators to communicate with local emergency response agencies. The findings of the PA Working Group will be made available to the public in the first quarter of calendar year 2014. PHMSA will also make the findings available to the API as input on public awareness for revision to API Recommended Practice 1162. PHMSA will review the PA Working Group’s findings to determine if additional changes need to be made to Federal regulations regarding communications and information sharing between pipeline operators and local emergency response agencies.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2015-01-22

Communication Type: Official Correspondence

Communication Contents: -From Timothy P. Butters, Acting Administrator: PHMSA is pursuing multiple actions to address this recommendation. Currently, pipeline operators (except for operators of distribution and gathering pipelines) are required to submit geospatial data, attributes, metadata, public contact information, and a transmittal letter to the National Pipeline Mapping System (NPMS) program. Further, emergency responders have access to data on pipe diameter (voluntarily submitted by approximately 75 percent of pipeline operators) and product transported. On July 30, 2014, PHMSA published the Federal Register notice titled, "Request for Revision of a Previously Approved Information Collection- National Pipeline Mapping System Program," inviting public comment on our intent to request the OMB's approval to revise and renew an information collection currently under OMB Control Number 2137-0596. The information collection proposes additional information gathering such as: improved positional accuracy of pipeline maps, pipe diameter (currently an optional submission only), operating pressure, pipe grade, percent of specified minimum yield strength, leak detection, pipe coating, pipe material, pipe join method, year of construction/installation, class location, high consequence "could affect" areas, onshore/offshore designation, inline inspection capability, year of last inline inspection/direct assessment, year and pressure of original and last hydrostatic test, detail on commodities transported, locations of special permits issued by PHMSA, pipe wall thickness, and seam type. As part of the process, we will review each additional data element to determine classification. Comments were due by December 1, 2014 and are currently under review. PHMSA also convened a Public Awareness Program Working Group (PAPWG). The PAPWG will issue a strengths, weaknesses, opportunities, and threats (SWOT) analysis on gaps in the requirements for pipeline operators to communicate with the affected emergency response stakeholder audience. The SWOT findings will be made available to the public and NTSB in calendar year 2015. PHMSA will also make the findings available to the American Petroleum Institute (API) as input for potential revision to API Recommended Practice 1162, "Public Awareness Programs for Pipeline Operators." PHMSA will review the findings to determine if additional changes need to be made to Federal regulations regarding communications and information sharing between pipeline operators and local emergency response agencies.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2011-12-14

Communication Type: Official Correspondence

Communication Contents: -From Cynthia L. Quarterman, Administrator: On November 3, 2010, PHMSA issued Advisory Bulletin PHMSA-2010-0307 regarding Pipeline Safety: Emergency Preparedness Communications. PHMSA expanded on that effort through an Emergency Responder Forum, which was held on December 9, 2011 at the U.S. Department of Transportation’s Headquarters in Washington, DC. The NTSB was invited to attend. This Forum convened leaders from the emergency responder community, Federal and State Government, the public, and the pipeline industry to begin development of a strategy and action plan for improving emergency responders’ ability to prepare for and respond to pipeline emergencies. Our Forum evaluated available resources and current regulatory requirements, and drew lessons from several recent pipeline accidents, and sought to reveal potential gaps in information firefighters and other emergency responders need to prepare for and respond to natural gas and hazardous liquid pipeline emergencies adequately. PHMSA will create a plan to address this recommendation now that the Forum is completed.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2012-11-01

Communication Type: Official Correspondence

Communication Contents: -From Cynthia Quarterman, Administrator: On November 3, 2010, PHMSA issued Advisory Bulletin PHMSA-2010-0307 regarding Pipeline Safety: Emergency Preparedness Communications. PHMSA expanded on that effort through an Emergency Responder Forum, which was held on December 9, 2011 at the U.S. DOT’s Headquarters in Washington, DC. The NTSB was invited to attend. This Forum convened leaders from the emergency responder community, Federal and State Government, the public, and the pipeline industry to begin development of a strategy and action plan for improving emergency responders’ ability to prepare for and regulatory requirements, drew lessons from several recent pipeline accidents, and sought to reveal potential gaps in information firefighters and other emergency responders need to prepare for and respond to natural gas and hazardous liquid pipeline emergencies adequately. A summary report of this forum can be viewed at: http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Pipeline%20Emergency%20Response%20Proceedings.pdf PHMSA is currently developing appropriate language to promulgate a rulemaking to address this recommendation.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence