Better Data and Guidance Needed to Improve Pipeline Operator Incident Response
GAO-13-168: Published: Jan 23, 2013. Publicly Released: Jan 23, 2013.
What GAO Found
The Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) has an opportunity to improve the ability of pipeline operators to respond to incidents by developing a performance-based approach for incident response times. The ability of transmission pipeline operators to respond to incidents--such as leaks and ruptures--is affected by numerous variables, some of which are under operators' control. For example, the use of different valve types (manual valves or "automated" valves that can be closed automatically or remotely) and the location of response personnel can affect the amount of time it takes for operators to respond to incidents. Variables outside of operators' control, such as weather conditions, can also influence incident response time, which can range from minutes to days. GAO has previously reported that a performance-based approach--including goals and associated performance measures and targets--can allow those being regulated to determine the most appropriate way to achieve desired outcomes. In addition, several organizations in the pipeline industry have developed methods for quantitatively evaluating response times to incidents, including setting specific, measurable performance goals. While defining performance measures and targets for incident response can be challenging, PHMSA could move toward a performance-based approach by evaluating nationwide data to determine response times for different types of pipeline (based on location, operating pressure, and pipeline diameter, among other factors). However, PHMSA must first improve the data it collects on incident response times. These data are not reliable both because operators are not required to fill out certain time-related fields in the reporting form and because operators told us they interpret these data fields in different ways. Reliable data would improve PHMSA's ability to measure incident response and assist the agency in exploring the feasibility of developing a performance-based approach for improving operator response to pipeline incidents.
The primary advantage of installing automated valves is that operators can respond quickly to isolate the affected pipeline segment and reduce the amount of product released; however, automated valves can have disadvantages, including the potential for accidental closures--which can lead to loss of service to customers or even cause a rupture--and monetary costs. Because the advantages and disadvantages of installing an automated valve are closely related to the specifics of the valve's location, it is appropriate to decide whether to install automated valves on a case-by-case basis. Several operators we spoke with have developed approaches to evaluate the advantages and disadvantages of installing automated valves. For example, some operators of hazardous liquid pipelines use spill-modeling software to estimate the amount of product release and extent of damage that would occur in the event of an incident. While PHMSA conducts a variety of information-sharing activities, the agency does not formally collect or share evaluation approaches used by operators to decide whether to install automated valves. Furthermore, not all operators we spoke with were aware of existing PHMSA guidance designed to assist operators in making these decisions. PHMSA could assist operators in making this decision by formally collecting and sharing evaluation approaches and ensuring operators are aware of existing guidance.
Why GAO Did This Study
The nation's 2.5 million mile network of hazardous liquid and natural gas pipelines includes more than 400,000 miles of "transmission" pipelines, which transport products from processing facilities to communities and large-volume users. To minimize the risk of leaks and ruptures, PHMSA requires pipeline operators to develop incident response plans. Pipeline operators with pipelines in highly populated and environmentally sensitive areas ("high-consequence areas") are also required to consider installing automated valves.
The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 directed GAO to examine the ability of transmission pipeline operators to respond to a product release. Accordingly, GAO examined (1) opportunities to improve the ability of transmission pipeline operators to respond to incidents and (2) the advantages and disadvantages of installing automated valves in high-consequence areas and ways that PHMSA can assist operators in deciding whether to install valves in these areas. GAO examined incident data; conducted a literature review; and interviewed selected operators, industry stakeholders, state pipeline safety offices, and PHMSA officials.
What GAO Recommends
DOT should (1) improve incident response data and use these data to evaluate whether to implement a performance-based framework for incident response times and (2) share guidance and information on evaluation approaches to inform operators decisions. DOT agreed to consider these recommendations.
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Recommendations for Executive Action
Comments: In 2014, OMB approved changes to three PHMSA incident reports - gas distribution (GD), gas transmission and gas gathering (GTGG), and hazardous liquid (HL). In January 2015, PHMSA implemented changes in the incident report data collection software to require the date/time of "operator initial awareness" and "operator arrived onsite" for each report. PHMSA plans to proceed with establishing performance measures for "arrival onsite". PHMSA also plans to measure "isolation time." The GTGG and HL incident report forms collect data about the type of valve used to isolate the incident location, but do not collect the time of valve closures. Later in 2015, PHMSA plans to propose changes to the report forms to collect the time of valve closures isolating the incident location. (Due to the networked nature of GD pipeline systems, valve closure data is not being proposed for the GD incident report.) After OMB approval and a year of GTGG and HL data collection, PHMSA plans to use the data to determine "time to isolation."
Recommendation: To improve operators' incident response times, the Secretary of Transportation should direct the PHMSA Administrator to improve the reliability of incident response data and use these data to evaluate whether to implement a performance-based framework for incident response times.
Agency Affected: Department of Transportation
Comments: PHMSA is addressing this recommendation through a combination of 1) highlighting enforcement guidance and 2) rulemaking. PHMSA publicly posts its enforcement guidance (http://phmsa.dot.gov/foia/e-reading-room) and PHMSA personnel have highlighted these postings in regular public presentations and in other forums attended by operators. There are a number of sections in PHMSA's regulations and enforcement guidance that are relevant to GAO-13-168 including: -49 CFR 192.615(a)(3) and 195.402(e)(2) (Emergency Plans) require operators to establish procedures that provide "prompt and effective response" to emergencies -49 CFR 192.935 (Gas Integrity Management, additional mitigative measures) require operators to conduct a risk analysis to identify additional measures to protect HCAs and enhance public safety such as installing ASVs or RCVs. -49 CFR 195.452 (Hazardous Liquid Pipeline Integrity Management in HCAs) requires an operator to consider the swiftness of leak detection and pipeline shutdown capabilities when determining if an Emergency Flow Restricting Device is needed. PHMSA acknowledges that, in addition to this guidance, a more specific performance-based standard in conjunction with carefully selected prescriptive requirements could be more effective in improving accident response times, particularly when ruptures are involved. Accordingly, PHMSA is developing a valve and rupture detection NPRM and anticipates proposing to require mandatory installation of automatic shutoff valves, remote controlled valves, or equivalent technology and establishing performance based metrics for rupture detection for gas and liquid transmission pipelines. The overall intent is that rupture detection metrics will be integrated with ASV and RCV placement with the objective of improving overall incident response. Rupture response metrics would focus on mitigating large, unsafe, uncontrolled release events that have a greater potential consequence. The areas proposed to be covered include High Consequence Areas (HCA) for hazardous liquids and HCA, Class 3 and 4 for natural gas (including could affect areas).
Recommendation: To assist operators in determining whether to install automated valves, the Secretary of Transportation should direct the PHMSA Administrator to use PHMSA's existing information-sharing mechanisms to alert all pipeline operators of inspection and enforcement guidance that provides additional information on how to interpret regulations on automated valves, and to share approaches used by operators for making decisions on whether to install automated valves.
Agency Affected: Department of Transportation