News media recently reported that the National Transportation Safety Board (NTSB) found continuing systemic weaknesses in gas pipeline safety. What does the NTSB have to say about where improvements are needed?
The NTSB and the gas pipeline integrity management rules
The NTSB is a congressionally-mandated transportation agency that operates independently to conduct objective accident investigations and safety studies, and advocates for implementation of safety recommendations. The NTSB does not conduct investigations of all pipeline incidents; it investigates those in which there is a fatality, substantial property damage, or significant environmental impact. In the past five years, the NTSB investigated three major gas transmission pipeline accidents in which operator and PHMSA oversight deficiencies were identified as concerns, occurring in Palm City, FL (2009), San Bruno, CA (2010), and Sissonville, WV (2012). These three accidents resulted in 8 deaths, over 50 injuries, and 41 homes destroyed with many more damaged.
The five-member NTSB Board held a meeting on Tuesday and soon after released an abstract of their recommendations. [The full study is now available here.] The study focuses on gas transmission pipelines within High Consequence Areas – basically, areas with higher population – and therefore must have in place an integrity management program. Only about 7% of the nearly 300,000 miles of gas transmission pipelines nationwide are required to have an integrity management program, though the industry says many more miles are inspected under integrity management than what the rules require.
The Pipeline and Hazardous Materials Safety Administration (PHMSA) gas pipeline integrity management program rules took effect in 2004. They require, among other things, that the pipeline operators inspect their gas pipelines at least every seven years, and have a program in place to assess risk and ensure their pipelines are safe and reliable. Integrity management rules are performance-based rather than prescriptive, and rely on the operator to have good and complete data that is continually evaluated. Pipeline operator integrity management programs are periodically inspected by PHMSA and/or state regulators to assess compliance. Theoretically, using integrity management, gas pipeline operators should be finding and addressing potential problems before they result in accidents. Clearly, that is not working as evidenced by the accidents mentioned, leading the NTSB to embark on their study.
The NTSB Study
The study highlights shortcomings of the gas transmission integrity management system, and underscores issues the Trust has been bringing up for years. [See our 2012 comments submitted to PHMSA on gas transmission line safety and our 2014 comments to PHMSA on improving the national pipeline mapping system.] The abstract from NTSB states, “there is no evidence that the overall occurrence of gas transmission pipeline incidents in HCA pipelines has declined.” The complexity of the integrity management programs require expertise in multiple technical disciplines from both operator personnel and pipeline inspectors, and PHMSA does not have the resources for guiding them. The thirty-three findings of the study are published in the abstract and are followed by twenty-eight recommendations.
In brief, many things need improvement, including much better geographic information so that inspectors and operators clearly know where pipelines and high consequence areas are, and all data is better integrated; better communication between state inspections lead by the National Association of Pipeline Safety Representatives and PHMSA; better use of in-line inspection tools and improved operation of the same; better threat identification and assessment methods, with PHMSA acting as a guide for pipeline operators and inspectors in this area; and generally stronger, clearer standards and criteria for both operator and inspector programs and personnel to raise the safety bar higher.
We sincerely hope that 2015 will be remembered not for more terrible pipeline accidents, but for safety improvements that are made in part when studies and recommendations like the NTSB’s are heeded.