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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: Revise Form F7100.1, Annual Report Form, to collect information about which methods of high consequence area identification and risk assessment approaches were used.
Original recommendation transmittal letter:
Open Acceptable Alternate Response
Addressee(s) and Addressee Status:
PHMSA (Open Acceptable Alternate Response)
Safety Recommendation History
We note that, although you agree that information about HCA identification methods and risk assessment approaches should be collected, you believe this information would be best stored as a data attribute in the NPMS, which you are improving in response to Safety Recommendation P 15 4. You anticipated new standards for NPMS data collection following the final information collection notice, which was published in the Federal Register on June 22, 2016; however, this notice is subject to the governmentwide regulatory review required by the president’s executive order. We believe that making information about HCA identification methods and risk assessment approaches a data attribute in the NPMS is an acceptable alternate approach that will satisfy this recommendation. Pending completion of the review and your adding the information as an attribute in the NPMS, Safety Recommendation P 15 15 is classified OPEN--ACCEPTABLE ALTERNATE RESPONSE.
-From Howard R. Elliott, Administrator: PHMSA agrees with the NTSB that information about HCA identification methods and risk assessment approaches should be collected. However, PHMSA believes this data would be best obtained as a data attribute in the NPMS Information Collection discussed in PHMSA's response to NTSB Recommendation P-15-4. The NPMS Information Collection Federal Register notices invited public comment on pipeline attribute details, including the locations of HCAs and "could affect HCA" areas, but not the method by which those areas were identified. The Information Collection also proposed to collect attributes of "last assessment year" and "most recent assessment method," which would be a choice between ILI, hydrostatic pressure test, or direct assessment method. Like many other issues before us, this is part of an ongoing regulatory review pursuant to the executive order issued by the President.
We understand that your efforts to address Safety Recommendation P-15-5 are related to Safety Recommendation P-15-15, and note that you continue to address these issues. You anticipate new standards for NPMS data collection following the final information collection notice, which was published at the Federal Register on June 22, 2016, following two previous notices in 2014 and 2015 regarding revisions to information collection standards. Pending the completion of ongoing action, Safety Recommendation P-15-15 is classified OPEN—ACCEPTABLE RESPONSE.
-From Marie Therese Dominguez, Administrator: PHMSA agrees with NTSB that information about HCA identification methods and risk assessment approaches should be collected. However, PHMSA believes this data would be best obtained as a data attribute in the NPMS geospatial information collection initiative discussed in PHMSA's response to NTSB Recommendation P-1 5-5. The NPMS Info Collection will collect the locations of HCAs (including "could affect" areas) but not the method by which those areas were identified. The NPMS is also collecting the related attributes of "Most recent assessment method" and ''Last assessment year." The choices for the method are inline inspection, hydrostatic pressure test, or direct assessment method. PHMSA anticipates new standards for NPMS data collection following the final Information Collection notice, which was published in the Federal Register on June 22, 2016. This followed two previous notices in 2014 and 2015 regarding revision of information collection standards.
We note that you believe this data would be best obtained as a data attribute in the NPMS geospatial information collection initiative, as a part of your response to Safety Recommendation P-15-5. We also note that the current annual report form F7100.2-1 cannot be used to collect such information because it has space to record only aggregated mileage amounts, whereas operators use different HCA identification methods for different segments of pipeline. We understand that the current Incident Report Form F7100.2, revised in October 2014, requests the class location of the incident site, whether or not it was an HCA, which method was used to identify HCAs, and other information regarding structures in the vicinity of the incident. We further note your belief that the new data being collected through the revised information collection will also help address this recommendation. Pending the completion of action on Safety Recommendation P-15-5 and our receipt of further information regarding how this action addresses the issue that is the focus of Safety Recommendation P-15-15, the recommendation 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 in part. PHMSA believes this data would be best obtained as a data attribute in the NPMS geospatial information collection initiative discussed in PHMSA’s response to P-15-5. The annual report form F7100.2-1 is not amenable to collecting this sort of information because the form only collects the aggregated mileage amounts. This said, operators can and do use different HCA identification methods for different segments of pipeline. PHMSA’s current Incident Report Form, published in October 2014, does request the class location of the incident site, whether or not it was an HCA, which method was used to identify HCAs, and other information regarding structures in the vicinity of the incident. PHMSA believes that the new data being collected through the revised information collection will also help address this recommendation.
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