NTSB Safety Recommendation P-15-001

NTSB safety recommendation P-15-001.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Assess (1) the need for additional inspection protocol guidance for state inspectors, (2) the adequacy of your existing mentorship program for these inspectors, and (3) the availability of your subject matter experts for consultation with them, and implement the necessary improvements.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

Overall Date Closed: 2016-12-05

Synopsis: There are approximately 298,000 miles of onshore natural gas transmission pipelines in the United States. Since 2004, the operators of these pipelines have been required by the Pipeline and Hazardous Materials Safety Administration (PHMSA) to develop and implement integrity management (IM) programs to ensure the integrity of their pipelines in populated areas (defined as high consequence areas [HCAs]) to reduce the risk of injuries and property damage from pipeline failures. An operator’s IM program is a management system designed and implemented by pipeline operators to ensure their pipeline system is safe and reliable. An IM program consists of multiple components, including procedures and processes for identifying HCAs, determining likely threats to the pipeline within the HCA, evaluating the physical integrity of the pipe within the HCA, and repairing or remediating any pipeline defects found. These procedures and processes are complex and interconnected. Effective implementation of an IM program relies on continual evaluation and data integration. The IM program is an ongoing program that is periodically inspected by PHMSA and/or state regulatory agencies to ensure compliance with regulatory requirements.

Ntsbnumber: DCA14SS002

Report Number: SS-15-01

Addressee Name: PHMSA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2016-12-05

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: We understand that you addressed this recommendation in your 2016 Guidelines for States Participating in the Pipeline Safety Program, which was distributed to state programs on December 29, 2015. In addition, we note that you will be using your responses to several of our Gas Integrity Management safety study recommendations to update inspection materials. Because these actions satisfy the intent of Safety Recommendation P-15-1, it is classified CLOSED—ACCEPTABLE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2015-07-15

Communication Type: Official Correspondence

Communication Contents: We understand that you plan to assess each of the recommended issues and to report your findings and any identified actions for improvement to us by September 30, 2015. Pending our receipt and review of this information, Safety Recommendation P-15-1 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2015-05-12

Communication Type: Official Correspondence

Communication Contents: -From Timothy P. Butters, Deputy Administrator: The Pipeline and Hazardous Materials Safety Administration’s (PHMSA) mission is to protect people and the environment from the risks of hazardous materials transportation. We are committed to continual improvements to our oversight program to positively influence the safety performance of pipeline operators. PHMSA has a long history of cooperating and collaborating with the NTSB, and we take our responsibility to address all recommendations seriously. Integrity Management (IM) is a performance-based, process-oriented regulatory program developed by PHMSA in response to the Accountable Pipeline Safety and Partnership Act of 1996 (P.L. 104-304), the Pipeline Safety Improvement Act of 2002 (P.L. 107-355), and PHMSA’s oversight experience. Integrity management regulations supplement PHMSA’s prescriptive safety requirements and set systemic performance requirements for operators. IM is based on practices employed by many safety-oriented organizations, whereby safety is continually improved through an iterative process of collecting data, identifying and prioritizing risks, undertaking corrective actions, and assessing performance. We understand that successful implementation of performance-based systems for pipeline safety requires a significant operator commitment to the approach, a diverse set of skills possessed by the operator and regulator that extend beyond pipeline engineering, detailed information on pipeline system and operating conditions, and an understanding of the causes of incidents and near-incidents. For both operators and regulators, the heart of integrity management is to identify the most serious risks through an evaluation of system and incident data, to take data informed corrective action to address risk, and to evaluate program effectiveness and implement new measures based on ongoing assessments of the results. PHMSA is working to improve pipeline safety and the IM program through regulatory development and other means at our disposal. Our Notice of Proposed Rulemaking (NPRM) titled “Pipeline Safety: Gas Transmission,” updating gas transmission pipeline regulations, was recently sent to the Office of Management and Budget (OMB) for review. This NPRM will address many of the NTSB’s recommendations, and we expect it to help pipeline safety by both setting new requirements for operators to follow, and clarifying existing ones. PHMSA’s National Pipeline Mapping System (NPMS) Information Collection was published in the Federal Register on July 30, 2014. We expect the revised Information Collection to lead to improved positional accuracy and address the need for additional pipeline attribute information to support our internal risk models. We believe both of these efforts will be responsive to the NTSB recommendations made in their respective areas. In parallel with our rulemaking and information collection efforts, PHMSA utilizes a variety of non-regulatory approaches to improve pipeline safety and communications. Our public awareness, emergency response training, research and development (R&D), technical workshops, and enforcement programs have helped to advance pipeline safety. For example, since February 2014, PHMSA has conducted seven workshops and public meetings on technical topics such as R&D, cracking, class location, Safety Management Systems, and the National Pipeline Mapping System. PHMSA is also planning a risk-modelling workshop for the summer of 2015 to address the need for operators to move to more sophisticated risk models. Finally, pipeline operators, as owners of the pipeline infrastructure, are required to know and understand their pipeline system operating environments. PHMSA challenges operators to focus on performance and aim beyond the minimum compliance standards established through pipeline safety regulations, to ensure the safety of the public that lives and works around pipelines. Concur. PHMSA will conduct an assessment of each of these aspects of federal support for state pipeline safety inspection agencies, and report the results and any identified actions for improvement to the NTSB by September 30, 2015.

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 proposes closure of this recommendation. PHMSA assessed the need for additional inspection materials and protocols for state inspectors. Additional information on the resources available to inspectors was added to Section 5.1.4.d of the 2016 Guidelines for Slates Participating in the Pipeline Safety Program (Guidelines) distributed to State Programs on December 29,2015. Additionally, PHMSA will use its responses to various NTSB Gas Integrity Management (IM) Safety Study Report recommendations to update the inspection materials. PHMSA assessed the adequacy of the existing mentorship program for state inspectors. PHMSA used the results of this assessment to update the formal process by which states may consult with PHMSA subject matter experts (SME). Specifically, PHMSA added language to Section 5. 1.4.d of the 2016 Guidelines to document the process by which state inspectors may obtain SME support. Please see Section 4.4 and Appendix H of the 2016 Guidelines for information on the mentorship program: (http://phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/2016_State_Guidelines_Final_Version_2015_12_31_with_Appendices.pdf) PHMSA will provide no further action on this action beyond the scope of activities mentioned above.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence