NTSB Safety Recommendation P-15-027

NTSB safety recommendation P-15-027.

TO THE NATIONAL ASSOCIATION OF PIPELINE SAFETY REPRESENTATIVES: Work with the Pipeline and Hazardous Materials Safety Administration to develop and implement a program to formalize, publicize, and facilitate increased state-to-state coordination in integrity management inspections.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

Overall Date Closed: 2017-02-22

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: National Association of Pipeline Safety Representatives

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2017-02-22

Addressee Acronym: NAPSR

Addressee Organization Type: A-Associations

Communication Date: 2016-12-31

Communication Type: Official Correspondence

Communication Contents: -From Peter A. Chace, NAPSR National Chairman 2016-2017, Public Utilities Commission of Ohio, Gas Pipeline Safety Program Manager: Since receipt of the original Recommendation, NAPSR has struggled with developing an integrated plan or formalized program to respond to this recommendation because of the way the gas transmission integrity management program is regulated. Transmission pipeline segments are either intrastate segments that only operate in one state and do not require state-to-state coordination of inspections, or interstate segments where only PHMSA has enforcement authority. Since the date of your letter, NAPSR has considered the recommendation and taken the following additional actions to develop and implement a plan to facilitate federal to state and state to state coordination to help pipeline safety inspectors conduct 1M inspections: 1. Voluntary Information Sharing System MSS) On November 28, 2016 PHMSA published a Federal Register Notice that announced the formation of a Voluntary Information Sharing System working group. This working group has the following mandate: • Identify the need for a system to ensure that dig verification data are shared with inline inspection operators to the extent consistent with the need to maintain proprietary and security-sensitive data in a confidential manner to improve pipeline safety and inspection technology; Explore ways to encourage the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis; • Explore opportunities to share data, including dig verification data between operators of pipeline facilities and inline inspector vendors to expand knowledge of the advantages and disadvantages of the different types of in-line inspection technology and methodologies; • Look at options to create a secure system that protects proprietary data while encouraging the exchange of pipeline inspection information and the development of advanced pipeline inspection technologies and enhanced risk analysis; • Discuss means and best practices for the protection of safety- and security sensitive information and proprietary information; and • Discuss removing regulatory, funding, and legal barriers to sharing the information described above. NAPSR has two members that have recently been appointed as representatives on the VISS working group (Joe Subsits, Washington Utilities and Transportation Commission, and Michelle Thebert, Georgia Public Utilities Commission). We believe active participation in this work group will satisfy the intent of the recommendation to develop and implement a program or a process to formalize, publicize and facilitate increased coordination in Integrity Management state inspections, in cooperation with PHMSA and other interested parties. 2. 2016 PIPES Act Mandate- Interstate Inspections The 2016 Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act modified 49 U.S.C. 60106 by adding a paragraph (f) Joint Inspectors- "At the request of a State authority, the Secretary shall allow for a certified State authority under section 60105 to participate in the inspection of an interstate pipeline facility". PHMSA has already requested from NAPSR a list of State programs interested in participating in inspections of interstate pipeline facilities, including Integrity Management inspections. PHMSA then will inform the interested states of interstate gas transmission inspections scheduled to be conducted within that state during the 2017 calendar year. Our understanding is that PHMSA will further formalize this process by including it in the next revision of their "Guidelines for the States Participating in the Pipeline Safety Program." The opportunity for State programs to participate jointly in interstate gas transmission integrity management inspections with PHMSA will facilitate federal to state coordination on integrity management inspections. 3. Mentoring Program PHMSA has modified Section 5 .1.3 .a of their "Guidelines for the States Participating in the Pipeline Safety Program" to add information regarding the availability of PHMSA personnel to provide technical support to State inspectors, including 1M inspections. This process is referred to as a "mentoring program" and is intended to allow State programs to consult with PHMSA subject matter experts (SME), including SME's that conduct Federal integrity management inspections.

Addressee Acronym: NAPSR

Addressee Organization Type: A-Associations

Communication Date: 2016-06-14

Communication Type: Official Correspondence

Communication Contents: -From Steve Allen, NAPSR National Chairman, National Association of Pipeline Safety Representatives: The National Transportation Safety Board’s (NTSB) Safety Study: Integrity Management of Gas Transmission Pipelines in High Consequence Areas (NTSB SS-15/01) was completed in 2015 and the National Association of Pipeline Safety Representatives (NAPSR) received one recommendation related to the study. This letter is to inform you of NAPSR's response to that recommendation. The National Association of Pipeline Safety Representatives (NAPSR) is a non-profit corporation, a national association with members that represent the 48 contiguous states, Puerto Rico and the District of Columbia. Nearly 90% of the nation’s 2.3 million miles of pipelines are directly subject to NAPSR regulatory oversight. Through a unique partnership with the U.S. Department of Transportation, Pipeline and Hazardous Materials Administration (PHMSA), NAPSR state inspectors members are responsible for safe and reliable transportation of natural gas, Liquefied Petroleum Gas (LP gas), hazardous liquids and other hazardous products through pipelines. State pipeline safety inspectors make up more than 75% of the State/Federal inspection workforce. NAPSR provides its members with a venue to share best practices, enhance communications with our federal counterparts, raise new issues, and influence policy. NAPSR is recognized by Congress, federal agencies, and the media as the national voice of the State pipeline safety community. NAPSR individual membership is comprised of dedicated state Pipeline Safety Program Managers, inspectors and technical personnel who are responsible for the state pipeline safety programs. The mission of NAPSR (which was founded in 1982) is "to strengthen state pipeline safety programs through promotion of improved pipeline safety standards, education, training and technology." NAPSR includes approximately 400 well qualified pipeline safety inspectors, with almost 150 inspectors within that total qualified for hazardous liquid facility inspections. Pipeline safety, including the safety of gas transmission pipeline systems, is a shared responsibility involving NAPSR, PHMSA and the operating companies that, as owners of pipeline infrastructure, are best positioned to know and understand varying pipeline system operating environments. NAPSR does not own or operate pipelines; its role as a collective of state regulators is to inspect pipelines and pipeline systems and enforce Federal and state pipeline safety regulations. Operators are ultimately responsible for their systems. They have the responsibility to monitor the area around their pipelines and keep abreast of risks. To that end, we continue to push operators to focus on performance and aim beyond the minimum compliance standards established through the pipeline safety regulations. Below is NAPSR's response to the specific NTSB recommendation contained in the Safety Study: Response to the NTSB Safety Study Recommendation: Safety Recommendation P-15-27 Recommendation: Work with the Pipeline and Hazardous Materials Safety Administration to develop and implement a program to formalize, publicize and facilitate increased state-to-state coordination in integrity management inspections. Response: NAPSR works with PHMSA on a regular basis. Part of the collaboration with PHMSA includes regular Region and National meetings to discuss both distribution and transmission pipeline safety and inspection issues. The meetings provide a primary process for the exchange of detailed information on completed and upcoming integrity management inspections. In addition, NAPSR conducts a Board of Directors Meeting each month to allow for, in addition to other NAPSR business, further communication and coordination of integrity management inspection efforts. In September/October of 2015, the NAPSR Board of Directors voted to allow all of the other Program Managers to participate in the Board meetings, thereby increasing communication and coordination among the members. In addition, through NAPSR/PHMSA collaboration in the NAPSR Grant Allocation and Strategic Planning Committee (GAC), PHMSA was able to formalize a process by which the states can request assistance and/or coordinate both gas transmission, gas distribution and hazardous liquid joint inspections with corresponding travel reimbursement. The process is currently in the 2016 PHMSA State Program Guidelines document. The NAPSR team web site also provides a means to share information related to both distribution and transmission integrity management inspections and issues. Information is regularly posted to the web site, which is accessible to all of the NAPSR Program Managers and key staff personnel who conduct inspections. CONCLUSION NAPSR feels that the coordinated efforts with PHMSA in regards to increased coordination and exchange of information related to integrity management inspections fully addresses this recommendation. Thus, NAPSR respectfully requests that NTSB indicate that Recommendation P-15-27 is closed with an acceptable response. NAPSR members will continue to work with each other to coordinate, when appropriate, integrity management inspections of gas transmission operators. NAPSR continues to strive for the highest possible safety outcomes within the inspection process.

Addressee Acronym: NAPSR

Addressee Organization Type: A-Associations

Communication Date: 2017-02-22

Communication Type: Official Correspondence

Communication Contents: On December 5, 2016, we responded to PHMSA’s August 17, 2016, letter regarding companion recommendation P-15-3. Because PHMSA had worked with you on this issue as requested, Safety Recommendation P-15-3 was classified “Closed—Acceptable Action.” In closing this recommendation, we noted that, on April 12, 2016, PHMSA’s director of state programs e-mailed an operator coordination report to all states. The report was developed for PHMSA and the states to see if any states have operators in common to help coordinate inspections. Further, we noted that PHMSA supports your internal website that states can use to share information to increase state-to-state coordination on IM inspections. Because you and PHMSA have satisfactorily addressed these issues as requested, Safety Recommendation P-15-27 is also classified CLOSED--ACCEPTABLE ACTION. Thank you for your assistance and commitment to pipeline safety.

Addressee Acronym: NAPSR

Addressee Organization Type: A-Associations

Communication Date: 2016-05-19

Communication Type: Official Correspondence

Communication Contents: Recipients of our safety recommendations typically complete action to address them within 3 to 5 years. Although we issued this recommendation to you over a year ago, we have received no reply from you regarding your actions or intentions to address Safety Recommendation P 15-27. Accordingly, we would appreciate receiving a prompt update on your plans and actions to satisfy it. We are interested in knowing whether and how our recommendations are implemented, both to ensure the public the highest level of safety and to identify creative solutions that can be shared with others. Safety Recommendation P-15-27 is currently classified OPEN—AWAIT RESPONSE; unless we receive a timely reply from you, we may have to classify this recommendation in an unacceptable status. A copy of our February 10, 2015, letter issuing Safety Recommendation P-15-27 is enclosed. The full report of our safety study, Integrity Management of Gas Transmission Pipelines in High Consequence Areas, is available at http://www.ntsb.gov/safety/safety-studies/Pages/SS1501.aspx

Addressee Acronym: NAPSR

Addressee Organization Type: A-Associations

Communication Date: 2016-08-31

Communication Type: Official Correspondence

Communication Contents: On July 15, 2015, we responded to a May 12, 2015, letter from PHMSA regarding companion recommendation P-15-3, which asked PHMSA to work with you on this issue. Our letter commended your ongoing support to PHMSA; your website, which allows states to share relevant information; and the anticipated implementation of your state-to-state mentoring program, which includes IM inspections. We noted PHMSA’s intent to work with you to complete the recommended actions by December 31, 2015. Safety Recommendation P-15-3 was classified “Open—Acceptable Response,” pending completion of this effort. You state in your most recent letter that that NAPSR continues to work with PHMSA on a regular basis, holding regional and national meetings to discuss distribution and transmission pipeline safety and inspection. NAPSR also conducts a board of directors (BOD) meeting each month, and in September 2015, the BOD voted to allow all other program managers within NAPSR to participate in the board meetings, thereby increasing communication among the members. Additionally, the NAPSR Grant Allocation and Strategic Planning Committee has formalized a process, in collaboration with PHMSA, in which states can request assistance for joint inspections. Finally, you highlight that NAPSR’s team website provides a way for personnel to share information related to distribution and transmission IM inspections and issues, and that NAPSR program managers and key staff who conduct inspections have access to this information. We are pleased you are working with PHMSA and have initiated the actions cited above. Our purpose in issuing Safety Recommendation A-15-27, as described in our safety study, Integrity Management of Gas Transmission Pipelines in High Consequence Areas, was to encourage you, in collaboration with PHSMA, to develop and implement a plan to facilitate federal-to-state and state-to-state coordination to help pipeline safety inspectors conduct IM inspections. This plan would facilitate coordination between regulatory organizations and between inspectors; however, it is not clear that your actions represent an integrated plan that has been implemented to address our recommendation, or if they are independent actions. It is also not clear that your program has been fully developed and implemented. We would appreciate additional information about how the actions you have taken represent an integrated plan that has been implemented to meet the intent of Safety Recommendation P-15-27, rather than independent actions that are associated with the recommendation topic. We would also like to know whether the program development is now complete. Accordingly, pending receipt of additional information, Safety Recommendation P 15 27 is classified OPEN—ACCEPTABLE RESPONSE.