NTSB Safety Recommendation P-15-007

NTSB safety recommendation P-15-007.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Work with the Federal Geographic Data Committee to identify and publish standards and specifications for geospatial data commonly used by gas transmission pipeline operators, and disseminate the standards and specifications to these operators and inspectors.

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 note that you do not share NPMS data with the federal community as a whole, nor do you include the data on distributed datasets, such as HSIP Gold, and you have not changed your security policy. To address this recommendation, you met with FGDC representatives and confirmed that the proposed positional accuracy standard of 50 feet for the majority of pipe segments is in line with FGDC standards, and also confirmed that your data are the same as FGDC standards. We further note that, although the data collected for the NPMS and the internal data used by operators are significantly different, you give operators a manual of NPMS technical standards and provide operators with one-on-one assistance when they prepare submissions to NPMS. We understand that you worked with FGDC to standardize other approaches, such as positional accuracy language and North American Datum (NAD) 83 versus NAD 27. You also standardized your datum to NAD 83 to match the FGDC standard, and have implemented all standards mentioned in the FGDC document, “Content Standard for Digital Geospatial Metadata.” We understand that the FGDC National Standard for Spatial Data Accuracy applies only to data that are collected in the field, and that you receive data from pipeline operators rather than collect it yourself. We note that you will follow the FGDC’s spatial standards if the FGDC embarks upon any data collection in the future. Because these actions satisfy the intent of Safety Recommendation P-15-7, 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 are aware (1) that you work on data standards and specifications with the gas transmission pipeline operators that are required to submit such information to the NPMS and (2) that the NPMS was converted to a modified version of Pipeline Open Data Standard in 2010. We are also aware that you provide substantial assistance to operators preparing their submissions. We note that your security policy requires that you individually vet each consumer of raw NPMS data and that you neither share NPMS data with the federal community as a whole, nor include it on distributed datasets. We are pleased to note that you will discuss with the Federal Geographic Data Committee (FGDC) about your plans for making the current NPMS data model and standards available, and we appreciate your intention to relay the outcome of this discussion in your next letter to us. Pending completion of the recommended action, Safety Recommendation P 15-7 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. By June 30, 2015, PHMSA will hold a discussion with the Federal Geographic Data Committee (FGDC) on making the current NPMS data model and standards available. PHMSA will report back to the NTSB on the outcome in its next comprehensive recommendations update submitted in the fall of 2015. PHMSA actively works with pipeline operators, required to submit to the NPMS, on the topic of data standards and specifications. In 2010, the NPMS was converted to a modified version of PODS (Pipeline Open Data Standard), the most widely used data model in the industry. Further, PHMSA provides a manual of NPMS technical standards to operators, as well as one-on-one assistance, when they are preparing their submission. Notwithstanding, PHMSA believes it is important to note that our security policy requires individually vetting each consumer of raw NPMS data; therefore, we do not share NPMS data with the federal community as a whole, nor is it included on distributed datasets such as HSIP Gold.

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. On May 12, 2015, PHMSA advised NTSB that it would meet with the Federal Geographic Data Committee (FGDC) no later than June 30, 2015, to discuss making the current NPMS model and standards available to operators and inspectors. PHMSA also advised NTSB that our security policy requires individually vetting each consumer of raw NPMS data. As such, PHMSA does not share NPMS data with the Federal community as a whole, nor does it include the data on distributed datasets such as HSJP Gold. PHMSA has not changed its security policy. On May 27, 2015, PHMSA met with representatives of FGDC and confirmed that the proposed positional accuracy standard of 50 feet for the majority of pipe segments is in line with FGDC standards. We also confirmed that PHMSA's datum3 is also the same as FGDC standards. While the data collected for the NPMS and the internal data used by operators are significantly different, PHMSA provides a manual of NPMS technical standards to operators, as well as one-on-one operator assistance when operators prepare submissions to NPMS. To meet the intent of the NTSB recommendation, PHMSA has worked with FGDC to standardize other approaches such as positional accuracy language and North American Datum (NAD) 83 vs NAD 27 datum. PHMSA has standardized its datum to NAD83 to match the FGDC standard, and has implemented all standards mentioned in the FGDC document, "Content Standard for Digital Geospatial Metadata." The FGDC National Standard for Spatial Data Accuracy applies only to data that is collected in the field. PHMSA currently does not collect its own data; the data is received from pipeline operators. PHMSA will follow the FGDC's spatial standards if it embarks upon any data collection in the future. PHMSA does not envision taking further action to close this recommendation.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence