# NTSB Safety Recommendation P-11-018 - **operation:** document - **citation:** P-11-018 - **title:** NTSB Safety Recommendation P-11-018 - **source type:** guidance - **agency:** National Transportation Safety Board - **status:** guidance - **official:** true - **published on:** 2011-09-26 - **effective on:** 2011-09-26 - **summary:** TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Revise your integrity management inspection protocol to (1) incorporate a review of meaningful metrics; (2) require auditors to verify that the operator has a procedure in place for ensuring the completeness and accuracy of underlying information; (3) require auditors to review all integrity management performance measures reported to the Pipeline and Haz - **machine formats:** - **json:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-11-018.json - **markdown:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-11-018.md - **app url:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-11-018 - **source url:** https://data.ntsb.gov/carol-main-public/sr-details/P-11-018 **body:** NTSB safety recommendation P-11-018. TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Revise your integrity management inspection protocol to (1) incorporate a review of meaningful metrics; (2) require auditors to verify that the operator has a procedure in place for ensuring the completeness and accuracy of underlying information; (3) require auditors to review all integrity management performance measures reported to the Pipeline and Hazardous Materials Safety Administration and compare the leak, failure, and incident measures to the operator’s risk model; and (4) require setting performance goals for pipeline operators at each audit and follow up on those goals at subsequent audits. Priority: CLASS II Overall Status: Closed - Acceptable 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 Action Addressee Date Closed: 2018-02-21 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: 2016-06-06 Communication Type: NPRM Response Communication Contents: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) notice of proposed rulemaking (NPRM), Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines, published on April 8, 2016. This NPRM addresses issues raised in an August 25, 2011, advance notice of proposed rulemaking (ANPRM) regarding the revision of pipeline safety regulations applicable to the safety of gas transmission and gas gathering pipelines, particularly those involving integrity management (IM). Proposal Topic E—Making Requirements Related to the Nature and Application of Risk Models More Detailed Summary PHMSA states its intention to require the addition of more detail related to the application of pipeline risk analyses models. PHMSA proposes to clarify the risk assessment aspects of the IM rule to explicitly articulate functional requirements and to assure that risk assessments are adequate to: (1) evaluate the effects of interacting threats, (2) determine intervals for continual integrity reassessments, (3) determine additional preventive and mitigative measures needed, (4) analyze how a potential failure could affect HCAs, including the consequences of the entire worst-case incident scenario from initial failure to incident termination, (5) identify the contribution to risk of each risk factor, or each unique combination of risk factors that interact or simultaneously contribute to risk at a common location, (6) account and compensate for uncertainties in the model and the data used in the risk assessment, and (7) evaluate predicted risk reduction associated with preventive and mitigative measures. These proposed actions address items 1 and 3 from Safety Recommendation P-11-18, which resulted from the investigation of the September 9, 2010, pipeline rupture and fire in San Bruno, California. Revise your integrity management inspection protocol to (1) incorporate a review of meaningful metrics; (2) require auditors to verify that the operator has a procedure in place for ensuring the completeness and accuracy of underlying information; (3) require auditors to review all integrity management performance measures reported to the Pipeline and Hazardous Materials Safety Administration and compare the leak, failure, and incident measures to the operator’s risk model; and (4) require setting performance goals for pipeline operators at each audit and follow up on those goals at subsequent audits. (P-11-18) PHMSA also notes in this NPRM that it proposes to require that operators validate their risk models in light of incident and leak failure history, and other historical information as an additional action in response to the recommendation. Response The NTSB concurs with the proposed actions. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2018-02-21 Communication Type: Official Correspondence Communication Contents: On April 8, 2015, we noted that you had completed action on the first three items of this recommendation and that you were working to complete action related to the fourth item. Since then, you have modified several components of your inspection and enforcement processes, including developing more meaningful metrics to be used in pipeline operators’ IM programs. We agree that these actions satisfy the intent of Safety Recommendation P-11-18, which is classified CLOSED--ACCEPTABLE ACTION. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Date: 2016-12-05 Communication Type: Official Correspondence Communication Contents: On April 8, 2015, based on information in your January 22, 2015, letter, we noted that you had completed action on the first three items of this recommendation and were working on final steps to complete action related to the fourth item. We understand that you have modified several components of your inspection and enforcement processes and procedures regarding meaningful metrics and their inclusion in pipeline operators’ IM programs. Accordingly, pending notification that you have completed part four of Safety Recommendation P-11-18, it 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: At the September 2013 joint staff meeting, we learned that PHMSA has made great progress in addressing these issues that include near-completion of a two-pronged approach to enhance oversight of current requirements for performance evaluation and associated measures, and to develop and improve guidance for operators to develop more meaningful metrics. We are aware that PHMSA created gas and liquid data and metrics teams and, in December 2012, issued an ADB reminding operators of gas transmission and hazardous liquid pipeline facilities of their responsibilities, under federal integrity management regulations, to evaluate their integrity management programs using meaningful performance metrics. We are also aware of PHMSA’s January, 2013 data workshop, its database of metrics available on the PHMSA website, and the agency’s other efforts in support of these recommendations. Pending completion of the recommended actions, Safety Recommendations P-11-18 and -19 remain 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 are pleased that you have (1) modified your inspection and enforcement procedures regarding meaningful metrics and their inclusion or use in pipeline operators’ IM programs, (2) revised and improved the IM inspection questions in the Inspection Assistant application, and (3) revised your hazardous liquid and gas transmission enforcement guidance documents to address these topics. We note that both documents are available at http://www.phmsa.dot.gov/foia/e-reading-room. We understand that you are developing a data analysis program to evaluate performance metrics derived from your incident and annual report data sets, and are considering posting operator metrics and goals on your website for public viewing. We commend your plans to encourage operators to exceed performance standards and to strive continuously to improve their safety records. Pending completion of actions to satisfy Safety Recommendations P-11-18, the recommendation 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: PHMSA has initiated action to revise its IMP inspection protocol and amend its audit requirements as requested. Accordingly, pending completion of these efforts, Safety Recommendation P-11-18 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 closure of this recommendation. In our last update dated August 17, 2016, PHMSA reported on our actions in completing the remaining component of this recommendation, including modifying several components of our inspection and enforcement processes and procedures regarding meaningful metrics and their inclusion and use in pipeline operators' integrity management (IM) programs. We also issued advisory bulletin ADB-2012-10, "Pipeline Safety: Using Meaningful Metrics in Conducting Integrity Management Program Evaluations" (77 FR 72435, https://www.federalregister.gov/documents/2012/12/05/2012-29362/pipeline-safetyusing-meaningful-metrics-in-conducting-integrity-management-program-evaluations) reminding operators of gas transmission and hazardous liquid pipeline facilities of their responsibilities, under Federal IM regulations, to perform evaluations of their IM programs using meaningful performance metrics. On October 15, 2014, PHMSA issued advisory bulletin ADB-2014-05, "Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics" (79 FR 6193 7, https://www.federalregister.gov/documents/2014110/15/2014-24439/pipeline-safety-guidance-for-strengthening-pipeline-safety-through-rigorousprogram-evaluation-and), which included guidance on the elements and characteristics of a mature program evaluation process that uses meaningful metrics. Additionally, PHMSA worked with a diverse stakeholder group, including public representatives, regulators and industry, to identify key performance indicators for three groups of pipeline systems - gas distribution, gas transmission, and persistent liquid commodities transported through hazardous liquid pipelines. The measures are derived from PHMSA incident and annual report data sets. These National Pipeline Performance Measures are available to the public at https://www.phmsa.dot.gov/pipeline/library/datastats/performance-measures. All of the measures have a national scope, with links within the measures providing access to data for individual operators and safety programs (groups of operators). The materials produced to address this recommendation were incorporated into the 2013 updates to our IM inspection tools. Operator performance relative to those in its peer group will be discussed with each operator during inspections and will help inform the focus areas of the inspection. Operators who perform significantly worse than their peers according to these metrics may be identified for intervention action such as executive performance reviews. Intervention actions would depend on the specific operator performance and other factors. 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 bas completed actions on the first three items of this recommendation and is working on final steps to complete actions related to the fourth item. PHMSA has modified several components of our inspection and enforcement processes and procedures regarding meaningful metrics and their inclusion and use in pipeline operators' integrity management (IM) programs. Specifically, PHMSA has revised and improved the IM inspection questions in the Inspection Assistant (IA) application used by PHMSA inspectors. We made significant enhancements, including the addition of more detailed guidance and considerations to the gas IM questions. We bolstered our liquid IM questions as well, so that the evaluation of meaningful metrics is similar for both gas and liquid IM. The incorporation of the new questions and modification of other questions has provided for the specific incorporation of meaningful metrics and their trending towards performance goals within operators' IM programs. Similar to the revised 1M inspection questions in the IA application, PHMSA implemented changes in the Hazardous Liquid and Gas IM Inspection Protocols used by State Programs to conduct IM inspections. These revised questions are posted on the public web sites. The new protocol fom1s, guidance, and other related reference material can be found on our gas and liquid IM public web sites, https://primis.phmsa.dot.gov/gasimp/ and https://primis.phmsa.dot.gov/iim/index.htm respectively, so they can be shared with operators and all stakeholders. We have also revised our hazardous liquid and gas transmission enforcement guidance documents to address these topics. Both documents are available now at http://www.phmsa.dot.gov/foia!e-reading-room. Inspectors now have additional resources to help them evaluate the effectiveness of an operator's use of meaningful metrics and to develop enforcement cases when necessary. During the course of an inspection of an operator's JM program, an inspector gains insight into the threats and potential consequences specific to the operator's unique operating environment. Based on these insights, the inspector is well equipped to evaluate the adequacy or inadequacy of the metrics an operator is utilizing to measure the performance of its IM program. Enforcement can be handled by requiring modifications to the IM program in the case of inadequate metrics or by use of orders if the trends in the metrics' data are not proving satisfactory and their actions not in compliance. The results of the PHMSA inspections are documented in the inspection reports. along wi.th enforcement data, when applicable, for follow-up evaluations at subsequent audits. Over the last 24 months, PHMSA has worked with a diverse stakeholder group. Including public representatives, regulators and industry, to identify key performance metrics for hazardous liquid, gas transmission, and gas distribution pipelines. PHMSA is developing a data analysis progran1 that looks at performance metrics derived from our incident and annual report data sets. The specific performance data for operators is evaluated, and key metrics are evaluated and compared to other operators in a comparable peer group (e.g., according to the size of operator based on mileage or the type of commodities transported by operator). Operator performance relative to those in its peer group will be discussed with each operator during inspections and will help inform the focus areas of the inspection. Operators who perform significantly worse than their peers according to these metrics may be targeted for intervention action, such as executive performance reviews. Intervention actions would depend on the specific operator performance and other factors. While we believe that our past inspections and enforcement actions have directed operators to consider performance measures (in cases where appropriate), these new questions and written guidance will provide additional assurance that meaningful and appropriate performance measures are considered and implemented by operators in their IM programs. In December 2012, PHMSA issued an Advisory Bulletin ADB-2012-10, "Pipeline Safety: Using Meaningful Metrics in Conducting Integrity Management Program Evaluations," reminding operators of gas transmission and hazardous liquid pipeline facilities of their responsibilities. under Federal integrity management regulations, to perform evaluations of their IM programs using meaningful performance metrics. Finally, PHMSA also revised its hazardous liquid and gas transmission enforcement guidance documents. We developed a data analysis program that looks at performance metrics derived from our incident and annual report data sets. 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 has nearly completed a “two-pronged” approach to: 1. Enhance oversight of current requirements for performance evaluation and associated measures; and 2. Develop and improve guidance for operators to develop more meaningful metrics. PHMSA stood up gas and liquid data and metrics teams comprised of representatives from Federal and State government, the pipeline industry, and the public. The purpose of these teams is to: • Identify key performance indicators and supporting meaningful metrics; • Identify leading and predictive indicators; • Improve the data collected by OPS; and • Improve the knowledge base of the pipeline industry. In January 2013, PHMSA held a data workshop facilitating our collection and sharing of information regarding data quality improvement; current performance measures; improving performance measures; and the best methods for collecting, analyzing, and ensuring the transparency of the additional data needed to improve performance measures. In December 2012, PHMSA issued an advisory bulletin (CITATION) reminding operators of gas transmission and hazardous liquid pipeline facilities of their responsibilities, under Federal integrity management regulations, to perform evaluations of their integrity management programs using meaningful performance metrics. 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 has modified several components of our inspection and enforcement processes and procedures regarding meaningful metrics and their inclusion or use in pipeline operators' integrity management (IM) programs. PHMSA has revised and improved the IM inspection questions in the Inspection Assistant (IA) application. We made significant enhancements, including the addition of more detailed guidance and considerations to the gas IM questions. We bolstered our liquid IM questions as well so that the evaluation of meaningful metrics is similar for both gas and liquid IM. The incorporation of the new questions and modification of other questions has provided for the specific incorporation of meaningful metrics. Moreover, these metrics are trending towards performance goals within the operators' IM program. The new questions were available in IA to support inspections beginning in CY2014. Similar to the revised IM inspection questions in the IA application, changes were implemented in the HL and Gas IM Inspection Protocols used by State Programs to conduct IM inspections. These revised questions are posted on the public websites. The new protocol forms, guidance and other related reference material can be found on our gas and liquid IM public web sites, https://primis.phmsa.dot.gov/gasimp/ and https://primis.phmsa.dot.gov/iim/index.htm respectively, so they can be shared with operators and all stakeholders. State Programs were notified to begin using these new protocol forms for upcoming IM inspections beginning in CY2014. We have also revised our hazardous liquid and gas transmission enforcement guidance documents to address these topics. Both documents are available now at http://www.phmsa.dot.gov/foia/e-reading-room. Inspectors now have additional resources to help them evaluate the effectiveness of an operator's use of meaningful metrics and to develop enforcement cases when necessary. During the course of an inspection of an operator's IM program, an inspector gains insight into the threats and consequences specific to the operator's unique operating environment. Based on these insights, the inspector is well equipped to evaluate the adequacy or inadequacy of the metrics an operator is utilizing to measure the performance of its IM program. Enforcement can be handled by requiring modifications to the IM program in the case of inadequate metrics or by use of orders if the trends in the metrics' data are not proving satisfactory and their actions not in compliance. The results of the inspection are documented in the inspection reports along with enforcement data, when applicable, for follow-up evaluations at subsequent audits. In addition, PHMSA is developing a data analysis program that looks at performance metrics derived from our incident and annual report data sets. The specific performance data for operators will be evaluated, and key metrics evaluated and compared to other operators in a comparable peer group (e.g., according to the size of operator based on mileage or the type of commodities transported by operator). Operators who perform significantly worse than their peers according to these metrics (i.e., do not meet the goal) would be identified as operators whose safety performance must be improved. These operators would be targeted for possible further action by PHMSA. The actions would depend on the specific operator performance and other factors. We are preparing to implement this program in CY2015. We also are considering posting the operator metrics and goals on PHMSA's website so each company's performance is clearly visible to the public. We anticipate repeating this process annually as new performance data become available. A process will be established to enhance continuous improvement of operators' safety programs, and adjustments to the criteria for selection of operators targeted for some intervention action by PHMSA will be made over the years. PHMSA will encourage operators to do more than move towards the "industry mean average" for performance, and to strive to continuously improve their safety records. While we believe that our past inspections and enforcement actions have directed operators to consider performance measures (in cases where appropriate), these new questions and written guidance will provide additional assurance that meaningful and appropriate performance measures are considered and implemented by operators in their IM programs. 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: PHMSA agrees that clear, meaningful metrics are important. PHMSA has been collecting and reviewing integrity management performance metrics from pipeline operators since 2004. PHMSA inspectors compare the operator reported data to the records maintained by the operator for consistency. In January 2011, PHMSA issued an Advisory Bulletin on record keeping and risk, two critical components to an effective integrity management program. PHMSA intends to revise the inspection format to encourage inspectors to focus on verification of performance measures, record adequacy, data integration, and risk analysis. PHMSA has always maintained a bias for continual improvement in pipeline safety, which at times, has included in-person performance reviews with company executives. These meetings have occurred to remedy unanswered deficiencies found in inspections, and establish clear expectations these companies need to follow for compliance. We intend to maintain our continual improvement approach with pipeline operators and will continue dialogue on this subject with NTSB to ensure needed actions are taken to address concerns. Addressee Acronym: PHMSA Addressee Organization Type: G-Federal Government Communication Type: Official Correspondence - **truncated:** false - **body characters:** 33318