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Safety Recommendation Details

Safety Recommendation P-15-005
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.
Recommendation: TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Revise the submission requirement to include high consequence area identification as an attribute data element to the National Pipeline Mapping System.
Original recommendation transmittal letter: PDF
Overall Status: Open - Acceptable Response
Mode: Pipeline
Location: United States
Is Reiterated: No
Is Hazmat: No
Accident #: DCA14SS002
Accident Reports:
Report #: SS-15-01
Accident Date: 11/20/2013
Issue Date: 2/10/2015
Date Closed:
Addressee(s) and Addressee Status: PHMSA (Open - Acceptable Response)

Safety Recommendation History
From: NTSB
Date: 2/21/2018
Response: We note that you continue to improve the quality of the data contained in the NPMS as described in your previous letters, including making specific improvements to data submissions relative to HCAs. We further note that these activities are currently subject to the governmentwide regulatory review required by executive order. Pending completion of the review and of the activities that you have previously described, Safety Recommendations P-15-4 and -5 remain classified OPEN--ACCEPTABLE RESPONSE.

Date: 11/13/2017
Response: -From Howard R. Elliott, Administrator: Please see PHMSA's response to NTSB Safety Recommendation P-15-4, which describes the steps PHMSA has taken since 2014 to improve the quality of the data contained in the NPMS, including specific improvements in data submissions relative to HCAs. Like many other issues before us, this is part of an ongoing regulatory review pursuant to the executive order issued by the President.

From: NTSB
Date: 12/5/2016
Response: Your update to Safety Recommendation P-15-4 describes the steps you have taken since 2014 to improve the quality of the data contained in the NPMS, including specific improvements in data submissions relative to HCAs. We note that, as part of your efforts to satisfy Safety Recommendations P-15-4 and -5, you have taken a series of steps to address the positional accuracy of NPMS data to help emergency responders more effectively locate pipelines and respond to environmental and integrity threats as well as to help in emergency planning. To this end, you published two Federal Register notices, “Request for Revision of a Previously Approved Information Collection—National Pipeline Mapping System Program,” and “Request for Revision of a Previously Approved Information Collection—NPMS Program,” which invited public comment on improved positional accuracy of pipeline maps and other pipeline attribute details. We note that you have proposed that gas transmission operators submit data at approximately 50-feet accuracy for all segments that are in a Class 2, Class 3, or Class 4 area; within an HCA or that have one or more buildings intended for human occupancy; in an identified site (49 CFR 192.903); or in a right-of-way for a designated interstate, freeway, expressway, or other principal four-lane arterial roadway, as defined in the Federal Highway Administration’s Highway Functional Classification Concepts, within the segment’s potential impact radius. We further note that all other gas pipeline segments would be mapped to a positional accuracy of approximately 100 feet and, as part of the process, you will review each additional data element to determine the appropriate security classification. In addition, you held a public meeting on this notice on November 18, 2015, and published an information collection notice on June 22, 2016. Pending completion of these efforts, Safety Recommendations P-14-4 and -5 are classified OPEN—ACCEPTABLE RESPONSE.

Date: 8/17/2016
Response: -From Marie Therese Dominguez, Administrator: Please see PHMSA 's response to NTSB Safety Recommendation P-15-4, which describes the steps PHMSA has taken since 2014 to improve the quality of the data contained in the NPMS, including specific improvements in data submissions relative to HCAs.

From: NTSB
Date: 7/15/2015
Response: We understand that, as part of your efforts to address Safety Recommendation P-15-4, you plan to continue to evaluate HCA identification as an NPMS attribute data element and, as discussed above, you are planning to revise the notice that you published last July accordingly. Pending completion of your efforts as scheduled, Safety Recommendations P-15-5 is classified OPEN—ACCEPTABLE RESPONSE.

Date: 5/12/2015
Response: -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 began addressing the identification of High Consequence Areas (HCAs) in the NPMS prior to the NTSB report. On July 30, 2014, PHMSA published a notice titled “Request for Revision of a Previously Approved Information Collection—National Pipeline Mapping System Program” (79 FR 44246), which specifically addressed identifying operators’ HCA pipe segments in their NPMS submissions. Subsequently, in response to comments received from the Federal Register notice, PHMSA held a public workshop on November 17, 2014, to address this and other geospatial information collection initiatives. Information on the workshop is available on PHMSA’s public website: PHMSA will continue to evaluate HCA identification as a NPMS attribute data element and is writing a revised information collection notice that addresses this issue. We anticipate publication by December 31, 2015.