Pipeline Safety:

Better Data and Guidance Needed to Improve Pipeline Operator Incident Response

GAO-13-168: Published: Jan 23, 2013. Publicly Released: Jan 23, 2013.

Additional Materials:

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Susan A. Fleming
(202) 512-2834
flemings@gao.gov

 

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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.

For more information, contact Susan A. Fleming at (202) 512-2834 or flemings@gao.gov.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: 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 in hazardous liquid and natural gas pipelines, the Pipeline and Hazardous Materials Safety Administration (PHMSA) requires pipeline operators to develop incident response plans. In 2013, GAO reported that PHMSA requires operators of hazardous liquid and natural gas pipelines to respond to incidents in a "prompt and effective manner." However, the agency does not define these terms or collect reliable data on incident response times from operators. GAO had 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. Furthermore, several organizations in the pipeline industry have developed methods for quantitatively evaluating response times to incidents, including setting specific measureable performance goals. For example, one industry association established the goal of responding to incidents within one hour. GAO concluded that 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's current data on incident response times are not reliable both because operators are not required to fill out certain time-related fields in the reporting form and because the meaning of the fields is not well defined. Therefore, GAO recommended that PHMSA improve incident response data and use these data to evaluate whether to implement a performance-based framework for incident response times. In 2017, GAO confirmed that PHMSA had a) implemented changes to the incident reporting software to require time-related fields be filled out, b) published a 30-day notice and requested OMB approval to revise incident reports to collect the time of pipeline valve closure as a consistent measure of incident response time, and c) developed a Valve Closure Performance Measures plan to implement after the receives OMB approval. However, OMB has not provided an anticipated date for approval of the revised form. Given OMB's delayed response, PHMSA has taken all the steps within its power to implement this recommendation while awaiting OMB action. As a result, GAO considers PHMSA's actions responsive to this recommendation. PHMSA's actions will improve its 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.

    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

  2. Status: Closed - Implemented

    Comments: To minimize the risk of leaks and ruptures in hazardous liquid and natural gas pipelines, the Pipeline and Hazardous Materials Safety Administration (PHMSA) requires operators with pipelines in highly populated and environmentally sensitive areas to consider installing automated valves. 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. In 2013, GAO reported that some operators were unaware of existing PHMSA guidance designed to assist operators in making the decision on whether to install automated valves. Several operators GAO spoke with had developed approaches to evaluate the advantages and disadvantages of installing automated valves, but PHMSA did not formally collect or share these evaluation approaches with other operators. 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 GAO spoke with were aware of existing PHMSA guidance designed to assist operators in making these decisions. Therefore, GAO recommended that PHMSA should use the agency'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. In April 2017, GAO confirmed that PHMSA had completed actions in response to this recommendation. Specifically, to improve visibility to operators, PHMSA posted its Enforcement Guidance--which includes information on how to interpret regulations on automated valves and methods of determining whether the installation of an automated valve is necessary--on the enforcement page of PHMSA's website. PHMSA also developed a guidance document titled "Guidance for Strengthening Pipeline Safety Through Rigorous Program Evaluation and Meaningful Metrics" that includes considerations for examining the performance and effectiveness of specific types of equipment, including automated valves. PHMSA notified all operators and the public of the existence of the guidance document in an Advisory Bulletin. Finally, according to PHMSA officials, personnel highlighted these postings in public presentations and forums attended by operators, such as state seminars and pipeline program meetings. According to PHMSA officials, they explored the potential to collect and share approaches used by operators for making decisions on whether to install automated valves; however, PHMSA was not able to accomplish that portion of the recommendation because of privacy concerns from operators. As a result of these actions taken by PHMSA, pipeline operators are better able to identify areas where automated valves could improve their ability to respond to pipeline incidents.

    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

 

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