In the 2019-2020 “Most Wanted List” released by the National Transportation Safety Board (NTSB), there is an important recommendation related to integrity management that could affect pipeline operators.
The open recommendation from NTSB to the Pipeline and Hazardous Materials Safety Administration (PHMSA), a division of the Department of Transportation (DOT), requests that operators elevate their integrity management programs using geographic information systems (GIS) and through enhanced data integration.
In summary, Safety Recommendation P-15-022 requests that PHMSA “develop and implement a plan for all segments of the pipeline industry to improve data integration for integrity management through the use of geographic information systems.”
The Facts on This NTSB “Most Wanted List” Item
Safety Recommendation P-15-022 was originally issued in 2015 following a series of incidents that led to concerns about “deficiencies in the operators’ integrity management programs and the oversight of these programs by PHMSA and state regulators.”
The NTSB conducted a study that “identified areas where improvements can be made to further enhance the safety of gas transmission pipelines in HCAs (high-consequence areas).”
One of the specific areas for improvement was “improving data collection and reporting, including geospatial data.”
PHMSA responded to the study by issuing a notice of proposed rulemaking (NPRM) titled “Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines.” DOT requested revisions, then asked for PHMSA to note whether they will determine if additional GIS requirements should be necessary to satisfy the safety recommendation.
P-15-022 is currently open with an “acceptable response” pending publication of a final rule that satisfied the safety recommendation.
Why is Integrity Management Important for Pipeline Operators?
Going back to 2004, pipeline operators have focused on integrity management, as required by PHMSA. The initial focus was to develop and implement programs that ensure the integrity of pipelines in HCAs to reduce the risks associated with pipeline incidents.
The components of a reliable integrity management program include:
- Updated policies and procedures
- Location tracking to identify HCAs
- The ability to determine pipeline threats within HCAs
- Evaluation of the physical integrity of pipe within HCAs
- The ability to repair pipeline defects in a reasonable period of time
That is the baseline, foundational level of integrity management for pipeline operators. However, integrity management is not a sit-and-forget or static process. As captured by the NTSB, this is an “ongoing program” that is inspected by PHMSA and/or state regulatory agencies to ensure compliance with regulations.
The key for pipeline operators is to remain vigilant, build a culture that supports pipeline integrity, define roles and responsibilities, ensure that controllers are supported to achieve situational awareness, use the right tools for inline inspection, utilize technology such as GIS to pinpoint problematic areas, and optimize data collection to create a more reliable responses to pipeline incidents.
How Does Integrity Management Impact the Control Center?
When pipeline integrity issues are identified, a common course of action is to derate the pipe. Meaning, the maximum allowable operating pressure (MAOP) is reduced until the integrity issue is addressed.
Effective communication between the pipeline integrity function and the pipeline control center is key to effective implementation of a pipeline pressure derate.
How Does GIS and Data Integration Support Integrity Management?
The NTSB noted in P15-022 that there are approximately 298,000 miles of onshore natural gas transmission pipelines in the United States. That represents a massive amount of pipe to manage.
If every pipeline operator did their part managing their pipelines with a high-level integrity management program, the industry could collectively approach the ultimate goal of zero incidents. Two tools in the toolbox to help achieve this goal are GIS and data.
Thanks to technological advancements, GIS helps operators more accurately identify problematic areas in their pipelines. GIS can be used to guide inline inspection, help identify risks in HCAs, and locate damage to a specific segment of pipe.
For the pipeline control center, access to GIS and maps can assist in coordination with field operators and can streamline alarm response.
The key to reliable GIS is reliable data integration. For example, when performing inline inspection, the data from a smart pig helps locate problem areas in a pipeline. The data is matched up with the GIS to pinpoint the problematic location.
Once the problem area is identified, the pipeline operator should have procedures in place that specify what actions should be taken. Getting to the end result of taking the appropriate action is the result of integrated GIS and data visibility.
What Action Should Pipeline Operators Take?
As of right now, there is no action to take. Pipeline operators should be aware of what could be coming down the pike in terms of an actual PHMSA requirement that outlines an elevated approach to integrity management.
If you have not reviewed or updated your integrity management program in a period of time, you should consider evaluating the reliability of your program. Additionally, consider taking steps to utilize GIS and enhance your data integration to ensure safe operations.
No one is expecting pipeline operators to implement wholesale changes overnight. It’s about taking a smart approach to gradually improve integrity management to continue driving toward zero incidents.
As recognized by the NTSB in P-15-022, “these procedures and processes are complex and interconnected. Effective implementation of an IM program relies on continual evaluation and data integration.”
The key for operators is to continually evaluate your program, take steps to continually improve, and strive toward safer, more reliable processes.
Work with EnerSys to Support Integrity Management
Our goal is to help pipeline operators take the right steps on their journey to achieve safety and compliance with PHMSA regulations, both in the present and potentially in the future.
From a software standpoint, we offer the ComplyMgr module. This software helps operators maintain the integrity of policies and procedures for the full range of pipeline safety requirements, including control room management and pipeline integrity management.
ComplyMgr ensures that operators follow best practices by tracing procedures to audit protocols, serving as a data repository for relevant documents, and directly linking procedures to federal regulations and industry standards.
We would like to have a conversation with your operation about your integrity management program and the status of your data integration approach using GIS. This will help us better deliver an educational demo of our ComplyMgr software and identify areas where we can come alongside your operation to provide support.
To have a conversation with our team about integrity management and the NTSB “Most Wanted List” recommendation, please contact us through one of three options. Complete our Contact form, email us directly at firstname.lastname@example.org, or call us at 281-598-7100 to talk to a member of our team.