NTSB Safety Recommendation P-15-009

NTSB safety recommendation P-15-009.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Establish minimum criteria for eliminating threats, and provide guidance to gas transmission pipeline operators for documenting their rationale for all eliminated threats.

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 note that, as part of your NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” published on April 8, 2016, you proposed enhancing and expanding minimum requirements to identify threats, including (but not limited to) specific requirements to address standards for minimum data sets used, data validation, data integration, subject-matter-expert bias, and interacting threat, and you believe that these improved requirements may address the root cause of previous threat identification shortcomings. Further, you plan to issue an AB by the end of 2016 that will provide guidance to gas transmission pipeline operators documenting their rationale for all eliminated threats. This will establish minimum criteria for eliminating threats. Pending the completion of these efforts and our review of the final rules, Safety Recommendation P-15-9 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: We note that, on March 16, 2017, you published Advisory Bulletin (AB) 2017-01, “Deactivation of Threats,” which helps gas transmission pipeline operators identify threats and establishes minimum criteria for deactivating them. Publishing the AB satisfies Safety Recommendation P-15-9, 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 as part of your notice of proposed rulemaking (NPRM) Pipeline Safety: Safety of Gas Transmission Pipelines, which is scheduled for publication this summer, you plan to include specific requirements for performing threat identification that will address standards for minimum data sets used, data validation, data integration, subject matter expert bias, and interacting threats. We note your belief that the proposed improved requirements may address the root cause of previous shortcomings in threat identification and will therefore address this recommendation. We further note that, in March 2015, you completed research, titled Repair/Replacement Considerations for Pre-Regulation Pipe, and that, when complete, this project will provide guidelines for implementing and executing a pre-regulation pipeline repair/replace program. We support your plan to tailor the guidelines to natural gas transmission pipelines, natural gas distribution pipelines, and hazardous liquid pipelines. Pending completion of the above-described actions by the end of May 2016, as scheduled, Safety Recommendation P-15-9 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 requests closure of this recommendation. On March 16, 2017, PHMSA issued Advisory Bulletin 2017-01, Deactivation of Threats (82 FR 14106, https://www.federalregister.gov/documents/2017/03/16/2017-05262/pipeline-safetydeactivation-of-threats ), to provide guidance to gas transmission pipeline operators on threat identification and established minimum criteria for the deactivation of threats to the integrity of a pipeline. The advisory bulletin provides guidance to gas transmission pipeline operators for documenting their rationale of any analyses, justifications, determinations, and decisions made relating to threat deactivation. The advisory bulletin also provides further guidance on when the elimination of threats to the integrity of a pipeline may be discounted and eliminated from consideration in the performance of integrity assessments.

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 perform an evaluation to establish criteria for eliminating threats and publish the results in an advisory bulletin and updated inspection protocol guidance, as needed, by May 31, 2016. PHMSA, as part of its in-process NPRM on gas transmission safety, will enhance and expand minimum requirements for performing threat identification to include specific requirements to address standards for minimum data sets used, data validation, data integration, subject matter expert bias, and interacting threats. PHMSA believes that these improved requirements may address the root cause of previous shortcomings in threat identification and address this recommendation. This NPRM is currently under OMB review, and we expect to publish in the summer of 2015. Further, in March 2015, PHMSA completed a research project titled “Repair/Replacement Considerations for Pre-Regulation Pipe.” This project will inform guidelines for implementing and executing a pre-regulation pipeline repair/replace program. The guidelines will be tailored for natural gas transmission pipelines, natural gas distribution pipelines, and hazardous liquid pipelines.

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: As part of the NPRM on gas transmission safety published on April 8, 2016, PHMSA proposed to enhance and expand minimum requirements for performing threat identification, including, but not limited to. specific requirements to address standards for minimum data sets used, data validation, data integration, subject matter expert bias, and interacting threats. PHMSA believes that these improved requirements may address the root cause of previous shortcomings in threat identification and address this recommendation. To further support the NTSB recommendation, PHMSA plans to issue an Advisory Bulletin by December 1, 2016, to provide guidance to gas transmission pipeline operators for documenting their rationale for all eliminated threats and establish minimum criteria for eliminating threats.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence