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From:
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PHMSA
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To:
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NTSB
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Date:
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5/12/2015
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Response:
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-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 that the in-process gas transmission safety NPRM will achieve the intention of this recommendation by maximizing the safety achievable given cost-benefit and technology constraints. The NPRM is currently under OMB review, and we expect to publish it in the summer of 2015.
Pipelines might not be able to be inspected with in line inspection (ILI) tools if they contain tight radius bends, low product flow conditions, valves that do not fully open, small diameters, some telescoping configurations, or other issues. Though there are some limitations on PHMSA’s ability to apply new design standards to existing infrastructure, we have commissioned a study that provides estimates of costs and benefits of regulatory scenarios for implementing the NTSB’s recommendation (P-11-18 superseded by P-15-18). PHMSA expects the results of the preliminary analysis to be communicated to the NTSB in the near future. In conjunction with the study, PHMSA’s proposed gas transmission safety rule will result in many miles of pipe being upgraded and assessed with ILI tools, even though the rule does not mandate ILI for all segments.
PHMSA actively supports the development of new technology in our R&D activities, and will consider future rulemaking mandating the use of new technologies as their capabilities and reliability are demonstrated.
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