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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.
TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Update guidance for gas transmission pipeline operators and inspectors on the evaluation of interactive threats. This guidance should list all threat interactions that must be evaluated and acceptable methods to be used.
Original recommendation transmittal letter:
Open - Acceptable Response
Addressee(s) and Addressee Status:
PHMSA (Open - Acceptable Response)
Safety Recommendation History
You previously told us that, on September 9 and 10, 2015, you held a risk-modeling workshop to address how operators can move beyond risk index models, when needed, to improve investigative and forensic capabilities and to enhance stakeholder engagement. Further, you established a risk modeling work group that included industry and other stakeholders and that addressed perceived shortcomings in certain risk models. Although you expected to develop risk-model guidance for operators by July 2017 that includes how to evaluate for interactive threats, the publication date for this guidance has been delayed until 2018. Pending publication of that guidance, Safety Recommendation P 15 10 remains classified OPEN--ACCEPTABLE RESPONSE.
-From Howard R. Elliott, Administrator: PHMSA is currently drafting guidance to meet this recommendation. On September 9-10, 2015, PHMSA held a risk modeling workshop to address how operators may move beyond risk index models to improve investigative and forensic capabilities where needed, and to enhance stakeholder engagement. After the workshop, PHMSA determined that additional time would be needed to allow for critical stakeholder involvement, and reported that we expected to publish by July 31, 2017. To gather this input, PHMSA established a risk modeling work group that includes industry and other stakeholders to address perceived shortcomings in the application of certain risk models (https://primis.phmsa.dot.gov/rmwg/index.htm). The group has held meetings since late 2015 to develop and discuss guidance for operators on risk models, including the evaluation of interactive threats, which will be finalized by PHMSA and communicated to stakeholders. Due to extensive stakeholder coordination, PHMSA now expects to publish guidance by April 30, 2018.
We understand that, in September 2015, you held a risk-modeling workshop to address how operators can move beyond risk index models, when needed, to improve investigative and forensic capabilities and to enhance stakeholder engagement. Further, you established a risk-modeling work group that included industry and other stakeholders and addressed perceived shortcomings in certain risk models. You are now developing guidance for operators to use when evaluating interactive threats, which you will disseminate to stakeholders by July 31, 2017. Pending completion of these efforts, Safety Recommendation P-15-10 is classified OPEN—ACCEPTABLE RESPONSE.
-From Marie Therese Dominguez, Administrator: On September 9-l 0, 2015, PHMSA held a risk modeling workshop to address how operators can move beyond risk index models where needed to improve investigative and forensic capabilities and to enhance stakeholder engagement. After the workshop, PHMSA established a risk modeling work group that includes industry and other stakeholders, to address perceived shortcomings in the application of certain risk models. The expected outcome of this work group will be guidance for operators to use in evaluating interactive threats. This guidance will be communicated to stakeholders through an appropriate mechanism, such as an advisory bulletin. PHMSA originally anticipated publishing this guidance by May 31, 20 16; however, to allow for critical stakeholder involvement, as discussed during the workshop, we now expect to publish by July 31, 2017.
We understand that you plan to perform an evaluation of interactive threats and publish the results in an advisory bulletin and as updated inspection protocol guidance, as needed, by the end of May 2016. Your plans to enhance and expand minimum requirements for performing threat identification to specify requirements for minimum data sets used, data validation, data integration, subject matter expert bias, and interacting threats, should address Safety Recommendation P-15-10 by addressing previous shortcomings in threat identification, specifically regarding interactive threats. We note that you are also planning to hold a risk modeling workshop in 2015 to address how operators may move beyond risk index models to improve investigative and forensic capabilities, which will help you in developing guidance for addressing interactive threats. Pending completion of these actions, Safety Recommendation P 15-10 is classified OPEN—ACCEPTABLE 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 will perform an evaluation of interactive threats and publish the results in an advisory bulletin and as updated inspection protocol guidance, as needed, by May 31, 2016. As part of its in-process NPRM on gas transmission safety, PHMSA intends to enhance and expand minimum requirements for performing threat identification to include specific requirements to address standards for minimum data sets used, data validation, data integration, subject matter expert bias, and interacting threats. PHMSA believes that these improved requirements will address this recommendation by focusing on the root cause of previous shortcomings in threat identification, specifically with respect to consideration of interactive threats. This NPRM is currently under OMB review, and we expect to publish in the summer of 2015. PHMSA is also planning a risk modelling workshop in 2015 to address how operators may move beyond risk index models where needed to improve investigative and forensic capabilities. The workshop will help inform guidance to address interactive threats.
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