NTSB Safety Recommendation P-15-004

NTSB safety recommendation P-15-004.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Increase the positional accuracy of pipeline centerlines and pipeline attribute details relevant to safety in the National Pipeline Mapping System.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

Overall Date Closed: 2020-07-16

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: 2020-07-16

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: Your update to Safety Recommendation P-15-4 describes the steps you have taken since 2014 to improve the quality of the data contained in the NPMS, including specific improvements in data submissions relative to HCAs. We note that, as part of your efforts to satisfy Safety Recommendations P-15-4 and -5, you have taken a series of steps to address the positional accuracy of NPMS data to help emergency responders more effectively locate pipelines and respond to environmental and integrity threats as well as to help in emergency planning. To this end, you published two Federal Register notices, “Request for Revision of a Previously Approved Information Collection—National Pipeline Mapping System Program,” and “Request for Revision of a Previously Approved Information Collection—NPMS Program,” which invited public comment on improved positional accuracy of pipeline maps and other pipeline attribute details. We note that you have proposed that gas transmission operators submit data at approximately 50-feet accuracy for all segments that are in a Class 2, Class 3, or Class 4 area; within an HCA or that have one or more buildings intended for human occupancy; in an identified site (49 CFR 192.903); or in a right-of-way for a designated interstate, freeway, expressway, or other principal four-lane arterial roadway, as defined in the Federal Highway Administration’s Highway Functional Classification Concepts, within the segment’s potential impact radius. We further note that all other gas pipeline segments would be mapped to a positional accuracy of approximately 100 feet and, as part of the process, you will review each additional data element to determine the appropriate security classification. In addition, you held a public meeting on this notice on November 18, 2015, and published an information collection notice on June 22, 2016. Pending completion of these efforts, Safety Recommendations P-14-4 and -5 are classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-07-16

Communication Type: Official Correspondence

Communication Contents: We note that you have taken numerous steps since this recommendation was issued to address it, including publishing four notices at the Federal Register between 2014 and 2019 asking for information, and holding two public meetings (one on November 17, 2014, and another on November 18, 2015). We further note that, on January 22, 2020, your NPMS information collection was approved by the Office of Management and Budget (OMB) for a 3-year period. You have successfully revised your data collection to increase the positional accuracy of pipeline centerlines and pipeline attribute details that are relevant to safety in the NPMS. Accordingly, Safety Recommendation P-15-4 is classified CLOSED--ACCEPTABLE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-01-23

Communication Type: Official Correspondence

Communication Contents: We note that you have taken numerous steps since this recommendation was issued to address it, including publishing three notices in the Federal Register asking for information (one each on July 30, 2014; August 27, 2015; and June 22, 2016) and held two public meetings (one on November 17, 2014, and another on November 18, 2015). On July 30, 2014, you also published a notice in the Federal Register titled, “Request for Revision of a Previously Approved Information Collection—NPMS Program,” soliciting public comment on your intent to revise and renew information collection for the NPMS. On November 17, 2014, you held a public workshop to address this and other geospatial information collection initiatives. We note that, according to your current letter, you intend to soon publish an additional information collection notice. We appreciate the actions you have taken to address this issue; however, it is unclear what specific changes you have made in response to our recommendation. Pending more detailed information on specific actions that have resulted in increased positional accuracy for pipeline centerlines, Safety Recommendation P-15-4 remains classified OPEN--ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: We note that you continue to improve the quality of the data contained in the NPMS as described in your previous letters, including making specific improvements to data submissions relative to HCAs. We further note that these activities are currently subject to the governmentwide regulatory review required by executive order. Pending completion of the review and of the activities that you have previously described, Safety Recommendations P-15-4 and -5 remain classified OPEN--ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2015-07-15

Communication Type: Official Correspondence

Communication Contents: We understand that, on July 30, 2014, you published a notice, titled Request for Revision of a Previously Approved Information Collection—National Pipeline Mapping System Program (79 Federal Register 44246), addressing the need for improved positional accuracy, and that, in response to comments you received regarding this notice, you held a public workshop on November 17, 2014, to address this and other initiatives regarding the collection of geospatial information. Further, we note that you posted information on your website at http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=101 regarding the workshop. We are pleased that you plan to continue to evaluate positional accuracy concerns and that you plan to revise the notice you published in July 2014 accordingly. Pending completion of these efforts as scheduled by the end of this year, Safety Recommendation P-14-4 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-04-20

Communication Type: Official Correspondence

Communication Contents: -From Howard R. Elliott, Administrator: PHMSA proposes closure of this recommendation. We appreciate the NTSB’s acknowledgment that PHMSA continues to improve the quality of the data contained in the National Pipeline Mapping System (NPMS). Since 2014, PHMSA has worked to increase the positional accuracy of data contained in the NPMS to assist emergency responders to more effectively locate pipelines, allowing faster responses to the environmental and safety threats caused by pipeline emergencies. As part of the development process, PHMSA worked with the Transportation Security Administration to appropriately classify sensitive data elements. On July 30, 2014, PHMSA published a Federal Register notice titled “Request for Revision of a Previously Approved Information Collection – NPMS Program.” In this notice, PHMSA proposed revisions to the NPMS data collection to expand the data attributes and geographic information system (GIS) data elements collected and to improve the positional accuracy of pipeline operators’ NPMS submissions. On November 17, 2014, PHMSA held a public workshop to discuss the proposed revisions and other geospatial information collection initiatives. On August 27, 2015, PHMSA published a second notice titled “Request for Revision of a Previously Approved Information Collection – NPMS Program,” which invited public comments to improve the positional accuracy of pipeline maps and other pipeline details.2 On November 18, 2015, PHMSA held a public meeting to receive comments relevant to this matter. On June 22, 2016, PHMSA published a third notice titled “Request for Revision of a Previously Approved Information Collection: National Pipeline Mapping System Program.” On April 11, 2019, PHMSA published a fourth notice titled “Request for Revision of a Previously Approved Information Collection: National Pipeline Mapping System Program.” On January 22, 2020, the NPMS information collection was approved by the Office of Management and Budget (OMB) for a three-year period. By 2023, PHMSA anticipates collecting the following attribute details relevant to pipeline safety: diameter, commodity details, seam type, decade of installation, wall thickness, pipe join method, pipe material, whether the pipe is coated or not, pipe grade, in-line inspection capability, gas pipeline class location, gas High Consequence Area (HCA) segment, whether the hazardous liquid segment “could affect” an HCA, and most recent assessment method and year. Additionally, the data on positional accuracy must be improved to within 50-100 feet by 2027.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2019-12-03

Communication Type: Official Correspondence

Communication Contents: -From Howard R. Elliott, Administrator: PHMSA appreciates the NTSB's acknowledgment that PHMSA continues to improve the quality of the data contained in the National Pipeline Mapping System (NPMS). Since 2014, PHMSA has worked to increase the positional accuracy of data contained in the NPMS. As part of the development process; PHMSA worked with the Transportation Security Administration to appropriately classify sensitive data elements. On July 30, 2014, PHMSA published a Federal Register notice titled, "Request for Revision of a Previously Approved Information Collection - NPMS Program." This notice solicited public comment regarding PHMSA's intent to revise and renew an information collection for the NPMS, which would require pipeline operators to submit data with improved positional accuracy. On November 17, 2014, PHMSA held a public workshop to address this and other geospatial information collection initiatives. Information about this workshop is available on PHMSA's public website at: http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg= 101. On August 27, 2015, PHMSA published a second notice, titled "Request for Revision of a Previously Approved Information Collection - NPMS Program," which invited public comment on the improved positional accuracy of pipeline maps and other pipeline attribute details. On November 18, 2015, PHMSA held a public meeting on this notice. On June 22, 2016, PHMSA published a third notice, titled "Request for Revision of a Previously Approved Information Collection: National Pipeline Mapping System Program." On April 11, 2019, PHMSA published a fourth notice, titled, "Request for Revision of a Previously Approved Information Collection: National Pipeline Mapping System Program." PHMSA is currently awaiting Office of Management and Budget (OMB) approval of this notice

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2019-04-01

Communication Type: Official Correspondence

Communication Contents: -From Howard R. Elliott, Administrator: PHMSA appreciates the NTSB's acknowledgment that PHMSA continues to improve the quality of the data contained in the National Pipeline Mapping System (NPMS). Since 2014, PHMSA has worked to increase the positional accuracy of data contained in the NPMS to assist, among other things, emergency responders to more effectively locate pipelines to quickly respond to environmental and integrity threats caused by a pipeline emergency. On July 30, 2014, PHMSA published a Federal Register notice titled "Request for Revision of a Previously Approved Information Collection - NPMS Program." This notice solicited public comment regarding PHMSA's intent to revise and renew an information collection for the NPMS, which would require pipeline operators to submit data with improved positional accuracy. On November 17, 2014, PHMSA held a public workshop to address this and other geospatial information collection initiatives. Information about this workshop is available on PHMSA's public website at: http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg= 101. On August 27, 2015, PHMSA published a second notice, titled "Request for Revision of a Previously Approved Information Collection - NPMS Program," which invited public comment on the improved positional accuracy of pipeline maps and other pipeline attribute details.7 On November 18, 2015, PHMSA held a public meeting on this notice. On June 22, 2016, PHMSA published a third Information Collection Notice titled "Request for Revision of a Previously Approved Information Collection: National Pipeline Mapping System Program." To support transparency, PHMSA intends to publish an additional Information Collection Notice by December 2019. As part of the development process, PHMSA worked with the Transportation Security Administration to appropriately classify sensitive data elements.

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: Since 2014, PHMSA has taken a series of steps to address the positional accuracy of data contained in the National Pipeline Mapping System (NPMS) to help emergency responders more effectively locate a pipeline to the degree needed to respond to environmental and integrity threats and help in emergency planning. On July 30, 2014, PHMSA first published a Federal Register notice, entitled "Request for Revision of a Previously Approved Information Collection -- NPMS Program" (79 FR 44,246, https://www.federalregister.gov/documents/2014/07/30/2014-17865/pipeline-safetyrequest-for-revision-of-a-previously-approved-information-collection-national), which invited public comment on PHMSA's intent to revise and renew an information collection of the NPMS, which would require pipeline operators to submit data with improved positional accuracy. Subsequently, on November 17, 2014, PHMSA held a public workshop to address this and other geospatial information collection initiatives. Information on the workshop is available on PHMSA's public website: http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg= 101. On August 27, 2015, PHMSA published a second notice entitled, "Request for Revision of a Previously Approved Information Collection - NPMS Program" (80 FR 52,084, https://www.federalregister.gov/documents/2015/08/27/2015-21238/pipeline-safetyrequest-for-revision-of-a-previously-approved-information-collection-national), which invited public comment on improved positional accuracy of pipeline maps, and other pipeline attribute details. On November 18, 2015, PHMSA held a public meeting on this notice. On June 22, 2016, PHMSA published an additional Information Collection Notice, "Request for Revision of a Previously Approved Information Collection: National Pipeline Mapping System Program" (81 FR 40757, https ://www.federalregister.gov/ documents/2016/06/22/2016-14 712/pipeline-safetyrequest-for-revision-of-a-previously-approved-information-information-collection). As part of the development process, PHMSA worked with TSA to appropriately classify sensitive data elements. Like many other issues before us, this is part of an ongoing regulatory review pursuant to the executive order issued by the President.

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 began addressing the positional accuracy of pipeline centerlines in the National Pipeline Mapping System (NPMS) prior to issuance of the NTSB report. On July 30, 2014, PHMSA published a notice titled “Request for Revision of a Previously Approved Information Collection—National Pipeline Mapping System Program” (79 FR 44246), which specifically addressed the need for improved positional accuracy. Subsequently, in response to comments received from the Federal Register notice, PHMSA held a public workshop on November 17, 2014, to address this and other geospatial information collection initiatives. Information on the workshop is available on PHMSA’s public website: http://primis.phmsa.dot.gov/meetings/MtgHome.mtg?mtg=101. PHMSA will continue to evaluate positional accuracy concerns and is writing a revised information collection notice that addresses this issue. We anticipate publication by December 31, 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: Since 2014, PHMSA has taken a series of steps to address the positional accuracy of data contained in the National Pipeline Mapping System (NPMS) to help emergency responders more effectively locate a pipeline to the degree needed to respond to environmental and integrity threats and to help in emergency planning. PHMSA first published a Federal Register notice titled "Request for Revision of a Previously Approved Information Collection -- NPMS Program,"1 which invited public comment on PHMSA 's intent to revise and renew an information collection of the NPMS Program, which would require pipeline operators to submit data with improved positional accuracy. Subsequently, PHMSA held a public workshop on November 17, 2014, to address this and other geospatial information collection initiatives. Information on the workshop is available on PHMSA's public website: http://primis.plunsa.dot.gov/meetings/MtgHome.rntg?mtg= 10 l. PHMSA published a second notice titled ''Request for Revision of a Previously Approved Information Collection- NPMS Program,"2 which invited public comment on improved positional accuracy of pipeline maps, and other pipeline attribute details. These details include pipe diameter (cuiTently an optional submission to the NPMS), operating pressure, pipe grade, percent of operating specified minimum yield strength, pipe coating, pipe material, and pipe join method, and decade of construction/installation. PHMSA proposed that gas transmission operators submit data at ± 50 feet accuracy for all segments which are in a Class 2, Class 3, or Class 4 area; within High Consequence Areas (HCA) or have one or more buildings intended for human occupancy; an identified site (See 49 CFR §192.903); a right-of-way for a designated interstate, freeway, expressway, or other principal four-lane arterial roadway, as defined in the Federal Highway Administration's "Highway Functional Classification Concepts," within the segment's potential impact radius. All other gas pipeline segments would be mapped to a positional accuracy of± 100 feet. As part of the process, PHMSA will review each additional data element to determine the appropriate security classification. PHMSA held a public meeting on this notice on November 18, 2015. The comment period ended on November 25, 2015. PHMSA published the Information Collection Notice on June 22, 2016.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence