NTSB Safety Recommendation P-15-008

NTSB safety recommendation P-15-008.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Work with the appropriate federal, state, and local agencies to develop a national repository of geospatial data resources for the process for high consequence area identification, and publicize the availability of the repository.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

Overall Date Closed: 2018-02-21

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: 2018-02-21

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: We acknowledge that you have worked with FGDC and note that the FGDC does not recommend developing a new repository, as one already exists that includes five HCA datasets (three of which are available to the public and two of which are available only to pipeline operators who request them through the NPMS website). We understand that you purchased an updated ecological unusually sensitive area dataset that will be delivered soon, and that you will develop an additional water-based ecological unusually sensitive area dataset in response to the SAFE PIPES Act 2016 by the end of 2016. Further, the current security policy for unusually sensitive area datasets will remain as is, and all datasets will be available to pipeline operators who request them through the NPMS website. Pending completion of these efforts to address Safety Recommendation P-15-8, it is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: In previous letters about this recommendation, you described your work with the Federal Geographic Data Committee (FGDC)—whose membership includes the appropriate federal, state, and local agencies—to evaluate the feasibility of a national geospatial data repository and to standardize other approaches. The FGDC advised you against developing a new repository because a repository already exists that includes five HCA datasets, three of which are available to the public and two of which are available only to pipeline operators. We note that you have also taken steps to improve the current NPMS datasets, including standardizing your data to match the FGDC standard, and you have implemented all the standards in the FGDC’s “Content Standard for Digital Geospatial Metadata.” Finally, we note that you recently purchased an updated ecological unusually sensitive area dataset that you are currently using to refresh the NPMS data. These actions satisfy Safety Recommendation P 15 8, which 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, at present, certain geospatial data is available to assist in HCA identification, that the NPMS website contains data downloads for populated area HCAs and commercially navigable waterway HCAs, based on US Census Bureau and Bureau of Transportation Statistics data, and that this information can be released to the industry. We also understand that you are reviewing available data from the Fish and Wildlife Service and the Environmental Protection Agency for potential inclusion in updates to the ecological and drinking water HCA datasets, and that class locations and gas transmission HCAs are part of the NPMS Information Collection initiative (P-15-4 and P-15-5, discussed above) and will be required from gas transmission operators when the information collection is complete. We are aware that HCA identification is dynamic and that pipeline operators spend a significant amount of time and resources to conduct right-of-way inspections, class location surveys, and continuing surveillance activities, to identify and address changes around their pipeline systems. We note that, during the implementation of the gas transmission IM regulations, you worked with state fire marshals to coordinate identification of identified sites. We understand that, because ecological and drinking water HCAs have always been designated as sensitive and are protected by your data security policy from dissemination to anyone other than pipeline operators and government officials, any requestors of these HCAs must be individually vetted. We further understand that PHMSA redesigned the NPMS website in September 2014 to more efficiently serve stakeholders’ needs and that you also provide information on available HCA data through NPMS outreach efforts. We appreciate that you plan to evaluate the feasibility of the requested repository, publish the results of this evaluation and your evaluation of additional datasets that can aid in HCA identification, and provide us with an update by the end of March 2016. Pending our review of these evaluations and completion of the recommended action, Safety Recommendation P-15-8 is classified OPEN—ACCEPTABLE RESPONSE.

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: PHMSA proposes closure of this recommendation. To meet the intent of the NTSB recommendation, PHMSA has worked with the Federal Geographic Data Committee (FGDC), whose membership includes the appropriate Federal, state, and local agencies, to evaluate the feasibility of a national geospatial data repository, and to standardize other approaches with the FGDC. The FGDC advised PHMSA that it does not recommend developing a new repository. A repository exists that includes five high consequence area (HCA) datasets, of which three are available to the public, and two are available only to pipeline operators, who request them through the NPMS web site. PHMSA took steps to improve the current NPMS datasets so that our current geospatial resources can more fully capture HCA identification. PHMSA standardized its datum to match the FGDC standard, and has implemented all standards mentioned in the FGDC's "Content Standard for Digital Geospatial Metadata." PHMSA also purchased an updated Ecological Unusually Sensitive Area dataset for use in the NPMS, to be delivered in the first quarter ofFY18. PHMSA believes this dataset will meet the intent of the recommendation, and will have the dataset update completed by December 31, 2017. PHMSA notes that the NTSB supported this action to address this recommendation as a response to our last update.

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 in part. PHMSA will evaluate the feasibility of such a repository and publish the results of its evaluation. PHMSA will evaluate additional datasets that can aid in HCA identification and will provide an update to the NTSB by March 31, 2016. Currently, certain geospatial data is available to assist in HCA identification. The NPMS website contains data downloads for populated area HCAs and commercially navigable waterway HCAs. These layers are based on U.S. Census Bureau and Bureau of Transportation Statistics data, and are publicly releasable. PHMSA is also reviewing available data from the Fish and Wildlife Service and Environmental Protection Agency for potential inclusion in updates to the ecological and drinking water HCA datasets. Class locations and gas transmission HCAs are part of the NPMS Information Collection initiative (see P-15-4 and P-15-5) and would be required from gas transmission operators when the Information Collection is final. HCA identification is very dynamic, and currently, pipeline operators spend a significant amount of time and resources through Right of Way inspections, class location surveys, and continuing surveillance activities, to identify and address changes around their pipeline systems. During the implementation of the gas transmission IM regulations, PHMSA worked with State Fire Marshals to coordinate identification of identified sites. Ecological and drinking water HCAs have always been designated as sensitive and are protected by PHMSA’s data security policy from dissemination to anyone other than pipeline operators and government officials. Any requestors of these HCAs must be individually vetted. PHMSA redesigned the NPMS website in September 2014 to more efficiently serve its stakeholders’ needs, including making the pages describing available HCA data more user-friendly. PHMSA provides information on available HCA data through NPMS outreach efforts.

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: Per our response to Recommendation P-15-7, PHMSA has worked with FGDC, whose membership includes the appropriate Federal, state, and local agencies, to evaluate the feasibility of a national geospatial data repository. The FGDC advised PHMSA that it does not recommend developing a new repository. A repository already exists that includes five HCA datasets, of which three are available to the public, and two are available only to pipeline operators who request them through the NPMS web site. In addition, PHMSA purchased an updated Ecological Unusually Sensitive Area dataset, to be delivered by the end ofFY16. By 12/3 1/2016, PHMSA will complete development of an additional water based Ecological Unusually Sensitive Area dataset in response to the SAFE PIPES Act 2016. The current security policy for Unusually Sensitive Area datasets will remain as is; all datasets will be available to pipeline operators who request them through the NPMS website.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence