NTSB Safety Recommendation P-15-020

NTSB safety recommendation P-15-020.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Identify all operational complications that limit the use of in-line inspection tools in piggable pipelines, develop methods to eliminate the operational complications, and require operators to use these methods to increase the use of in-line inspection tools.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

Overall Date Closed: 2020-01-23

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: 2020-01-23

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-06-06

Communication Type: NPRM Response

Communication Contents: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration (PHMSA) notice of proposed rulemaking (NPRM), Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines, published on April 8, 2016. This NPRM addresses issues raised in an August 25, 2011, advance notice of proposed rulemaking (ANPRM) regarding the revision of pipeline safety regulations applicable to the safety of gas transmission and gas gathering pipelines, particularly those involving integrity management (IM). PHMSA proposes to incorporate by reference the American Petroleum Institute In-line Inspection Systems Qualification Standard (API STD 1163); the National Association of Corrosion Engineers (NACE) In-line Inspection of Pipelines (SP0102-2010); and the American Society for Nondestructive Testing In-line Inspection Personnel Qualification and Certification (ANSI/ASNT ILI PQ 2010). These proposed actions address two recommendations from our January 27, 2015, study Integrity Management of Gas Transmission Pipelines in High Consequence Areas. The recommendations are as follows: Require that all natural gas transmission pipelines be capable of being in-line inspected by either reconfiguring the pipeline to accommodate in line inspection tools or by the use of new technology that permits the inspection of previously uninspectable pipelines; priority should be given to the highest risk transmission pipelines that considers age, internal pressure, pipe diameter, and class location. (Supersedes Safety Recommendation P-11-17, which is now classified “Closed?Superseded”) (P-15-18) Identify all operational complications that limit the use of in-line inspection tools in piggable pipelines, develop methods to eliminate the operational complications, and require operators to use these methods to increase the use of in-line inspection tools. (P-15-20) Response The NTSB understands that the PHMSA proposed actions are intended to address Safety Recommendations P-15-18 and P-15-20. It is not clear, however, if the proposed actions will require operators to modify previously uninspectable pipelines to accommodate ILI tools or alternatively, require operators to use new technologies to perform the inspections. Furthermore, it is not clear if PHMSA will establish any requirements to prioritize new ILIs based on pipeline age, operating pressure, or other relevant criteria. We urge PHMSA to ensure the regulations that result from this NPRM address all elements contained in Safety Recommendations P-15-18 and P-15-20.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: We note that you believe the intent of this recommendation will be met by incorporating, by reference, into your “Gas Transmission” NPRM the consensus industry standard NACE SP0102-2010 (formerly RP0102), In-Line Inspection of Pipelines, which outlines a process that pipeline operators can use to plan, organize, and execute ILI projects. As we stated in our June 6, 2016, comments to the NPRM, “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines,” it is unclear whether the proposed actions will require operators to modify previously uninspectable pipelines to accommodate ILI tools or, alternatively, whether they would require operators to use new technologies to perform the inspections. Furthermore, it is unclear whether you will establish any requirements to prioritize new ILIs based on pipeline age, operating pressure, or other relevant criteria. Pending the completion of these efforts, and with the understanding they will lead to the eventual use of ILI tools on all gas transmission lines, Safety Recommendation P-15-20 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-01-23

Communication Type: Official Correspondence

Communication Contents: On February 21, 2018, we told you that this recommendation could be satisfied if you incorporated by reference the consensus industry standard, National Association of Corrosion Engineers (NACE) SP0102-2010 (formerly RP0102), “In-Line Inspection of Pipelines,” into your April 8, 2016, NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines.” On October 1, 2019, you published a new rule, “Pipeline Safety: Safety of Gas Transmission Pipeline: MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments,” that incorporates by reference NACE SP0102, section 7, making it a requirement. Accordingly, Safety Recommendation P-15-20 is classified CLOSED--ACCEPTABLE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: We agree that incorporating by reference the consensus industry standard National Association of Corrosion Engineers (NACE) SP0102-2010 (formerly RP0102), “In-Line Inspection of Pipelines,” into your April 8, 2016, NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” addresses this recommendation. We note that, as with Safety Recommendation P-15-18, although you initially expected to publish the final rule by the end of 2017, publication has been delayed due to the governmentwide moratorium on new regulations and required review of all proposed regulations. Pending publication of a final rule that includes NACE SP0102-2010 by reference, Safety Recommendation P-15-20 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 agree that operational complications that limit the use of in-line inspection tools are already well understood, and we are aware that these issues are addressed in the industry standard, NACE RP0102-2010. We also recognize that the mandatory elimination of some operational complications would be tantamount to replacing the pipeline (which is seldom a practical or cost-effective solution); accordingly, we support your plan to incorporate by reference the NACE standard into the pending gas transmission safety rulemaking. Pending publication of a final rule that addresses the issue, Safety Recommendation P-15-20 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 proposes closure of this recommendation. On October 1, 2019, PHMSA published the "Safety of Gas Transmission Pipelines: MAOP Reconfirmation, Expansion of Assessment Requirements, and Other Related Amendments" final rule, in which PHMSA incorporated by reference the industry standard "In-line Inspection of Pipelines, NACE SP0102-2010" (formerly RP0102) under§ 192.7. PHMSA notes that NTSB agreed that incorporating this standard by reference, as proposed in PHMSA's April 8, 2016, NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines," would address this recommendation.

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 notes that the NTSB agreed that incorporating by reference the industry standard "In-line Inspection of Pipelines, NACE SP0102-2010 (formerly RP0102)," which PHMSA proposed in the April 8, 2016, NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines," would address this recommendation. As discussed in our response to Recommendation P-11-14, PHMSA separated the Gas Rule into three rulemaking actions. PHMSA plans to address this recommendation in the "Pipeline Safety: Safety of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion of Assessment Requirements and Other Related Amendments" final rule, which PHMSA plans to publish in August 2019, according to the DOT' s March 2019 Significant Rulemakings Report.

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 notes that the NTSB had some questions about whether PHMSA's proposal to incorporate by reference the consensus industry standard NACE SP0102-2010 would require operators to modify previously difficult-to-inspect pipelines to accommodate ILI tools or use new technologies to perform the inspections. The standard, "In-Line Inspection of Pipelines" (formerly RP0102), outlines a process for pipeline operators to plan, organize, and execute ILI projects but does not require operators to modify existing pipelines. However, the NPRM proposed to require that each new and replaced line pipe or other component must be able to accommodate an ILI device (see response to P-15-18). The NPRM has a detailed set of requirements for pipeline assessments and repairs based on pipeline age, operating pressure, and other relevant criteria, which would lead to the highest risk pipelines being addressed first. PHMSA held Gas Pipeline Advisory Committee (GPAC) meetings on the rule on January 12, 2017, and on June 6-7, 2017. PHMSA plans to hold additional meetings in December 2017 to continue discussing the proposed rule. The final rule was initially expected to publish by the end of2017. Due to the continued process of gathering GPAC recommendations, we are expecting delays and currently assessing impacts. Like many other issues before us, this is part of an ongoing regulatory review pursuant to the executive order issued by the President.

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. Operational complications that limit the use of in-line inspection tools are already well understood. These considerations are addressed in consensus industry standard NACE RP0102-2010. The mandatory elimination of some operational complications would be tantamount to replacing the pipeline, which is seldom a practical or cost-effective solution. PHMSA plans to incorporate by reference consensus industry standard NACE RP0102-2010 into the gas transmission safety rulemaking. PHMSA believes this will meet the intent of this recommendation. The NPRM is currently under OMB review, and we expect to publish it in the summer of 2015.

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 believes it will meet the intent of this recommendation by incorporating by reference into its Gas Transmission NPRM the consensus industry standard NACE SP0102-2010 (formerly RP0102), "In-Line Inspection of Pipelines." NACE SP0102-2010 outlines a process by which pipeline operators can plan, organize, and execute in-line inspection projects.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence