Pipeline Safety Stakeholder Communications

As part of its annual grant evaluation process, PHMSA performs thorough evaluations of each state pipeline safety regulatory program. To support this evaluation PHMSA and the National Association of Pipeline Safety Representatives (NAPSR) have developed a set of performance metrics. These metrics look at state program performance in six areas:

• Damage Prevention Program
• Inspection Activity
• Inspector Qualification
• Leak Management
• Enforcement
• Incident Investigation

These metrics for Oregon are provided below.(1) The Oregon Public Utility Commission provides oversight of intrastate gas pipelines in Oregon through certification by PHMSA.

Damage Prevention Program

Excavation damage is the leading cause of natural gas distribution pipeline incidents, and a leading cause of other pipeline incidents, nationwide. A critical step in preventing excavation damage is for the excavator to notify pipeline operators of intent to excavate at a specific location. This is normally done by the excavator calling a one-call center. The one-call center then issues a locate ticket to inform pipeline operators and other underground utility operators with facilities located near the planned excavation activity. The pipeline operators can then locate and mark the location of their pipelines and otherwise communicate with the excavator as necessary to prevent damage to the pipelines.

The number of excavation damage occurrences per 1,000 locate tickets is an established benchmark within the damage prevention industry and an important indicator of damage prevention program performance. However, note that variations among state laws regarding locate ticket size and scope, along with the length of time a locate ticket is valid, will limit any state to state comparison of this metric.

The excavation damages metric illustrated below includes data for natural gas distribution system operators only. It does not include data from gas transmission or hazardous liquid pipeline operators as there is insufficient data available for those types of pipelines.

Inspection Activity

Regulator inspection time with each pipeline operator is vital in identifying compliance issues and gaining knowledge about the condition of the operator’s systems. Measurement of the level of inspection activity by the state program is based on the number of inspection days per combined miles of distribution (including mains and service lines), gathering and transmission lines. Measurement of the level of inspection activity spent on master meter and small liquid propane gas (LPG) system operators is shown separately, where applicable, as those operators are handled individually by each state due to various unique considerations.

Inspector Qualification

PHMSA rates each state’s inspector qualification program based on the levels of training and experience of the program’s inspection staff. The level of training and experience of inspectors directly impacts the quality of pipeline inspections performed. For the ratings, PHMSA looks at three separate attributes, including the percentages of the state’s inspection staff that have: 1) successfully completed the core pipeline safety training program; 2) successfully completed additional training addressing topics such as Integrity Management, Welding, and Failure Investigations; and, 3) five or more years of inspection experience.

“Additional Training” primarily consists of detailed PHMSA-provided training relating to conducting integrity inspections and understanding the methods and processes used in integrity management programs.

Leak Management

Leak management is measured by the total number of leaks repaired per mile, the total number of hazardous leaks repaired per mile, and the total leaks scheduled for repair per mile for gas distribution systems in each state. This provides an overview of the status of gas distribution pipeline systems in each state and the efforts to locate, evaluate, and repair and mitigate leaks.

Enforcement

Effective state enforcement programs and processes are necessary to ensure all operators are in compliance with all applicable pipeline safety regulations. The effectiveness of the State agency’s pipeline safety efforts depends on information obtained through inspections and evaluation of operator compliance. Each State agency must have a current written plan for its pipeline safety program.

An important aspect of any State agency’s compliance program involves the gathering of the necessary evidence for documenting noncompliance. Subsequent to each inspection, any findings should be documented and include an account of the situations encountered during the inspection and a copy of the inspection checklist. The documentation must identify and describe each regulation with which the operator is believed to be in noncompliance. Copies of relevant operator records, statements from operator personnel, photographs, calculations, and all other data pertaining to each issue of noncompliance should be made a part of the documentation.

This metric demonstrates the effectiveness of the state’s regulatory enforcement program. It is based on PHMSA’s annual evaluation of the state’s enforcement program, with review of the state’s records and procedures. The state’s performance is measured against the percentage of possible score that the state could achieve.

Documents used in evaluating state programs are available. Look under the section entitled “Federal Grant Program”.

Incident Investigation

State agencies must have effective incident investigation processes and must conduct investigations of each significant or reportable incident/accident involving a jurisdictional pipeline facility. The primary objective of the investigation activity is to minimize the possibility of recurrence and to institute enforcement actions where noncompliance with the safety standards has occurred. Effective incident investigation processes are also necessary to ensure operators have and effectively implement emergency response procedures and make continuous improvements to their emergency response programs.

This metric demonstrates the effectiveness of the state’s incident investigation process. It is based on PHMSA’s annual evaluation of the state’s program, with review of the state’s records and procedures. It is measured against the percentage of possible score that the state could achieve, and is measured separately for hazardous liquid and natural gas pipelines. Since individual states sometimes experience a limited number of pipeline incidents, they may not conduct a full incident investigation in a given calendar year. In these years, evaluation of a state’s incident investigation performance may be limited to evaluation of the procedures the state has in place.

Documents used in evaluating state programs are available. Look under the section entitled “Federal Grant Program”.

Notes

1. PHMSA began collecting data for these metrics in 2010; prior to then adequate data was not readily available.

Sources

• Gas Distribution Annual Report data submitted by pipeline operators to PHMSA for calendar years 2010 – 2015
• Gas Transmission Annual Report data submitted by pipeline operators to PHMSA for calendar years 2010 – 2015
• Hazardous Liquid Annual Report data submitted by pipeline operators to PHMSA for calendar years 2010 – 2014
• Base Grant Progress Reports, State Field Inspection Activity, submitted by each state pipeline safety agency to PHMSA
• Qualified Liquid Standard inspectors, CY13, CY14, and CY15 reports from PHMSA Training and Qualification Group
• Qualified Gas Inspectors, CY13, CY14, and CY15 reports from PHMSA Training and Qualification Group
• Qualified Liquid IM Inspectors plus CRM and OQ WBT Courses, CY13, CY14, and CY15 reports from PHMSA Training and Qualification Group
• Qualified Gas IM Inspectors plus CRM, OQ WBT, and DIMP Courses, CY13, CY14, and CY15 reports from PHMSA Training and Qualification Group
• State Program Evaluations, Parts D and E, reports from PHMSA for calendar years 2010 through 2014