NTSB Safety Recommendation P-15-006

NTSB safety recommendation P-15-006.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Assess the limitations associated with the current process for identifying high consequence areas, and disseminate the results of your assessment to the pipeline industry, inspectors, and the public.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

Overall Date Closed: 2017-03-01

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: 2017-03-01

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: We note that you continue to address this issue and plan to publish the results in an AB and in updated inspection protocol guidance, as needed, by the end of 2016. Pending completion of these efforts, Safety Recommendation P-15-6 is classified OPEN—ACCEPTABLE REPSONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2017-03-01

Communication Type: Official Correspondence

Communication Contents: We are pleased that you assessed the process for identifying HCAs, as requested, and that, on December 13, 2016, you published an advisory bulletin (ADB), ADB-2016-07, High Consequence Area Identification Methods, to disseminate the assessment results and address this recommendation. Because these actions satisfy the intent of Safety Recommendation P-15-6, 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 note your position that proper identification and periodic verification of an HCA relies on both (1) pipeline-specific information that includes the accurate location of the centerline of the pipeline, the nominal diameter of the pipeline, and the pipeline segment’s maximum allowable operating pressure and (2) all the structures and their usage (including occupancy) located along the pipeline. We understand that these topics are addressed in current IM protocol inspection guidance, that you plan to perform an assessment of the impact regarding these two key types of information needed for identifying HCAs, and that you plan to publish the results in an advisory bulletin and in updated inspection protocol guidance, as needed, by May 2016. Pending completion of these efforts as scheduled, Safety Recommendation P-15-6 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2017-01-06

Communication Type: Official Correspondence

Communication Contents: -From Marie Therese Dominguez, Administrator: I am writing to propose closure of the National Transportation Safety Board (NTSB) Recommendation P-15-6. This letter provides an update of the actions taken to address this recommendation. We take our responsibility to address all recommendations seriously and will continue to work aggressively to close all open recommendations. PHMSA performed an assessment of the process for identifying High Consequence Areas (HCAs) and on December 13,2016, PHMSA published an advisory bulletin, ADB-2016-07, High Consequence Area Identification Methods (ADB) to disseminate the assessment results and address this recommendation. The ADB is available online at https://www.federalregister.gov/documents/2016/12/13/2016-29880/pipeline-safetyhigh-consequence-area-identification-methods-for-gas-transmission-pipelines. The ADB reminds gas transmission pipeline operators of certain previously issued guidance, and provides operators with additional guidance for the identification of HCAs along pipeline right-of-ways. This ADB provides suggestions for accurately mapping and integrating HCA data, documenting how mapping systems are used, periodically verifying and updating their mapping systems, using buffer zones (tolerances) to provide additional protection around the calculated potential impact radius along their pipelines, and ensuring the accuracy of class locations. The ADB emphasizes that HCA identification relies on pipeline-specific information regarding the location, size, and operating characteristics of the line, as well as the identification of structures, specified sites, and the intended usage of these specified sites along the pipeline right-of-way. PHMSA will continue to work with your office in the future as we continue our efforts to ensure the safe, reliable, and environmentally sound operation of the Nation's pipeline transportation system. We appreciate your consideration for closing Recommendation P-15-6.

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 has noted that proper identification and periodic verification of an HCA relies on two key types of information: (1) pipeline-specific information that includes the accurate location of the centerline of the pipeline, the nominal diameter of the pipeline, and the pipeline segment’s MAOP; and (2) all the structures and their usage (including occupancy) located along the pipeline. These topics are addressed in current IM protocol inspection guidance. PHMSA will perform an assessment of the impact regarding these two key types of information needed for identifying HCAs, and will publish the results in an advisory bulletin and in updated inspection protocol guidance, as needed, by May 2016.

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 has noted that proper identification and periodic verification of an HCA relies on two key types of information: (I) pipeline-specific information that includes the accurate location of the centerline of the pipeline, the nominal diameter of the pipeline, and the pipeline segment's maximum allowable operating pressure; and (2) all the structures and their usage (including occupancy) located along the pipeline. PHMSA is performing an assessment of these two key types of inf01mation needed for identifying HCAs. We are on schedule to publish an advisory bulletin, and, if needed, updated inspection protocol guidance, in November 2016.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence