NTSB Safety Recommendation P-15-022

NTSB safety recommendation P-15-022.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Develop and implement a plan for all segments of the pipeline industry to improve data integration for integrity management through the use of geographic information systems.

Priority: CLASS II

Overall Status: Closed - Acceptable Alternate Action

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

Overall Date Closed: 2020-07-16

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 Alternate Action

Addressee Date Closed: 2020-07-16

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). This NPRM addresses several IM topics, including: • revising IM repair criteria for pipeline segments in high consequence areas (HCA) • explicitly including functional requirements related to the nature and application of risk models currently invoked by reference to industry standards • specifying requirements for collecting, validating, and integrating pipeline data models currently invoked by reference to industry standards • strengthening requirements for applying knowledge gained through the IM program models currently invoked by reference to industry standards • strengthening requirements on the selection and use of direct assessment methods models by incorporating recently issued industry standards by reference Topics addressed in this proposed rule that are not related to IM requirements include: • proposing a new “moderate consequence area” definition • adding requirements for monitoring gas quality and mitigating internal corrosion • adding requirements for external corrosion management programs including above ground surveys, close interval surveys, and electrical interference surveys • adding requirements for management of change (MOC) currently invoked by reference to the industry standard, American Society of Mechanical Engineers (ASME) B31.8S, Managing System Integrity of Gas Pipelines Section 11 • establishing repair criteria for pipeline segments located in areas not in an HCA • adding requirements for verification of maximum allowable operating pressure (MAOP) and verification of pipeline material for certain on-shore, steel, and gas transmission pipelines • modifying the regulation of on-shore gas gathering lines • adding a new definition for “on-shore production facility/operation” • revising a definition for “gathering lines” • extending certain Title 49 Code of Federal Regulations (CFR) Part 192 regulatory requirements to Type A lines in Class 1 locations for lines 8 inches diameter or greater. This NPRM also contains six other topics that were not included in the 2011 ANPRM: • requiring inspections by on-shore pipeline operators of areas affected by an extreme weather event such as a hurricane or flood, a landslide, an earthquake, a natural disaster, or other similar event • revising the regulations to allow extension of the IM 7-year reassessment interval • adding a requirement to report each incident of a pipeline operating pressure that exceeds the MAOP plus the margin allowed for operation of pressure-limiting or control devices • adding requirements to consider seismicity of the area in identifying and evaluating all potential threats • adding regulations to require safety features on launchers and receivers for in-line inspection (ILI), scraper, and sphere facilities • incorporating consensus standards into the regulations for assessing the physical condition of in-service pipelines using ILI, internal corrosion direct assessment, and stress corrosion cracking direct assessment We acknowledge that PHMSA is addressing certain recommendations issued by the NTSB related to the September 9, 2010, San Bruno, California, and December 11, 2012, Sissonville, West Virginia, accident investigations as applicable to the above listed items. The proposed rule also addresses several of the recommendations from our January 27, 2015, study Integrity Management of Gas Transmission Pipelines in High Consequence Areas, including P 15-18 (IM–ILI capability), P-15-20 (IM–ILI tools), P-15-21 (IM–direct assessments), and P 15-22 (IM–data integration).

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2016-12-05

Communication Type: Official Correspondence

Communication Contents: In our June 6, 2016, comments on your NPRM, “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines,” we acknowledged that PHMSA was addressing certain safety recommendations we issued, including P-15-22. We note your belief that the proposed regulatory amendments would enhance and expand minimum requirements for risk assessment and threat identification to include specific requirements addressing standards for minimum data sets used, data validation, data integration (including identification and analysis of spatial relationships), and subject-matter-expert bias. You further believe that these improved requirements will address certain root causes of previous shortcomings in current data integration by improving operator understanding of data integration requirements, which will ultimately address this recommendation. You write that you will take action to understand the effect of these new regulations on GIS implementation, including conducting a cost-benefit assessment. Accordingly, pending our review of the final rules addressing this issue, Safety Recommendation P-15-22 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-07-16

Communication Type: Official Correspondence

Communication Contents: After initially planning to address this recommendation in the final rule, “Safety of Gas Transmission Pipelines,” on April 1, 2019, you asked us to consider alternate actions to address this recommendation. Your alternate approach includes synchronizing the reporting period for annual reports and NPMS reports, which will allow you to compare data extracted from an operator’s system on the same date. Additionally, you now require operators to use the same operator identification number to report the same pipeline segment on both the annual report and the NPMS submission. Finally, because you can now compare the annual report and NPMS data, you can implement quality-control processes to identify inaccurate data, which the operator is then required to correct, resulting in a more complete and accurate NPMS dataset. In our January 23, 2020, letter, we agreed that your proposed three-tiered implementation approach will meet the intent of this recommendation once it is approved by OMB, which occurred on January 22, 2020. We note that the NPMS information collection will now require, among other things, that operators integrate hazardous liquid segment “could affect HCA” analysis results and submit new pipeline attributes critical to integrity management with their pipeline geographic information system data. We believe these actions constitute an alternative method of addressing Safety Recommendation P-15-22; accordingly, it is classified CLOSED-- ACCEPTABLE ALTERNATE ACTION.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-01-23

Communication Type: Official Correspondence

Communication Contents: In our June 6, 2016, comments about your NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” we said that Safety Recommendation P-15-22 would be satisfied if the proposed revisions were included in a final rule; however, in your most recent response, you propose a three-tiered implementation approach that you believe is an alternative way to meet the recommendation’s intended safety goal. This approach includes synchronizing the reporting period for annual reports and NPMS reports, which will allow you to compare data extracted from an operator’s system on the same date. Additionally, you now require operators to use the same operator identification number to report the same pipeline segment on both the annual report and the NPMS submission. Finally, because you can now compare the annual report and NPMS data, you can implement quality-control processes to identify inaccurate data, which the operator is then required to correct, resulting in a more complete and accurate NPMS dataset. We agree that your proposed approach will meet the intent of this recommendation, and we understand that you are finalizing a revised 30-day NPMS information collection notice for Office of Management and Budget (OMB) approval. Pending OMB approval and our review of the final notice, Safety Recommendation P-15-22 is classified OPEN--ACCEPTABLE ALTERNATE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2018-02-21

Communication Type: Official Correspondence

Communication Contents: In our June 6, 2016, comments about your NPRM, “Pipeline Safety: Safety of Gas Transmission Pipelines,” we said that if the proposed revisions were included in a final rule, Safety Recommendation P-15-22 would be satisfied. We note that you also plan to determine if additional GIS requirements are necessary to satisfy this recommendation. Although you initially expected to publish the final rule by the end of 2017, publication is delayed because of the executive order imposing a governmentwide moratorium on new regulations and requiring a review of all pending regulations. Pending publication of a final rule that satisfies Safety Recommendation P 15 22, it 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 that, as part of your pending rulemaking on gas transmission safety, you plan to enhance and expand minimum requirements for performing risk assessment and threat identification to include specific requirements to address standards for minimum data sets used, data validation, data integration (including identification and analysis of spatial relationships), and subject matter expert bias. We further note that you believe these improved requirements will address the root cause of previous shortcomings in data integration by improving operator understanding of data integration requirements. We understand that you plan to conduct a cost benefit analysis and take other action to understand the effect of the new regulations on the implementation of GIS before initiating rulemaking requiring this technology. Pending the outcome of these actions, Safety Recommendation P 15-22 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2020-04-20

Communication Type: Official Correspondence

Communication Contents: -From Howard R. Elliott, Administrator: PHMSA proposes closure of this recommendation. As discussed in PHMSA’s response to P-15-04, on January 22, 2020, OMB approved the NPMS information collection for a three-year period. The NPMS information collection will now require, among other things, that operators: • Integrate hazardous liquid segment “could affect HCA” analysis results; and • Submit new pipeline attributes critical to integrity management with their pipeline GIS data. PHMSA is committed to continuously help improve the safety of our nation’s pipeline system. Towards that end, we take our responsibility to address all NTSB recommendations seriously. Thank you for your consideration regarding the closure of Recommendations P-15-04, P-15-10, P-15-12, P-15-13, P-15-21 and P-15-22. We look forward to a favorable 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 proposed an alternative approach for this recommendation on April 1, 2019, and looks forward to NTSB's response.

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 proposes that the NTSB consider alternative actions to address this recommendation. PHMSA originally stated that we would address this recommendation in the "Safety of Gas Transmission Pipelines" final rule via a proposal to enhance and expand minimum requirements for performing risk assessments and threat identification. This proposal was intended to include specific requirements to address standards for minimum data sets used, data validation, data integration (including identification and analysis of spatial relationships), and subject matter expert bias. However, PHMSA reexamined its approach and now believes that the safety intent of this recommendation can be expedited through other means. PHMSA is proposing the following three-tiered implementation approach that we believe meets the recommendation's intended safety goal: • PHMSA has taken several actions to improve IM data integration within the National Pipeline Mapping System (NPMS) and other PHMSA systems. These include synchronizing the reporting period of annual reports and NPMS reports, thereby allowing PHMSA to compare data extracted from an operator's system on the same date, instead of comparing by different dates before the synchronization took place. Additionally, operators are now required to use the same Operator ID number to report the same asset (pipeline segment) on both the annual report and the NPMS submission. Being able to compare the annual report and NPMS data has also allowed PHMSA to implement quality control processes to identify inaccurate data. When inaccurate data is found, NPMS staff require that the operator correct it, resulting in a more complete and accurate NPMS dataset. • PHMSA is facilitating the Voluntary Information-sharing System (VIS) Working Group's (WG) development and submission of a voluntary information-sharing recommendation report to the Secretary of Transportation. • PHMSA will publish a revised 30-day NPMS Information Collection Notice, which is currently being prepared for submittal to OMB for approval. PHMSA believes these actions support the provision of additional data to pipeline operators, thereby improving IM and data integration through the NPMS. The proposed additional pipeline attributes will be used to improve pipeline safety across the pipeline industry. Additionally, the VIS WG report recommendations have the potential to align with SMS principles, including an industry-wide process. PHMSA completed the actions to improve IM data integration within NPMS and other systems. PHMSA plans to submit the VIS WG's recommendation report to the Secretary of Transportation by May 2019. PHMSA anticipates finalizing a revised 3 0-day NPMS Information Collection Notice for OMB approval by December 2019.

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 appreciates NTSB' s comments on the Gas Transmission NPRM expressing that they "believe that adding specificity, as proposed in this NPRM, is a favorable addition to IM analysis requirements. [NTSB] further concur[ s] that expanding pipeline records requirements is a significant improvement in the management of pipelines through their service lifecycle." PHMSA's NPRM titled "Pipeline Safety: Safety of Gas Transmission Pipelines" (81 FR 20721 ), published on April 8, 2016, (https://www.federalregister.gov/documents/2016/04/08/2016-06382/pipeline-safetysafety-of-gas-transmission-and-gathering-pipelines), proposed to enhance and expand minimum requirements for performing risk assessments and threat identification to include specific requirements to address standards for minimum data sets used, data validation, data integration (including identification and analysis of spatial relationships), and subject matter expert bias. PHMSA believes that these expanded requirements will improve operator understanding of data integration requirements and will address this recommendation. PHMSA proposes to understand any effect of these new data integration requirements on operators' GIS implementation to determine if additional GIS requirements are necessary to meet this recommendation. 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 of 2017. Due to the continued process of gathering GP AC 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. In addition, PHMSA notes that pipeline operators (except for operators of distribution and gathering pipelines) are currently required to submit geospatial data to the National Pipeline Mapping System (NPMS) program. PHMSA has published Federal Register notices, as described in our response to Recommendation P-15-4, to invite public comment on possible revisions to the NPMS Information Collection. The information collection proposed additional geospatial information attributes that operators would then be able to use for IM risk management. On August 27, 2015, PHMSA issued a second 60-day notice. Comments were received and analyzed. A 30- day notice was published June 22, 2016. 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 in part. PHMSA, as part of its in-process rulemaking on gas transmission safety, plans to enhance and expand minimum requirements for performing risk assessment and threat identification to include specific requirements to address standards for minimum data sets used, data validation, data integration (including identification and analysis of spatial relationships), and subject matter expert bias. PHMSA believes that these improved requirements will address the root cause of previous shortcomings in data integration, by improving operator understanding of data integration requirements, and would address this recommendation. The NPRM is currently under OMB review, and we expect to publish it in the summer of 2015. PHMSA proposes to understand the effect of the new regulations on the implementation of GIS, before embarking on the regulatory process, including a cost-benefit assessment, to consider making GIS mandatory.

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: The Gas Transmission NPRM published on April 8, 2016, would enhance and expand minimum requirements for performing risk assessment and threat identification to include specific requirements to address standards for minimum data sets used, data validation, data integration (including identification and analysis of spatial relationships), and subject matter expert bias. PHMSA believes that these improved requirements will address certain root causes of previous shortcomings in current data integration, by improving operator understanding of data integration requirements, and will address this recommendation. PHMSA will take action to understand the effect of these new regulations on GIS implementation, including a cost-benefit assessment.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Type: Official Correspondence