Pipeline Integrity Management:
An Evaluation to Help Improve PHMSA’s Oversight Of Performance-Based Pipeline Safety Programs
Background
In the aftermath of the natural gas pipeline explosion and fire in San Bruno, California on September 9, 2010, the National Transportation Safety Board (NTSB) identified actions that could improve the Department’s oversight of performance-based safety programs and formally recommended that the Secretary of Transportation conduct an audit to address these concerns. Accordingly, the Department’s Office of the Under Secretary for Policy tasked a senior staff member from the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Office of the Chief Safety Officer to conduct a review of PHMSA’s Pipeline Integrity Management Program.
Integrity Management is a performance-based, process-oriented regulatory program developed by PHMSA in response to the Accountable Pipeline Safety and Partnership Act of 1996 (PL 104-304) and the Pipeline Safety Improvement Act of 2002 (PL 107-355). Integrity Management is intended to replicate the methods used by best-in-class safety-oriented organizations to improve safety performance continually through an iterative process of collecting data, identifying risks, undertaking corrective action, and assessing performance.
Review Purpose and Results
The purpose of this review was to assess PHMSA’s experience with Integrity Management as a regulatory approach, to identify the challenges with applying Integrity Management in a regulatory context, and to offer suggestions to improve program performance. The review describes the challenges that arise when transitioning from a predominantly prescriptive-based regulatory regime to an approach that balances prescriptive regulations with a performance-based approach.
The review suggests that it is more difficult to monitor performance-based regulations than a static set of rules, and to objectively determine compliance or non-compliance. Successful implementation of performance-based systems requires a significant operator commitment to the approach; a diverse set of skills that extend beyond pipeline engineering; detailed information on each individual pipeline system and operating conditions; and an understanding of the causes of accidents and near-accidents. There is a risk that some operators may adopt Integrity Management principles without understanding or properly implementing the substance.
Regulators require information about pipeline conditions and incident causes in order to accurately assess programmatic effectiveness. For both operators and regulators, the heart of Integrity Management is to identify the most serious risks through evaluation of system and accident data, take corrective action, evaluate program effectiveness, and take new measures based on an assessment of the results. The report noted the general inadequacy of industry risk-models used to target risk and concluded that PHMSA needs more information to effectively assess the performance of pipeline Integrity Management.
Efforts Underway to Effect Continuous Improvement in Pipeline Safety
Motivated by lessons learned, the results of its inspections, multiple major accidents, and recent technical studies, PHMSA took action to improve Integrity Management regulations through two Advanced Notices of Proposed Rulemakings (ANPRM), titled “Safety of On-Shore Hazardous Liquid Pipelines” issued on October 18, 2010, and “Safety of Gas Transmission Pipelines” issued on October 25, 2011. These ANPRMs led to the development of two major Notices of Proposed Rulemakings (NPRMs): the NPRM for Gas Transmission Pipelines was published on March 17, 2016; the NPRM for Hazardous Liquid Pipelines was published on October 1, 2015. Both of these NPRMs involve major improvements to the gas and hazardous liquid Integrity Management programs, the first such overhauls since they were instituted in 2002.
On July 30, 2014, PHMSA proposed revisions to the National Pipeline Mapping System through an Information Collection. The goal of this notice, among other things, is to allow PHMSA access to additional geospatial data that will permit more powerful and accurate analysis, which will, in turn, strengthen PHMSA’s ability to evaluate operator programs and procedures, as well as proposed and existing regulations. The Information Collection will also require more accurate pipeline centerlines. PHMSA received and analyzed several comments as a result of the July 30th proposal. This review resulted in the publication of a second proposal on August 27, 2015 and a public meeting held on September 10, 2015. Comments on the August 27th proposal were due on November 25, 2015. PHMSA will analyze the new set of comments and determine its path forward.
In addition to improving regulations, PHMSA also utilizes non-regulatory activities, which include publishing Advisory Bulletins such as, “Pipeline Safety: Lessons Learned from the Release at Marshall, Michigan” issued on May 6, 2014, to provide safety guidance and remind operators of existing Integrity Management requirements. PHMSA has also driven improvements by updating operator reporting forms to capture better data, and through public awareness and outreach, emergency response training, and by investing in research, development and technology.
Moreover, PHMSA is conducting numerous workshops and webinars to improve knowledge on a variety of pipeline safety topics. Recent workshops include a series on pipeline Safety Management Systems (SMS). This workshop series is part of a collaborative process involving the NTSB, PHMSA, pipeline industries, and other stakeholders. Three workshops have been held to date. Two of the three workshops occurred during the development of the American Petroleum Institute’s new pipeline SMS standard – Recommended Practice 1173 published in July 2015. These workshops reviewed the draft standard and discussed successful aspects of SMS in multiple industries. The third workshop was held on April 22, 2015 and was designed to continue socializing elements of the standard and encourage operators to adopt SMS.
In September 2015, PHMSA held a workshop involving pipeline industries, other industries, and a variety of other stakeholders to share lessons learned on risk modeling approaches applicable to the advancement of risk modeling methodologies for gas transmission and hazardous liquid pipelines. An outcome of the workshop will be the development of pipeline system risk modelling guidance leveraging stakeholder engagement and public comment.
PHMSA is also continually improving pipeline integrity management through its Agency Safety Action Plan (ASAP) which is responsive to the Secretary of Transportation’s challenge to each DOT modal administration to review its safety regime and measure its effectiveness in achieving the highest level of safety for the public. The ASAP strategically targets key areas for safety innovation and improvement, and includes implementation strategies for reviewing oversight of integrity management practices, advancing PHMSA’s and industry’s knowledge of pipeline risks and risk management, and enhancing integrity management inspection and oversight.
The regulatory and non-regulatory efforts outlined above will effect continuous improvement in pipeline safety and the Integrity Management program by:
- Expanding data collection and integration requirements;
- Requiring periodic inspections of pipelines not already covered under the Integrity Management program;
- Requiring operators to improve their knowledge of their own unique systems, including record keeping to help ensure data used in risk management programs is relevant;
- Requiring verification of maximum allowable operating pressures for higher risk pipelines in populated areas;
- Expanding coverage of Integrity Management to a greater portion of the pipeline systems, which will include requiring integrity assessments of a much larger portion of the national pipeline system;
- Improving risk analysis;
- Encouraging more robust operator safety management by helping to socialize a new voluntary safety management system standard;
- Reminding operators of existing Integrity Management requirements through extensive public engagement and Advisory Bulletins; and
- Making available improved guidance on risk modelling approaches.
PHMSA acknowledges the challenges involved in successfully implementing Integrity Management, both for operators and as a regulatory program, but believes that a data-driven, risk-based, safety management program, as required by PHMSA’s Integrity Management program, offers a flexible yet rigorous approach that can continue to deliver continuous safety improvements over time. The agency’s actions are intended to make Integrity Management more effective, while continuing to identify and implement specific measures to inform and mitigate risk. Pipeline operators, as owners of the pipeline infrastructure, are required to know and understand their pipeline system operating requirements. 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.