Pipeline Safety:

Additional Actions Could Improve Federal Use of Data on Pipeline Materials and Corrosion

GAO-17-639: Published: Aug 3, 2017. Publicly Released: Aug 3, 2017.

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Susan Fleming
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FlemingS@gao.gov

 

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What GAO Found

The U.S. gas and hazardous liquid pipeline network is constructed primarily of steel and plastic pipes, both of which offer benefits and limitations that present trade-offs to pipeline operators, as do corrosion prevention technology options. According to data from the Pipeline and Hazardous Materials Safety Administration (PHMSA), over 98 percent of federally regulated pipelines that gather natural gas and other gases and hazardous liquid products, such as oil, and transmit those products across long distances are made of steel. An increasing majority of pipelines that distribute natural gas to homes and businesses are made of plastics. Steel pipelines are manufactured in various grades to accommodate higher operating pressures, but require corrosion protection and cost more than plastics, according to operators and experts. In contrast, plastics and emerging composite materials generally are corrosion-resistant, but lack the strength to accommodate high-operating pressures. Operators use a range of technologies to protect steel pipes from corrosion, including applying coatings and cathodic protection, which applies an electrical current to the pipe. (See fig.) While such technologies are generally considered effective, operators and experts stated that coatings degrade over time and that cathodic protection requires ongoing maintenance and costs to deliver the current over long pipeline distances, among other considerations.

Application and Installation of Pipeline Coating and Cathodic Protection

U:\Work in Process\VCA_Graphics\FY 17\PI\Malika\101017-PI-mr (Hazardous Liquid & Gas Pipeline)\FigAv3_7-101017_mr.tif

PHMSA uses materials and corrosion data collected from operators in its Risk Ranking Index Model to determine the frequency of PHMSA's inspections of operators based on threats, such as ineffective coatings, to pipeline integrity. PHMSA officials said they used professional judgment to develop their model, but did not document key decisions for: (1) the threat factors selected, (2) their associated weights, or (3) the thresholds for high, medium, and low risk tiers for pipeline segments inspected by PHMSA. Moreover, PHMSA has not used data to assess its model's overall effectiveness, as would be consistent with federal management principles. PHMSA officials said they have not established an evaluation process because they consider the model to be effective in prioritizing inspections. Although PHMSA officials said they analyzed the model when they developed it in 2012, they have not done so since that time and did not document the results of this initial analysis. Without documentation and a data-driven evaluation process, PHMSA cannot demonstrate the effectiveness of the model it uses to allocate PHMSA's limited inspection resources.

Why GAO Did This Study

The U.S. energy pipeline network is composed of over 2.7-million miles of pipelines transporting gas and hazardous liquids. While pipelines are a relatively safe mode of transportation, incidents caused by material failures and corrosion may result in fatalities and environmental damage. PHMSA, an agency within the Department of Transportation, inspects pipeline operators and oversees safety regulations.

2016 pipeline safety legislation included a provision for GAO to examine a variety of topics related to pipeline materials and corrosion. This report addresses: (1) the materials and corrosion-prevention technologies used in the pipeline network and their benefits and limitations and (2) how PHMSA uses data on pipelines and corrosion to inform inspection priorities, among other topics. GAO analyzed PHMSA's 2010–2016 data; reviewed PHMSA regulations; and interviewed PHMSA officials and representatives of nine states selected based on pipeline inspection roles, eight pipeline operators—providing a range of sizes, geographic locations, and other factors—and eight stakeholders selected for expertise on pipeline and corrosion issues.

What GAO Recommends

GAO recommends that PHMSA document the design of its Risk Ranking Index Model and implement a process that uses data to periodically assess the model's effectiveness. The Department of Transportation agreed with our recommendation and provided technical comments, which we incorporated as appropriate.

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

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: The U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) inspects pipeline operators and oversees safety regulations for the U.S. natural gas and hazardous liquid pipeline network. In 2017, GAO reported that, PHMSA uses its Risk Ranking Index Model (referred to as RRIM) to prioritize pipelines for inspection and manage its inspection resources. PHMSA uses RRIM to calculate a risk score for each pipeline unit, based on threats to pipeline integrity, such as ineffective coatings. PHMSA then uses this risk score to determine whether the system is assigned to a high, medium, or low risk tier, and inspected at least every 3, 5, or 7 years, respectively. However, while PHMSA officials designed RRIM using their professional judgments, they did not document key decisions and rationale used to the design RRIM. Specifically, in designing RRIM, PHMSA did not document its rationale for the selection of threat factors and their associated weights, or the thresholds for risk tiers and the frequency of inspection associated with each risk tier. Standards for Internal Control in the Federal Government state that documentation is necessary to demonstrate the design, implementation, and operating effectiveness of a program. Without documentation, the rationale for key decisions and assumptions made as part of designing and implementing RRIM is unclear. As a result, GAO recommended that PHMSA document the decisions and underlying assumptions for the design of RRIM, including what data and information were analyzed as part of determining each component of the model. In 2019, GAO confirmed that PHMSA had developed documentation to be used in PHMSA's annual planning process for pipeline inspections. This documentation outlines the decisions and assumptions used to develop RRIM, including the data and information used to determine the model components. By developing this documentation, PHSMA has (1) clarified how it prioritizes pipelines for inspection to ensure that PHMSA's limited inspection resources are assigned based on a clear and data-driven rationale as well as (2) the basis for the design and key decisions of RRIM.

    Recommendation: To assess and validate the effectiveness of PHMSA's Risk Ranking Index Model (RRIM) in prioritizing pipelines for inspection, the Secretary of Transportation should direct the Administrator of PHMSA to document the decisions and underlying assumptions for the design of RRIM, including what data and information were analyzed as part of determining each component of the model, such as the threat factors, weights, risk tiers, and inspection frequency.

    Agency Affected: Department of Transportation

  2. Status: Closed - Implemented

    Comments: The U.S. Department of Transportation's Pipeline and Hazardous Materials Safety Administration (PHMSA) inspects pipeline operators and oversees safety regulations for the U.S. natural gas and hazardous liquid pipeline network. In 2017, GAO reported that, PHMSA uses its Risk Ranking Index Model (RRIM) to prioritize pipelines for inspection and manage its inspection resources. PHMSA uses RRIM to calculate a risk score for each pipeline unit, based on threats to pipeline integrity, such as ineffective coatings. PHMSA then uses this risk score to determine whether the system is assigned to a high, medium, or low risk tier, and inspected at least every 3, 5, or 7 years, respectively. However, PHMSA lacked a process that uses data to assess the ongoing effectiveness of RRIM and validate that it appropriately prioritizes inspections. Leading management practices and principles have highlighted the importance of periodic review and evaluation of risk management approaches. Without a process that uses data to assess the effectiveness of RRIM, PHMSA is unable to demonstrate the validity of RRIM and whether it is effectively prioritizing pipelines for inspection. Moreover, it is unclear how effectively the model has helped PHMSA manage its inspection resources or maximize safety benefits to the public. As a result, GAO recommended that PHMSA establish and implement a process that uses data to periodically review and assess the effectiveness of the model in prioritizing pipelines for inspection and document the results of these analyses. In 2019, GAO confirmed that PHMSA had developed a process to periodically review and assess the effectiveness of the model each year. For example, PHMSA assesses whether inspection systems with higher relative risk were correctly assigned to a higher risk tier and required more frequent inspections. In addition, PHMSA provided documentation of the most recent results of its evaluation, which provided useful information to PHMSA on the effectiveness of each threat factor used in RRIM to assign risk tiers. By taking these steps, PHMSA has increased its assurance that RRIM prioritizes inspections effectively, helping PHMSA make progress toward its goal of becoming a more data-driven and risk-based safety agency.

    Recommendation: To assess and validate the effectiveness of PHMSA's RRIM in prioritizing pipelines for inspection, the Secretary of Transportation should direct the Administrator of PHMSA to establish and implement a process that uses data to periodically review and assess the effectiveness of the model in prioritizing pipelines for inspection and document the results of these analyses.

    Agency Affected: Department of Transportation

 

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