Safety Recommendation P-15-011
Details
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: Develop and implement specific risk assessment training for inspectors in verifying the technical validity of risk assessments that operators use.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Action
Mode: Pipeline
Location: United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA14SS002
Accident Reports:
Report #: SS-15-01
Accident Date: 11/20/2013
Issue Date: 2/10/2015
Date Closed: 4/19/2021
Addressee(s) and Addressee Status: PHMSA (Closed - Acceptable Action)
Keyword(s):

Safety Recommendation History
From: NTSB
To: PHMSA
Date: 4/19/2021
Response: We note that PHMSA established a Critical Task Selection Board to revise all of the agency’s integrity management courses, and prioritized their placement on PHMSA’s Master Course Development Schedule to train inspectors on how to verify the validity of risk assessment procedures. We further note that you post revised web-based training materials and course materials as a continuing education resource for students who have previously taken the courses. Accordingly, Safety Recommendation P-15-11 is classified CLOSED--ACCEPTABLE ACTION.

From: PHMSA
To: NTSB
Date: 12/21/2020
Response: -From Howard R. Elliott, Administrator: PHMSA proposed closure of this safety recommendation on December 3, 2019, and looks forward to NTSB's response. PHMSA would be pleased to meet with the NTSB to further discuss this safety recommendation.

From: NTSB
To: PHMSA
Date: 1/23/2020
Response: We note that you have identified the portions of your training program that would be affected by the materials being developed in response to Safety Recommendation P-15-10, and you have evaluated the impacted portions of your training and qualifications (TQ) program. We further note that the TQ program’s Critical Task Selection Board is nearly finished reviewing all risk-assessment courses and training materials within your IM curriculum that need to be revised, and you expect this review to soon be completed. Your TQ program will make revised web based training and course materials available as continuing education for students who have already taken the courses. Pending completion of these actions, Safety Recommendation P-15-11 remains classified OPEN--ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 12/3/2019
Response: -From Howard R. Elliott, Administrator: PHMSA requests closure of this recommendation. PHMSA identified the portions of its training program that would be affected by the training materials specified in P-15-10, P-15-12, and P-15-13. Using a Critical Task Selection Board, PHMSA revised all Integrity Management (IM) related courses and prioritized their placement on PHMSA's Master Course Development Schedule to clearly train inspectors on how to verify the validity of risk assessment procedures. Specifically, PHMSA revised the Fundamentals of Integrity Management DL course and several IM prerequisite courses, which include: • PL0150 DLl Fundamentals of Pipelines • PL0150 DL2 Introduction to Inspections • PL0150 IL Introduction to Inspections • PL1250 DL Safety Evaluation of Gas Pipeline Systems • PL1250 IL Safety Evaluation of Gas Pipeline Systems • PL3242 DL Introduction to Welding Inspections • PL3242 IL Introduction to Welding Inspections • PL3275 General Safety Awareness PHMSA posts revised web-based training materials and course materials as a continuing education resource for students who have previously taken the courses. Additional training materials within the IM curriculum that need to be revised will be addressed during PHMSA's ongoing course enhancement activities. PHMSA believes that the actions already undertaken to revise risk assessment training for inspectors meet the intent of this recommendation.

From: PHMSA
To: NTSB
Date: 4/1/2019
Response: -From Howard R. Elliott, Administrator: PHMSA Training and Qualifications (TQ) is currently reviewing its courses using a critical task selection board (CTSB) that meets and reviews each course. CTSB meetings were originally scheduled through 2020 to accommodate course redesign and further curriculum development. By December 2019, PHMSA will revise training materials relating to risk assessment to clearly train inspectors on how to verify the validity of risk assessment procedures. PHMSA intends to post revised web-based training materials and course materials as a continuing education resource for students who have previously taken the courses.

From: NTSB
To: PHMSA
Date: 2/21/2018
Response: We note that you have identified the portions of your training program that would be affected by the materials being developed in response to Safety Recommendations P 15 10, -12, and -13, and you have evaluated the impacted portions of your training and qualifications (TQ) training program. Your letter describes the formalized process that you use to review and revise your TQ program. We note that the TQ program’s Critical Task Selection Board (CTSB) is nearly finished reviewing all risk assessment courses, and training materials within the IM curriculum that need to be revised will be addressed during the course redevelopment activities that will follow to ensure risk assessment is clearly explained throughout the process. Your TQ program will make revised web based training and course materials available as continuing education for students who have already taken the courses. Pending completion of the CTSB review, revisions to the IM curriculum, and your posting revised web-based training materials and course materials for students who have previously taken the courses, Safety Recommendation P-15-11 remains classified OPEN--ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 11/13/2017
Response: -From Howard R. Elliott, Administrator: PHMSA identified the portions of its Training Program that would be affected by the training materials specified in P-15-10, P-15-12, and P-15-13 that are currently under development. PHMSA evaluated the impacted portions of its Training & Qualifications (TQ) Training Program and identified portions of the curriculum for improvement. Specifically, PHMSA reviewed the training materials in Integrity Management (IM)-related courses, which include: • PHMSA-PL3350 Integrated Inspection (II) Course • PHMSA-PL3267 Fundamentals ofIM Course • PHMSA-PL1297 Gas IM Protocol Course • PHMSA-PL2294 Hazardous Liquid IM Protocol Course • PHMSA-PL1245 Safety Evaluation of Distribution IM Web-based training that supplements these courses' materials include: • WBT-PLlIPROC IM Processes • WBT-PLlRA Introduction to risk assessment methods • WBT-PLlDIMP Distribution IM Improvements in the course materials are directed at facilitating a more effective verification of the technical validity of risk assessments that operators use. PHMSA TQ is reviewing all of its courses using a Critical Task Selection Board (CTSB) that meets and reviews each course. The purpose of each CTSB meeting is to develop and validate individual and collective tasks required for job performance and critical tasks which inspectors must perform to successfully accomplish their duties. This process uses a Systems Approach to Training (SAT) and occurs in the middle of the Analysis phase of the instructional design model/process, ADDIE (Analysis, Design, Development, Implementation, Evaluation). Our focus within the Analysis phase is on task analysis to develop a critical task list. Critical tasks are those that inspectors (the students) must perform to successfully accomplish their duties. The Critical Tasks identified become learning objectives, which are the foundation of lesson plans. The goal of the CTSB is to complete a Critical Task List and Individual Task Analysis Report to send to the TQ Director for approval. Once the Board reaches consensus, the Training and Development Division Team will plan the course design and then submit a course design document for TQ Director approval. Course · development/redevelopment does not take place until these steps are complete. Training and Development Division's goal is to complete revised courseware one year from CTSB completion. The current schedule is for PHMSA TQ to complete the CTSB meetings for all courses addressing risk assessment by December 31, 2017, and the training materials identified for revision within the IM curriculum will be addressed during the course redevelopment activities to ensure risk assessment is clearly explained throughout the process. PHMSA TQ will post revised web-based training materials and course materials for students who have previously taken the courses to have available as continuing education.

From: NTSB
To: PHMSA
Date: 12/5/2016
Response: We note that you have identified the portions of your training program that would be affected by the training materials specified in Safety Recommendations P -15-10, -12, and -13 that are currently being developed; you have evaluated the impacted portions of your Training & Qualifications Training Program; and you have identified portions of the curriculum for improvement. You have also reviewed training materials in various IM-related courses and in web-based training that supplement these course materials. We understand that you intend to complete the critical task selection board meetings for all courses addressing risk assessment by the end of 2017, and that the training materials identified for revision within the IM curriculum will be addressed during course redevelopment activities to ensure risk assessment is clearly explained throughout the process. You will then post revised web -based training materials and course materials as continuing education for students who have previously taken the courses. Pending completion of these efforts, Safety Recommendation P -15-11 is classified OPEN—ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 8/17/2016
Response: -From Marie Therese Dominguez, Administrator: PHMSA has identified the portions of its Training Program that would be affected by the training materials specified in P-1 S-1 0, P-15-12, and P-15-13 that are currently under development. PHMSA evaluated the impacted portions of its Training & Qualifications (TQ) Training Program and identified portions of the curriculum for improvement. Specifically, PHMSA reviewed the training materials in 1M-related comes, which include: • PHMSA-PL3267 - Fundamentals of Integri1y Management Course • PHMSA-PL 1297 - Gas Integrity Management (IM) Protocol Course • PHMSA-PL2294- Hazardous Liquid 1M Protocol Course • PHMSA-PL1245- Safety Evaluation of Distribution Integrity Management. Web-based training that supplements these course materials include: • WBT-PLIIPROC- Integrity Management Processes • WBT-PLIRA- Introduction to Risk Assessment Methods • WBT-PLlDIMP- Distribution Integrity Management. Improvements in the course materials are directed at facilitating a more effective verification of the technical validity of risk assessments that operators use. PHMSA TQ is reviewing all of its courses using a Critical Task Selection Board (CTSB) that meets and reviews each course. The purpose of each CTSB is to develop and validate individual and collective tasks required for job performance and critical tasks which inspectors must perform to successfully accomplish their duties. This process uses a Systems Approach to Training (SAT) and occurs in the middle of the "Analysis" phase of the instructional design model/process, ADDIE (Analysis, Design, Development, Implementation, Evaluation). Our focus within the Analysis phase is on task analysis, to develop a critical task list. Critical tasks are those that inspectors (the students) must perform to successfully accomplish their duties. The Critical Tasks identified become learning objectives which are the foundation of lesson plans. The goal of CTSB is to complete a Critical Task List and Individual Task Analysis Report to send to the TQ Director for approval. Once each Board reaches consensus, the Training and Development Division Team will plan the course design and then submit a course design document for the TQ Director approval. Course development/redevelopment does not take place until these steps are complete. The Training and Development Division's goal is to complete revised courseware one year from CTSB completion. The current schedule is for PHMSA TQ to complete the CTSB meetings for all courses addressing risk assessment by December 3 J, 2017, and the training materials identified for revision within the IM curriculum will be addressed during the course redevelopment activities to ensure risk assessment is clearly explained throughout the process. PHMSA TQ will post revised web-based training materials and course materials for students who have previously taken the courses to have available as continuing education.

From: NTSB
To: PHMSA
Date: 7/15/2015
Response: We note that, by May 31, 2016, you plan to evaluate existing risk assessment training, identify needed improvements, and develop a corrective action plan, as required, to facilitate more effective verification of the technical validity of risk assessments that operators use. Accordingly, Safety Recommendation P-15-11 is classified OPEN—ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
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 will evaluate existing risk assessment training, identify needed improvements, and develop a corrective action plan, as required, by May 31, 2016, to facilitate more effective verification of the technical validity of risk assessments that operators use.