NTSB Safety Recommendation P-15-017

NTSB safety recommendation P-15-017.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Develop a program to use the data collected in response to Safety Recommendations P-15-15 and P-15-16 to evaluate the relationship between incident occurrences and (1) inappropriate elimination of threats, (2) interactive threats, and (3) risk assessment approaches used by the gas transmission pipeline operators. Disseminate the results of your evaluation to the pipeline industry, inspectors, and the public annually.

Priority: CLASS II

Overall Status: Open - Acceptable Response

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

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: Open - Acceptable Response

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: We note that you will evaluate the analysis method to include potential changes to your investigation and data systems, and will communicate your findings back to us within 6 months of completing the actions described under Safety Recommendations P-15-15 and -16. Pending your further communication and our review of how you plan to use the data collected in response to P-15-15 and -16, Safety Recommendation P-15-17 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2022-05-02

Communication Type: Official Correspondence

Communication Contents: We note that you will evaluate the method for conducting this analysis, including potential changes to your investigation and data systems, and plan to communicate the results of your evaluation to the pipeline industry, inspectors, and the public. Pending the development of a program to use the data collected in response to Safety Recommendations P-15-15 and -16, Safety Recommendation P-15-17 remains classified OPEN-- ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-01-23

Communication Type: Official Correspondence

Communication Contents: We note that you will evaluate your analysis methods and will inform us of your findings within 12 months of completing the actions that satisfy both Safety Recommendations P-15-15 and -16. Pending our review of how you plan to use the data collected in response to Safety Recommendations P-15-15 and 16, Safety Recommendation P-15-17 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 will evaluate the analysis method used to consider changing your investigation and data systems, and you will tell us your findings within 6 months of completing the actions that satisfy Safety Recommendations P-15-15 and -16. Pending our review of how you plan to use the data collected in response to Safety Recommendations P-15-15 and 16, Safety Recommendation P-15-17 remains 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 note your position that the data collection approach requested in Safety Recommendations P-15-15 and -16 would not constitute an effective way to evaluate and study the relationship between incident occurrences and the operator’s performance, with respect to the operator’s threat identification and risk assessment approached, and that the best way to perform this evaluation is with detailed data analysis, during incident investigations, by its subject matter experts. We are aware that your failure investigation reports are available to the public at http://phmsa.dot.gov/pipeline/library/failure-reports. We note that, instead, you intend to address this issue by evaluating the method for conducting the analysis, that you may revise your investigation and data systems as a result, and that you intend to report your findings by July 31, 2016. Pending the outcome of this effort as scheduled, Safety Recommendation P-15-17 is classified OPEN—ACCEPTABLE RESPONSE.

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 NTSB's acknowledgment that using the data collections in Recommendations P-15-15 and P-15-16 may be an ineffective approach to evaluating the relationship between incident occurrences and the operator's performance, with respect to the operator's threat identification and risk assessment approach. We also appreciate NTSB's classification of this recommendation as "Open-Acceptable Response" based on PHMSA's proposal to evaluate the method for conducting this analysis, including potential changes to our investigation and data systems. PHMSA will communicate our findings to NTSB within 12 months of completing the actions described under P-15-15 and P-15-16.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2022-01-14

Communication Type: Official Correspondence

Communication Contents: -From Tristan H. Brown, Deputy Administrator: PHMSA will evaluate the method for conducting this analysis, including potential changes to its investigation and data systems, and plans to communicate its implementation plan to NTSB by December 2022.

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 will evaluate the method for conducting this analysis, including potential changes to our investigation and data systems. PHMSA will then communicate our findings to the NTSB within 12 months of completing the actions described under P-15-15 and P-15-16.

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 will evaluate the method for conducting the analysis to include potential changes to our investigation and data systems and communicate our findings to the NTSB within six months of completing the actions described under P-15-15 and P-15-16.

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 method for conducting the analysis to include potential changes to our investigation and data systems and communicate our findings to the NTSB by July 31, 2016. PHMSA does not believe the data collection approach suggested in P-15-15 and P-15-16 would be an effective way to evaluate and study the relationship between incident occurrences and the operator’s performance, with respect to the operator’s threat identification and risk assessment approached. Such an assessment, to be effective, would require too much case-specific and operator-specific information to collect on a standardized form. PHMSA believes that the best way to perform this evaluation is with detailed data analysis, during incident investigations, by our subject matter experts. PHMSA investigates and prepares failure investigation reports, and they are available to the public online at: http://phmsa.dot.gov/pipeline/library/failure-reports.

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 will evaluate the method for conducting the analysis to include potential changes to our investigation and data systems and communicate our findings to NTSB within six months of completing the actions described under P-15-15 and P-15-16.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence