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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 critical components of risk assessment approaches. Include (1) methods for setting weighting factors, (2) factors that should be included in consequence of failure calculations, and (3) appropriate risk metrics and methods for aggregating risk along a pipeline.
Original recommendation transmittal letter:
Open - Acceptable Response
Addressee(s) and Addressee Status:
PHMSA (Open - Acceptable Response)
Safety Recommendation History
We note that the three risk-model–oriented research and development projects that you sponsored to partly satisfy this recommendation were recently finished, and final reports for each are available. We also note that your September 2015 risk-modeling workshop addressed how operators can move beyond risk index models to improve investigative and forensic capabilities and enhance stakeholder engagement, and you established a risk-modeling work group, including industry and other stakeholders, which addressed perceived shortcomings in certain risk models. Finally, we understand that the guidance you are developing on critical components of risk assessment management was delayed because it requires extensive coordination with industry and other stakeholders. Pending completion and issuance of this guidance, Safety Recommendation P-15-13 remains classified OPEN--ACCEPTABLE RESPONSE.
-From Howard R. Elliott, Administrator: PHMSA is drafting risk modeling guidance that will address this recommendation. To develop the guidance, PHMSA held a risk modeling workshop and established a working group, described in our response to Recommendation P-15-10. 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 coordination, PHMSA now expects to publish guidance by April 30, 2018. PHMSA may host a webinar regarding the guidance following its publication. All meeting minutes and meeting presentations are available at https://primis.phmsa.dot.gov/rmwg/index.htm. PHMSA also addressed this recommendation through its Research and Development (R&D) initiatives. On September 30, 2015, PHMSA awarded three risk-oriented R&D projects that will inform, as appropriate, the risk modeling guidance. The projects covered areas such as: (1) reviewing candidate models from inside/outside pipeline industry based on their suitability to pipelines and the models' operational, regulatory and business realities, including usage of decision theory to optimize risk; (2) approaches for preventing catastrophic events; and (3)risk tolerance: • Approaches for Preventing Catastrophic Events (http://primis.phmsa.dot.gov/matrix/PrjHome.rdm ?prj=63 8) • White Paper on Risk Tolerance (http://primis.phmsa.dot.gov/matrix/PrjHome.rdm?prj=639) • Critical Review of Candidate Pipeline Risk Models (http://primis.phmsa.dot.gov/matrix/PrjHome.rdm?prj=656). All three projects are now complete and Final Reports are publicly posted to the links above.
We note that you sponsored research and development work in risk-model-oriented projects, including three in September 2015: Approaches for Preventing Catastrophic Events, White Paper on Risk Tolerance, and Critical Review of Candidate Pipeline Risk Models. We also note that you conducted a risk-modeling workshop in September 2015 to address how operators can move beyond risk index models to improve investigative and forensic capabilities and enhance stakeholder engagement. You established a risk-modeling work group that includes industry and other stakeholders to address perceived shortcomings in the application of certain risk models, and, by the end of July 2017, you will issue guidance on critical components of risk-assessment management. Pending completion of these efforts, Safety Recommendation P-15-13 is classified OPEN—ACCEPTABLE RESPONSE.
-From Marie Therese Dominguez, Administrator: PHMSA sponsors Research & Development (R&D) projects which, among other things, focus on providing near-term solutions that will increase the safety and reliability of the Nation's pipelines. The existing R&D portfolio includes risk model-oriented projects in areas such as: (1) reviewing candidate models from inside/outside pipeline industry based on their suitability to pipelines and the models' operational, regulatory and business realities, including usage of decision theory to optimize risk; (2) approaches for preventing catastrophic events; and (3) risk tolerance. We awarded three projects on September 30,2015: Approaches for Preventing Catastrophic Events (http://prirnis.phmsa.dot.gov/matrix/PrjHome.rdm?prj=638); White Paper on Risk Tolerance (http://primis.phmsa.dot.gov/matrix/PrjHome.rdm?prj=639); and Critical Review of Candidate Pipeline Risk Models (http://primis.phmsa.dot.gov/matrix/PrjHome.rdm?prj=656). Insights and lessons learned from these projects will inform, as appropriate, the revision of PHMSA's guidance on risk assessment approaches. On September 9-10, 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 is guidance on critical components of risk assessment management. This guidance will be communicated to stakeholders through an appropriate mechanism such as an advisory bulletin. PHMSA expects to publish by July 31, 2017.
We note that PHMSA has existing research and development (R&D) solicitations for risk model?oriented projects in such areas as (1) reviewing candidate models from inside and outside the pipeline industry, based on their suitability to pipelines and the models’ operational, regulatory and business realities, including usage of decision theory to optimize risk; (2) approaches for preventing catastrophic events; and (3) risk tolerance. We further note that project awards were scheduled for May 2015 and that you plan to consider the insights and lessons learned from these projects, as appropriate, in revising your guidance on risk assessment approaches. In addition, the modeling workshop discussed above will provide you a public forum for gathering data to assist you in developing guidance on risk assessment approaches. We understand that, upon completion of the action taken in response to Safety Recommendation P-15-12, you plan to evaluate your guidance on critical components of risk assessment approaches, identify needed improvements, and revise the guidance, as required, by December 31, 2017. We support your plans to communicate the revisions through updated inspection protocol guidance and to the industry and the public through an advisory bulletin and other appropriate means. Pending completion of these efforts as described and scheduled, Safety Recommendation P 15 13 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. Upon completion of the action noted in P-15-12, PHMSA will conduct an evaluation of its guidance on critical components of risk assessment approaches, identify needed improvements, and revise its guidance, as required, by December 31, 2017. Revised guidance will be communicated through updated inspection protocol guidance and to the industry and the public through an advisory bulletin and other means as appropriate. PHMSA has existing R&D solicitations for risk model oriented projects in areas such as: (1) reviewing candidate models from inside/outside pipeline industry based on their suitability to pipelines and the models’ operational, regulatory and business realities, including usage of decision theory to optimize risk; (2) approaches for preventing catastrophic events; and (3) risk tolerance. We anticipate project awards in May 2015. Insights and lessons learned from these projects will be considered, as appropriate, for informing the revision of PHMSA’s guidance on risk assessment approaches. The modelling workshop referred to in response to P-15-10 and P-15-12 will provide a public forum for PHMSA to gather data to inform guidance developed on risk assessment approaches.
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