NTSB Safety Recommendation P-15-003

NTSB safety recommendation P-15-003.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Work with the National Association of Pipeline Safety Representatives to develop and implement a program to formalize, publicize, and facilitate increased state-to-state coordination in integrity management inspections.

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: National Association of Pipeline Safety Representatives

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2016-12-05

Addressee Acronym: NAPSR

Addressee Organization Type: A-Associations

Communication Date: 2016-12-31

Communication Type: Official Correspondence

Communication Contents: -From Peter A. Chace, NAPSR National Chairman 2016-2017, Public Utilities Commission of Ohio, Gas Pipeline Safety Program Manager: NOT a response from PHMSA: In addition to the three points above, NAPSR has observed that Recommendation P-15-03 to PHMSA is identical to Recommendation P-15-27 to NAPSR. In a December 5, 2016 letter, NTSB responded to PHMSA regarding its response to P-15-27: "On April12, 2016, the director of state programs e-mailed an operator coordination report to all states, which was developed for you and the states to see whether any states have operators in common to help facilitate the coordination of inspections. We note that you are supporting an internal NAPSR website that states can use to share information to increase state-to-state coordination in 1M inspections. Because these actions satisfy the intent of Safety Recommendation P-15-3, it is classified "Closed-Acceptable Action.'

Addressee Acronym: NAPSR

Addressee Organization Type: A-Associations

Communication Date: 2017-02-22

Communication Type: Official Correspondence

Communication Contents: On December 5, 2016, we responded to PHMSA’s August 17, 2016, letter regarding companion recommendation P-15-3. Because PHMSA had worked with you on this issue as requested, Safety Recommendation P-15-3 was classified CLOSED--ACCEPTABLE ACTION.

Addressee Acronym: NAPSR

Addressee Organization Type: A-Associations

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: LETTER TO PHMSA: We understand that you addressed the recommended issues in your 2016 Guidelines for States Participating in the Pipeline Safety Program, that you will continue to publicize this new information during meetings and discussions with NAPSR, and that you will continue to encourage states to coordinate with you on inspections, including IM inspections, and to facilitate that coordination through state liaisons. Because these actions satisfy the intent of Safety Recommendation P-15-2, it is classified “Closed—Acceptable Action.” On April 12, 2016, the director of state programs e-mailed an operator coordination report to all states, which was developed for you and the states to see whether any states have operators in common to help facilitate the coordination of inspections. We note that you are supporting an internal NAPSR website that states can use to share information to increase state-to-state coordination in IM inspections. Because these actions satisfy the intent of Safety Recommendation P-15-3, it is classified CLOSED—ACCEPTABLE ACTION.

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 the recommended issues in your 2016 Guidelines for States Participating in the Pipeline Safety Program, that you will continue to publicize this new information during meetings and discussions with NAPSR, and that you will continue to encourage states to coordinate with you on inspections, including IM inspections, and to facilitate that coordination through state liaisons. Because these actions satisfy the intent of Safety Recommendation P-15-2, it is classified “Closed—Acceptable Action.” On April 12, 2016, the director of state programs e-mailed an operator coordination report to all states, which was developed for you and the states to see whether any states have operators in common to help facilitate the coordination of inspections. We note that you are supporting an internal NAPSR website that states can use to share information to increase state-to-state coordination in IM inspections. Because these actions satisfy the intent of Safety Recommendation P-15-3, 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 commend your ongoing support of the National Association of Pipeline Safety Representatives (NAPSR) and its website, where states can share relevant information, and the anticipated implementation of your state-to-state mentoring program, which includes IM inspections. We note that you intend to work with NAPSR to complete the recommended actions by December 31, 2015; accordingly, Safety Recommendation P-15-3 is classified OPEN—ACCEPTABLE RESPONSE, pending completion of this effort.

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 work with the National Association of Pipeline Safety Representatives (NAPSR) to develop and implement a program to formalize, publicize, and facilitate increased state-to-state coordination in integrity management inspections by December 31, 2015. The program will be documented and include a perspective on the current level of coordination, challenges associated with effecting increased coordination, and actions for implementing increased and effective coordination. Further, PHMSA supports NAPSR on a continual basis, including supporting a NAPSR website where States can share information, and is working to implement its current state-to-state mentoring program, which includes the area of IM inspections.

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. Please see PHMSA's response to NTSB Safety Recommendation P-15-2, which describes PHMSA strategies for publicizing and facilitating increased coordination at NAPSR meetings. On April 12, 20 16, the Director of State Programs emailed an "Operator Coordination Report" to all States. This report was developed for use by states and PHMSA to see whether other states have operators in common to help facilitate the coordination of inspections. This report also allows states to see whether they have operators in common with PHMSA. PHMSA also supports an internal NAPSR website where states can share information to facilitate increased state-to-state coordination in integrity management inspections. PHMSA does not envision taking further action to close this recommendation.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence