Pipeline Safety and Security
Improved Workforce Planning and Communication Needed Gao ID: GAO-02-785 August 26, 2002The Office of Pipeline Safety (OPS) is implementing a new approach to overseeing the safety of a 2.2-million-mile network of pipelines in the United States that transports potentially dangerous materials, including hazardous liquids, such as oil and natural gas. OPS has to complete several important steps to implement its integrity management approach within an ambitious, self-imposed schedule. The agency began applying this new regulatory approach to hazardous liquid pipelines in 2000 by issuing final rules requiring operators of these pipelines to develop integrity management programs. While implementing its integrity management approach, OPS must also perform ongoing oversight duties, such as inspecting the construction of new pipelines and investigating pipeline incidents. In addition to meeting its ambitious schedule, OPS faces a number of other challenges in implementing this new regulatory approach. These challenges include (1) enforcing the integrity management requirements consistently and effectively, (2) ensuring that natural gas transmission pipeline operators use assessment methods appropriately, (3) establishing an inspection interval for natural gas transmission pipelines, (4) measuring and reporting on the effectiveness of the approach, and (5) developing and implementing an approach for overseeing pipeline security. OPS's efforts to identify the resources and expertise needed to implement its integrity management approach are hampered by the lack of an up-to-date assessment of current and future staffing and training needs and an examination of the workforce's deployment across the organization--essential elements of a "workforce plan."
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-02-785, Pipeline Safety and Security: Improved Workforce Planning and Communication Needed
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Report to the Ranking Minority Member, Committee on Energy and
Commerce, House of Representatives:
United States General Accounting Office:
GAO:
August 2002:
Pipeline Safety and Security:
Improved Workforce Planning and Communication Needed:
GAO-02-785:
Contents:
Letter:
Results in Brief:
Background:
OPS Has Set an Ambitious Schedule for Implementing Integrity
Management:
OPS Faces Additional Challenges in Implementing the Integrity
Management Approach:
OPS‘s Plan for Obtaining Resources and Expertise Is Not Complete or
Adequately Communicated to State Partners:
OPS Is Taking Action to Improve Data Quality:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Scope and Methodology:
Appendix I: Comments from the U.S. Department of
Transportation:
Tables:
Table 1: Hazardous Liquid and Natural Gas Pipeline Mileage in the
United States:
Table 2: OPS‘s Data Quality Initiatives:
Figure:
Figure 1: Time Line for OPS‘s Implementation of the Integrity
Management Approach:
Abbreviations:
DOT: Department of Transportation
OPS: Office of Pipeline Safety
RSPA: Research and Special Programs Administration:
August 26, 2002:
The Honorable John D. Dingell
Ranking Minority Member
Committee on Energy and Commerce
House of Representatives:
Dear Mr. Dingell:
The Office of Pipeline Safety (OPS), within the Department of
Transportation‘s (DOT) Research and Special Programs Administration
(RSPA), is implementing a new approach to overseeing the safety of a
2.2-million-mile network of pipelines in the United States that
transports potentially dangerous materials, including hazardous
liquids, such as oil, and natural gas. Traditionally, OPS has carried
out its oversight responsibility by issuing minimum safety standards
and enforcing them uniformly across all pipelines. To better focus on
safety risks that are unique to individual pipelines, OPS has been
exploring a risk-based approach to overseeing pipeline safety since the
mid-1990s and is now implementing this approach. This initiative--
termed ’integrity management“--requires pipeline operators, in
addition to meeting minimum safety standards, to develop programs to
assess, evaluate, and mitigate any risks to pipeline segments where a
leak or rupture could have significant consequences, such as near
highly populated areas. To address security concerns after September
11, 2001, OPS advised pipeline operators to consider potential
terrorist threats to their pipelines in their assessments of pipeline
risks. In addition to the integrity management initiative, OPS is
implementing several actions to collect better data on pipeline
incidents in order to improve its oversight of the pipeline industry
and help evaluate the performance of the integrity management approach.
You asked us to examine what OPS has done and plans to do to implement
this new approach, which differs significantly from OPS‘s traditional
oversight activities. Accordingly, we examined OPS‘s (1) steps to
implement the integrity management approach, (2) challenges in
implementing this approach, (3) plans for obtaining the resources and
expertise needed to oversee pipeline safety under integrity management,
and (4) major initiatives to improve the quality of its data on
pipeline incidents.
Results in Brief:
OPS has to complete several important steps to implement its integrity
management approach within an ambitious, self-imposed schedule. The
agency began applying this new regulatory approach to hazardous liquid
pipelines in 2000 by issuing final rules requiring operators of these
pipelines to develop integrity management programs. OPS now plans to
finalize integrity management requirements for natural gas transmission
pipelines and to inspect the programs of more than 1,000 hazardous
liquid and natural gas transmission pipeline operators. Although OPS
may take until 2006 or later to complete these steps, the agency‘s
schedule for the next 2 years is particularly challenging. For example,
OPS plans to:
* issue proposed and final rules to establish requirements for
integrity management programs for natural gas transmission pipeline
operators by spring 2003,
* conduct comprehensive inspections--each of which takes about 2 weeks-
-of the programs for over 200 hazardous liquid pipeline operators from
summer 2002 through fall 2004, and:
* prepare to conduct comprehensive inspections of the programs for
about 830 natural gas transmission pipeline operators from summer 2004
to summer 2006.
While implementing its integrity management approach, OPS must also
perform ongoing oversight duties, such as inspecting the construction
of new pipelines and investigating pipeline incidents. Although OPS
officials believe that the agency can achieve this ambitious schedule
with the assistance of state pipeline safety inspectors, the schedule
leaves little margin for error if OPS is to meet its time frame. For
example, agency officials acknowledge that they have prepared protocols
for comprehensive inspections of hazardous liquid operators under a
tight schedule in order to start these inspections in summer 2002, as
planned.
In addition to meeting its ambitious schedule, OPS faces a number of
other challenges in implementing this new regulatory approach. These
challenges include (1) enforcing the integrity management requirements
consistently and effectively, (2) ensuring that natural gas
transmission pipeline operators use assessment methods appropriately,
(3) establishing an inspection interval for natural gas transmission
pipelines, (4) measuring and reporting on the effectiveness of the
approach, and (5) developing and implementing an approach for
overseeing pipeline security. OPS is pursuing a variety of actions to
address these challenges. For example, the agency has developed
detailed guidance for inspectors to use in reviewing operators‘
integrity management programs to help ensure that enforcement decisions
will be consistent, is preparing a proposed integrity management rule
for natural gas transmission pipelines that will include proposed
requirements on assessment methods and inspection intervals for these
pipelines, and is developing protocols for reviewing operators‘
security programs. However, although some hazardous liquid pipeline
operators have begun to implement their integrity management programs,
OPS has not yet established uniform performance measures for these
programs. OPS officials told us that they intend to establish such
measures, which would allow the agency to track the progress of these
programs in improving pipeline safety, by the end of 2002. OPS also
needs to resolve several issues related to its approach for overseeing
pipeline security. For example, OPS needs to determine how best to use
its own and its state partners‘ resources for carrying out this
oversight because the agency does not anticipate obtaining additional
resources for this purpose.
OPS‘s efforts to identify the resources and expertise needed to
implement its integrity management approach are hampered by the lack of
an up-to-date assessment of current and future staffing and training
needs and an examination of the workforce‘s deployment across the
organization--essential elements of a ’workforce plan.“[Footnote 1]
Although OPS has estimated the number of inspectors it needs to hire to
implement its integrity management approach and has developed a
curriculum to train federal and state inspectors, its resource
estimates are outdated and cover only the initial phases of
implementation. In addition, OPS has not communicated its intentions
for involving its state partners in implementing the integrity
management approach. Although the agency believes it will need to
augment its own resources with those of states to effectively implement
integrity management, OPS officials have acknowledged that the agency‘s
efforts to communicate with state partners have been limited. This
limited communication has left some states unsure of the roles they
will play. OPS is acting to resolve some of these issues, but a
workforce plan--including updated multiyear resource estimates--would
help the agency better plan for future resource needs. Furthermore, a
strategy for communicating with states would help OPS to effectively
involve its state partners in the implementation of the integrity
management approach.
In the past, OPS has experienced a number of problems with the
completeness and accuracy of its data on pipeline incidents, which the
agency uses in overseeing pipeline safety. For example, OPS‘s incident
report forms used a limited number of cause categories--“other“
accounted for about one-fourth of all pipeline incidents--and OPS did
not have a procedure for following up with operators to ensure that
their incident reports included any necessary revisions. OPS is
implementing several initiatives to improve the completeness and
accuracy of its data, which, if effectively implemented, should help
the agency improve its oversight of pipeline safety. For example, OPS
has revised its incident report forms to include more than 3 times as
many cause categories, has assigned inspectors to review forms and
follow up with operators, and has proposed to require an annual report
from hazardous liquid operators. The agency plans to have most of the
initiatives implemented for 2002 data. OPS plans to use the improved
data to, among other things, help develop performance measures for the
integrity management approach, focus its oversight efforts on the
greatest risks to pipeline safety, and prioritize research and
development projects. According to some state and federal government
and industry officials, these initiatives address OPS‘s underlying data
problems and will enable the agency to better understand the causes of
incidents and improve its oversight of pipeline safety.
Although OPS has efforts under way to address several challenges it
faces in implementing its new regulatory approach, the lack of a
workforce plan and strategy for communicating with its state partners
puts it at risk of not being able to overcome these challenges and
effectively implement this approach on schedule. Therefore, we are
recommending that OPS prepare a workforce plan that includes updated
current and future resource estimates and develop a strategy for
clearly communicating with its state partners about the role that they
will play in implementing the integrity management approach. In
commenting on a draft of this report, DOT officials noted that OPS
recognizes the need for workforce planning and improved communication
with the states, as we recommended. They also provided information on
the agency‘s current and planned efforts in these areas. DOT‘s comments
are reprinted in appendix I.
Background:
Pipelines transport about 65 percent of the crude oil and refined oil
products and nearly all of the natural gas in the United States. Table
1 shows the three primary types of pipelines that form a 2.2-million-
mile network across the nation.
Table 1: Hazardous Liquid and Natural Gas Pipeline Mileage in the
United States:
Type of pipeline: Hazardous liquid; Description: Transports crude oil
to refineries and refined oil products, such as gasoline, to product
terminals; Approximate miles in the: 159.
Type of pipeline: Natural gas transmission; Description: Transports
natural gas over long distances from sources to communities;
Approximate miles in the: 325[A].
Type of pipeline: Natural gas distribution; Description: Transports
natural gas throughout the communities to consumers; Approximate miles
in the: 1,850.
[A] This mileage figure includes onshore and offshore transmission
pipelines as well as some gathering lines, which collect natural gas
from producing wells and carry the product to a natural gas
transmission pipeline.
Source: OPS data.
[End of table]
Pipelines are inherently safer than other modes of freight
transportation for hazardous liquids and natural gas. Although an
average of about 24 fatalities resulted from pipeline incidents each
year from 1989 through 2000, this number is relatively low compared
with the number of fatalities from other forms of freight
transportation. On average, about 66 people die each year in barge
incidents, about 590 in railroad incidents, and about 5,100 in truck
incidents. Despite the relative safety of pipelines, pipeline incidents
can have tragic consequences, as evidenced by the pipeline ruptures in
Bellingham, Wash. (1999), and Carlsbad, N. Mex. (2000). These
incidents, which caused 15 fatalities, highlight the importance of
pipeline safety.
OPS develops, issues, and enforces regulations to ensure the safe
transportation of hazardous liquids and natural gas by pipeline. In
fiscal year 2002, OPS employed about 135 people, over half of whom were
pipeline inspectors. In addition, state agencies have roles in pipeline
safety. In general, OPS retains full responsibility for inspecting and
enforcing regulations on interstate pipelines but certifies states to
perform these functions for intrastate pipelines.[Footnote 2] Certified
states are allowed to impose safety requirements for intrastate
pipelines that are stricter than the federal regulations. In 2002, 48
state agencies, the District of Columbia, and Puerto Rico were
certified for intrastate natural gas pipeline inspections, and 13 state
agencies were certified for intrastate hazardous liquid pipeline
inspections. OPS also uses some states to help inspect interstate
pipelines. These states, or ’interstate agents,“ inspect segments of
interstate pipelines within their boundaries. However, OPS handles any
enforcement actions identified through inspections conducted by these
interstate agents. In 2002, 11 states were acting as interstate agents-
-2 states for hazardous liquid pipelines, 5 states for natural gas
pipelines, and 4 states for both types of pipelines. In total, there
are about 400 state pipeline safety inspectors trained to assist OPS in
overseeing pipeline safety within their states.
OPS has traditionally carried out its oversight responsibility by
establishing minimum standards in its regulations and enforcing them
uniformly across pipelines.[Footnote 3] However, this uniform
regulatory approach does not account for differences in the risks faced
by individual pipelines. For example, pipelines located in the Pacific
Northwest states are susceptible to damage from geologic hazards, such
as landslides, but OPS‘s uniform, minimum regulations do not address
this risk.
Recognizing that pipeline operators face different risks depending on
such factors as location and the products they carry, OPS began
exploring the concept of a risk-based approach to pipeline safety in
the mid-1990s. In 1996, the Accountable Pipeline Safety and Partnership
Act included provisions for DOT to establish a demonstration program to
test a risk-based approach.[Footnote 4] As a result, OPS established
the Risk Management Demonstration Program, which went beyond the
agency‘s traditional regulatory approach by allowing individual
companies to identify and focus on the unique risks to their pipelines.
Partly on the basis of OPS‘s experience with the demonstration program,
the agency moved forward with a new regulatory approach--termed
integrity management--to supplement uniform, minimum regulations. In a
May 2000 report, we recognized the potential benefits of a risk-based
approach to pipeline safety; however, we expressed concern that OPS did
not have performance measures in place to demonstrate the effectiveness
of the Risk Management Demonstration Program or the resulting integrity
management approach.[Footnote 5]
The integrity management approach requires individual pipeline
operators to develop programs to systematically identify and address
risks to the segments of their pipelines that could affect ’high
consequence areas“ where a leak or rupture would have the greatest
impact, including highly populated or environmentally sensitive
areas.[Footnote 6] OPS designed the integrity management approach to
achieve greater safety by allowing individual operators flexibility in
tailoring their programs to the characteristics of their pipelines.
This flexibility is reflected in performance-based requirements, which
allow operators to determine the most appropriate processes and
technologies to use in their integrity management programs, subject to
OPS‘s review. For example, operators may use a variety of techniques
for assessing pipeline integrity and analyzing these results and other
available information about the conditions of their pipelines. In
addition, OPS‘s integrity management program requirements include
prescribed elements that provide some consistency among integrity
management programs. For example, OPS requires all hazardous liquid
pipeline operators to conduct a baseline assessment of the integrity of
all pipeline segments that could affect high consequence areas,
periodically reassess the integrity of these pipeline segments, take
prompt action to address any anomalies found during the assessments
that threaten the integrity of the pipeline, and develop measures of
the program‘s effectiveness. After September 11, 2001, OPS advised
pipeline operators also to consider potential terrorist threats to
their pipelines in their assessments of pipeline integrity.[Footnote 7]
OPS Has Set an Ambitious Schedule for Implementing Integrity
Management:
OPS has to complete several important steps to implement its integrity
management approach under an ambitious self-imposed schedule, including
finalizing requirements for integrity management programs and
inspecting the programs of more than 1,000 hazardous liquid and natural
gas transmission pipeline operators. Although it may take OPS until
2006 or later to complete these steps, the agency‘s schedule for the
next 2 years is particularly challenging.
To finalize the requirements for integrity management programs, OPS
plans to issue proposed and final rules establishing these requirements
for natural gas transmission pipeline operators by spring
2003.[Footnote 8] The agency has already issued separate rules
establishing requirements for hazardous liquid pipelines.[Footnote 9]
OPS is issuing separate rules for the different types of pipeline
operators because of differences in the products carried by their
pipelines, the types of risks faced, and the configuration of the
pipelines. For example, hazardous liquid pipelines are more subject to
metal fatigue, which can increase the risk of pipeline failure, than
gas pipelines because they experience a greater number of pressure
cycles. However, hazardous liquid pipelines also tend to be more
uniform in size than natural gas pipelines, which makes it easier for
them to accommodate internal inspection devices to detect corrosion.
These differences have implications for the requirements for integrity
management programs, such as the types of assessment methods that
operators can use to identify risks to their pipelines and the
appropriate intervals between required safety assessments.
OPS chose to issue the rule for operators of large hazardous liquid
pipelines (those with 500 or more miles of pipeline) first because it
needed more information on how integrity management principles should
be applied to smaller hazardous liquid pipelines and natural gas
transmission pipelines. Consequently, OPS issued requirements for
operators of large hazardous liquid pipelines in December 2000 and
similar requirements for operators of small hazardous liquid pipelines
(those with less than 500 miles of pipeline) in January 2002. OPS
anticipates issuing a proposed rule for operators of gas transmission
pipelines by the end of summer 2002 and a final rule in spring 2003.
In addition to completing the requirements, OPS needs to inspect the
integrity management programs developed by more than 1,000 individual
operators of hazardous liquid pipelines and natural gas transmission
pipelines. OPS has developed and begun to implement the following four-
phased approach for reviewing and monitoring the programs for 65
operators of large hazardous liquid pipelines.
* Phase 1: From January through April, 2002, OPS conducted ’quick hit“
inspections of each operator‘s identification of pipeline segments that
could affect high consequence areas to determine if the operator had
correctly identified these segments. OPS also reviewed documents
describing how each operator intends to implement all elements of an
integrity management program to determine whether the operator was
making satisfactory progress in developing a program.
* Phase 2: From August 2002 through November 2004, OPS plans to conduct
’comprehensive“ inspections of each operator‘s more fully developed
integrity management program, including each operator‘s plans for
conducting an initial assessment of the safety of its pipelines. OPS
estimates that each inspection will require about 2 weeks.
* Phase 3: After completing phase 2, OPS plans to monitor operators‘
progress on their programs through periodic inspections. OPS
anticipates that each operator will be inspected at least once every 2
years.
* Phase 4: Concurrently with the other phases, OPS plans to review and
respond to notifications from operators of changes in their
programs.[Footnote 10] For example, an operator is required to notify
OPS if it cannot repair any anomaly that affects the integrity of the
pipeline within the time frame specified in the rule.[Footnote 11]
OPS is conducting and planning a variety of activities aimed at
carrying out these four phases, including developing inspection
protocols and providing training to federal and state inspectors on
conducting the inspections. OPS anticipates using a similar phased
approach to review and monitor the programs for operators of small
hazardous liquid and natural gas transmission pipelines. [Footnote 12]
According to OPS officials, OPS‘s schedule for implementing the
integrity management approach is ambitious and presents a significant
challenge. For the 65 operators of large hazardous liquid pipelines,
OPS plans to conduct all of the comprehensive inspections within 4
years of issuing the final rule requiring integrity management programs
for these operators. If OPS issues the final rule for integrity
management programs for natural gas transmission pipelines in spring
2003, as it anticipates, and follows a similar schedule for conducting
comprehensive inspections, then the agency will not complete
inspections of these pipelines before spring 2006. However, because
there are about 60 more interstate natural gas transmission pipeline
operators than hazardous liquid operators that OPS will need to
inspect, it may take the agency longer to complete these inspections.
During this time frame, OPS also has to perform ongoing oversight
activities, such as conducting standard inspections, investigating
incidents, and inspecting pipeline construction.[Footnote 13] Figure 1
shows a time line for the steps that OPS must complete to implement
integrity management for large and small hazardous liquid pipelines and
gas transmission pipelines.
Figure 1: Time Line for OPS‘s Implementation of the Integrity
Management Approach:
[See PDF for image]
[A] This time frame assumes that OPS will issue the final rule for
integrity management programs for natural gas transmission pipelines in
spring 2003 and will follow a schedule for conducting inspections of
small hazardous liquid and gas transmission operators similar to the
inspections for large hazardous liquid operators.
Source: GAO analysis of information provided by OPS.
[End of figure]
According to OPS officials, the agency is implementing integrity
management under an ambitious time frame because it wants to emphasize
to operators the importance of evaluating and improving the safety of
their pipelines. In addition, OPS‘s integrity management approach
fulfills some long-standing congressional mandates and recommendations
of the National Transportation Safety Board (the Safety Board), and the
agency wants to address concerns about the amount of time it has taken
to fulfill these mandates and recommendations.[Footnote 14] Although
the schedule is ambitious, OPS officials believe the agency can meet
its time frame by hiring additional federal inspectors, using
contractor support, and relying on state pipeline safety inspectors to
conduct integrity management inspections for intrastate pipelines.
However, as shown in figure 1, the next 2 years leave little margin for
error if OPS is to follow its schedule. For example, agency officials
acknowledge that they have prepared protocols and guidance for
comprehensive inspections under a tight time frame in order to meet
their target date for starting these inspections.
OPS Faces Additional Challenges in Implementing the Integrity
Management Approach:
In addition to meeting its ambitious schedule, OPS faces a number of
other challenges in implementing its integrity management approach.
Some challenges--such as enforcing the requirements for integrity
management programs consistently and effectively, and measuring and
reporting on the effectiveness of the integrity management approach--
are more urgent for hazardous liquid pipeline operators because they
have begun implementing their programs. Other challenges--such as
ensuring that operators use pipeline safety assessment methods
appropriately and establishing an inspection interval--have been
addressed in OPS‘s requirements for integrity management programs for
hazardous liquid pipelines and must now be resolved for natural gas
transmission pipelines before OPS can issue a final rule for these
pipelines. In addition, since September 11, 2001, OPS faces the
challenge of developing an approach to overseeing pipeline security,
including how to incorporate security into its integrity management and
standard inspections of pipeline operators.
OPS is taking a variety of actions to address these challenges as
hazardous liquid pipeline operators are implementing their individual
programs. However, in attempting to meet its ambitious schedule for
implementing the integrity management approach for hazardous liquid
pipeline operators, OPS has not yet required these operators to adopt
standardized measures for monitoring the performance of their programs
or to provide the agency with the results of such measures. Agency
officials told us that they intend to establish such requirements by
the end of 2002 and are considering ways to report performance
measurement data to local officials. OPS also needs to resolve several
issues related to its approach for overseeing pipeline security. For
example, OPS will need to determine how best to use its existing
resources, as well as those of its state partners, for carrying out
security oversight because the agency does not anticipate obtaining
additional resources for this purpose.
Enforcing the Integrity Management Requirements Consistently and
Effectively:
In implementing its integrity management approach, OPS faces the
challenge of enforcing compliance with the program‘s flexible
requirements consistently and effectively--a much more difficult task
than enforcing compliance with uniform minimum safety standards, as OPS
has traditionally done. According to representatives of the pipeline
industry, environmental organizations, and states, inspectors will face
difficulties in judging the adequacy of complex integrity management
processes that will vary from company to company. For example, under
the integrity management rules, operators must analyze risks for each
pipeline segment that could affect high consequence areas in order to
identify actions needed to enhance public safety or environmental
protection. Operators may choose from a range of actions, such as
improving leak detection systems or installing shut-off valves to limit
the amount of product released during a leak or rupture, but they must
implement those actions they have identified as necessary. It will be
challenging for inspectors to determine the adequacy of operators‘ risk
analyses because, although the rule specifies some risk factors that
operators should consider, it allows them to choose from a wide variety
of methods for conducting risk analyses. Furthermore, because
inspections will be conducted by five regional offices and 48 state
partners, it will be challenging for OPS to ensure that inspectors make
consistent judgments nationwide.
OPS officials have told us that their main goal in implementing the
integrity management rules is to develop a nationally consistent
approach for inspecting operators‘ integrity management programs. The
agency is taking a number of steps aimed at ensuring consistency,
including:
* completing a set of detailed inspection protocols and guidance
designed to provide clear criteria to inspectors for evaluating the
adequacy of operators‘ actions and making enforcement decisions;
* putting together inspection teams of staff from multiple regions,
including its most experienced inspectors, as well as external experts
and state representatives; and:
* requiring all OPS and state inspectors who will conduct integrity
management inspections to complete a set of relevant training courses.
According to OPS officials, the development and use of detailed
protocols and guidance for conducting integrity management inspections
are their most important means for ensuring the consistency of
inspectors‘ decisions during these inspections. OPS has developed an
initial set of protocols and guidance for the comprehensive inspections
of operators of large hazardous liquid pipelines. The agency plans to
pilot test the use of these protocols in its first five comprehensive
inspections, which are scheduled for August through October, 2002. The
agency intends to make necessary adjustments to the protocols and
guidance on the basis of this pilot testing and to revise them
periodically afterward on the basis of further experience with its
inspections.
OPS, according to some environmental organization representatives, may
face particular difficulties in enforcing its integrity management
rules because operators may disagree with enforcement actions
pertaining to flexible requirements in the rules.[Footnote 15] OPS
officials told us that they intend to vigorously enforce the integrity
management rules, levying fines for serious violations, to ensure that
operators comply with the requirements. After conducting 40 quick hit
inspections of hazardous liquid pipeline operators, the agency has
decided to take enforcement actions in 36 cases. OPS anticipates that
about half of these actions will be notices of amendment and the other
half will be notices of probable violation. Notices of amendment cite
inadequate operator procedures and require operators to make needed
improvements. Notices of probable violation generally contain a
proposed compliance order requiring companies to take action to correct
the violations found and may propose fines.
According to OPS officials, the agency anticipates that many operators
will question integrity management enforcement actions, but it has
prepared for this challenge by increasing its enforcement staff. It
also plans to establish a new Enforcement Office, which will formulate
enforcement policies and review enforcement actions to ensure
consistency, and it plans to provide more training on enforcement
issues for inspector and enforcement staff. OPS officials have stressed
that they have been under tight time frames in developing an inspection
and enforcement approach for large hazardous liquid pipelines and that
this approach will evolve over time, as the agency implements the
approach for small liquid and gas transmission pipelines.
Ensuring That Natural Gas Pipeline Operators Use Assessment Methods
Appropriately:
Because the methods typically used for assessing the integrity of
hazardous liquid pipelines are either not currently suitable for a
large portion of natural gas pipelines or would interrupt the supply of
gas to customers, OPS faces the challenge of ensuring that natural gas
transmission pipeline operators use alternative assessment methods
appropriately. Integrity management programs for hazardous liquid
pipeline companies allow the use of two primary assessment methods: (1)
internal inspection devices, or ’smart pigs,“ that run inside the
pipeline to detect anomalies, such as corrosion, metal loss, or damage
to the pipeline, and (2) hydrostatic testing, a process of draining the
pipeline, filling it with water, and increasing the pressure of the
water to test the strength of the pipeline. Both methods have limited
applications for testing natural gas transmission pipelines.
Specifically, one industry association estimates that smart pigs cannot
move through about half of gas transmission pipeline mileage because of
such pipeline features as variations in diameter, sharp bends, and
valves that do not fully open. Hydrostatic testing, which interrupts
the supply of natural gas to consumers for up to 3 weeks per test, may
leave communities without an energy source because natural gas
transmission pipelines have minimal storage facilities.[Footnote 16]
Although integrity management programs for hazardous liquid pipeline
operators allow the use of alternative safety assessment methods, they
also specify that any other method must provide an equivalent level of
protection and that operators must notify OPS before conducting the
assessment.[Footnote 17]
As an alternative to smart pigs and hydrostatic testing, OPS is
considering allowing gas transmission pipeline operators to use a
method called ’direct assessment“ to assess the integrity of their
pipelines. Direct assessment consists of four steps:
* Preassessment. The pipeline operator analyzes information about the
physical characteristics of the pipeline--such as the coating material,
soil moisture, and past leaks--to determine whether direct assessment
is appropriate, what threats are likely to be present and significant,
where these threats are likely to occur, and what tools should be used
to inspect the areas of the ground above the pipeline where the threats
are likely to occur.
* Indirect inspections. The operator uses one or more inspection tools
to examine the pipeline through the soil in areas identified during the
preassessment. For example, to identify corrosion on the exterior
surface of a pipeline, an operator walks over the areas of the pipeline
holding a tool that takes readings through the soil to assess the
condition of the pipeline‘s surface. Separate passes over the pipeline
with two or more different types of tools are generally required to get
an accurate assessment.
* Direct examinations. Using the results of the aboveground
examination, the operator digs holes at intervals along the pipeline to
examine suspected problem areas. After the holes have been dug, the
pipeline can be examined visually and with diagnostic equipment, such
as tools that measure the thickness of the pipe, to determine whether
the operator needs to repair the pipeline or take other corrective
action. For safety reasons, the pressure of the natural gas within the
pipeline is generally reduced by about 25 percent during this step.
* Postassessment. The operator integrates and analyzes the information
gathered during the three previous steps to determine whether
additional excavations are necessary and how often pipeline segments
should be reassessed.
Like other assessment methods, direct assessment has some limitations.
For example, direct assessment has been proven reliable in detecting
only one threat to the integrity of pipelines--external corrosion--
while smart pigs can identify a wide range of threats to the integrity
of pipelines, such as external corrosion, internal corrosion, and metal
loss from external damage.[Footnote 18] State pipeline safety officials
and some natural gas pipeline company representatives we spoke with are
concerned about the limitations of direct assessment and believe that
its use should be closely monitored. For example, the Texas Railroad
Commission‘s pipeline safety section requires intrastate pipeline
operators to obtain approval from the office if they plan to use direct
assessment to assess the safety of their pipelines.[Footnote 19] To
obtain approval, the operators must present evidence at a hearing that
this method is a valid choice for the circumstances of the pipeline and
receive approval from the commission.
OPS officials explained that the agency has ongoing research activities
focused on advancing the state of the art of direct assessment
technology. Agency officials expect to issue a proposed rule by the end
of this summer for integrity management requirements for natural gas
transmission pipeline operators, which will address how direct
assessment should be treated as an assessment method.
Establishing an Inspection Interval for Gas Pipelines:
Establishing an appropriate interval between the safety inspections
that operators are required to make of gas pipelines is likely to be a
complex and controversial challenge for OPS because the agency must
strike a balance between the existing industry standards, which allow
intervals of up to 20 years, and shorter intervals. Although the
appropriate interval for individual pipelines could vary with their
circumstances, OPS is including a maximum interval in the requirements
for integrity management programs to ensure that all operators conduct
their inspections within a reasonable time frame. For hazardous liquid
pipelines, OPS requires inspections at least once every 5
years.[Footnote 20] For natural gas transmission pipelines, longer
intervals could be justified for several reasons:
* Pressure fluctuations, which can weaken a pipeline, are less
frequent.
* Thicker pipeline walls or operation at lower pressure is already
required in high consequence areas[Footnote 21] under the existing
uniform requirements.
* Internal corrosion is less likely because natural gas contains a
minimal amount of moisture.
* Fewer storage facilities exist, therefore, interrupting the flow of
gas to conduct inspections of the pipeline would have a greater impact
on customers.
Because of these differences, the industry standards for natural gas
pipeline integrity management programs (published by the American
Society of Mechanical Engineers) allow maximum inspection intervals
from 5 years to 20 years, depending on the type of assessment method
and test procedures used and the operating pressure of the
pipeline.[Footnote 22] For higher pressures, the maximum interval is 5
years for less stringent methods and procedures (e.g., using direct
assessment and excavating a sample of potential problem areas) or 10
years for more stringent methods and procedures (e.g., using direct
assessment and excavating all problem areas). For lower pressures, the
maximum interval is 20 years using any type of assessment method and
the most stringent test procedures.
According to some pipeline industry and environmental group
representatives, the maximum inspection interval for natural gas
transmission pipelines should be limited to between 5 and 10 years to
allow for a ’worst-case“ scenario. However, industry representatives
noted that longer inspection intervals could be justified more for
natural gas pipelines than for hazardous liquid pipelines, given the
differences in their characteristics. For example, they cited the
greater possibility of damage to liquid pipelines from pressure
fluctuations and internal corrosion and noted that external corrosion
can threaten both types of pipelines. One natural gas transmission
pipeline operator told us that it would take 12 years for a worst
possible case of external corrosion to damage a pipeline enough to
cause a failure. According to this operator, a 10-year inspection
interval would allow time for pipeline operators to detect and repair
such a worst case before it resulted in an incident.
OPS is trying to achieve a balance between these arguments as it
prepares the proposed rule on integrity management for gas transmission
pipelines. For the proposed rule, OPS is considering a maximum
inspection interval of 5 or more years for pipelines assessed by direct
assessment and 10 years for pipelines inspected by smart pigs or
hydrostatically tested. For pipelines that operate at lower pressure,
OPS is considering allowing inspection intervals that are longer than
10 years.
Measuring and Reporting on the Effectiveness of the Integrity
Management Approach:
OPS faces the challenge of establishing performance measures to
determine the overall effectiveness of the integrity management
approach and monitor the progress of individual operators‘ programs.
Such performance measures would assist in determining the impact of the
integrity management approach on pipeline safety and identifying needed
improvements. OPS officials told us that the agency has identified some
performance measures for integrity management, intends to require
operators to report the results of these measures to the agency, and is
considering ways to report performance measurement information to local
officials and the public.
According to OPS officials, the agency has developed measures of the
overall effectiveness of the integrity management approach on the basis
of its data on pipeline leak and rupture incidents and will start
publicly reporting these measures by early 2003.[Footnote 23] Some
recent improvements in OPS‘s incident data, such as new requirements
for operators to report on whether incidents occurred in high
consequence areas, should allow OPS to use these data to measure the
overall performance of the integrity management approach in reducing
incidents in these areas.[Footnote 24] (OPS‘s efforts to improve these
data are discussed later in this report.) For example, the agency
intends to measure the effectiveness of integrity management by
tracking reductions in the number of significant pipeline incidents and
in the volume of oil spilled in high consequence areas. However,
because operators of large hazardous liquid pipelines did not begin
implementing their integrity management programs until 2002 and other
types of pipeline operators will not begin implementing their programs
until subsequent years, it will be some time before OPS can analyze
trends and determine the impact of the integrity management approach on
safety.
OPS also intends to develop new requirements for operators to report
uniform performance measures for their individual integrity management
programs. OPS‘s current integrity management rules for hazardous liquid
pipelines require operators to develop performance measures for their
programs, but the rules do not specify what measures they should use.
As a result, these measures will not be consistent, and therefore OPS
will not be able to use these data to develop industrywide measures or
to compare the performance of operators. OPS and industry officials
have told us that the development of consistent performance measures
for operator integrity management programs has been difficult because
of a lack of agreement on which measures can be standardized. OPS
officials have recently worked with both the hazardous liquid and gas
transmission pipeline industries to identify performance measures for
integrity management programs that can be standardized, such as the
numbers of integrity assessments conducted and repairs completed. OPS
intends to modify its integrity management requirements for liquid
pipeline operators by the end of 2002 to include a requirement that
operators adopt these standardized measures and make the results of
these measures available to OPS.[Footnote 25] Until these operators
start providing such standardized data to OPS, the agency‘s ability to
monitor and compare the performance of operators‘ integrity management
programs, some of which began in spring 2002, will be limited. The
agency also intends to include similar requirements for gas
transmission pipeline operators in the proposed and final integrity
management rules for these pipelines, anticipated by spring 2003. OPS
intends to require that hazardous liquid as well as natural gas
transmission operators start making these standardized performance
measurement data available to the agency in 2004.[Footnote 26]
Although OPS intends to make industrywide measures on the effectiveness
of the integrity management approach available on its Web site and in
public reports, the agency has not yet determined what measures of
individual operators‘ performance will be made publicly available or
how this information will be communicated. The Safety Board and some
public interest organizations have recommended that pipeline operators
provide more information to the public about their safety operations.
In response, the hazardous liquid and gas transmission pipeline
industries, with the encouragement of OPS, are developing joint
guidelines for operators on communicating safety information about
their pipelines to the public and expect to finalize these guidelines
by the end of 2002. At that time, OPS plans to consider whether to
adopt all or part of these guidelines as regulations. However, the
guidelines will not address what information operators should provide
to state and local officials and the public about their integrity
management programs. The liquid and gas pipeline industries intend to
develop additional guidelines on this issue after finalizing their
initial guidelines, and OPS plans to consider incorporating these
additional guidelines as requirements after they are finalized. In
addition to this industry initiative, OPS is currently considering
alternatives for reporting information on the performance of individual
operators‘ integrity management programs. Because operators want to
protect information that may pose a security risk if publicly
distributed, OPS officials have told us that they are considering
developing a system that would make information on individual
operators‘ performance available to local officials who need it, but
not to the general public.
Developing and Implementing an Approach for Overseeing Pipeline
Security:
Since September 11, 2001, OPS has faced the challenge of ensuring that
operators are taking appropriate actions to protect their pipeline
systems from acts of terrorism.[Footnote 27] To address this challenge,
OPS has been developing an approach for overseeing pipeline security
that does not involve the development of new regulatory requirements.
Under this approach, OPS and state inspectors will review operators‘
pipeline security programs to determine whether they follow guidelines
developed by the pipeline industry with OPS‘s participation and review.
The agency intends to conduct these reviews as part of its
comprehensive inspections of integrity management programs as well as
its ongoing standard inspections of pipelines.[Footnote 28] These
reviews will focus on how operators are managing security risks at
critical facilities, because the agency will expect operators to have
more rigorous security practices in place at these facilities.[Footnote
29] OPS is developing protocols for conducting these security reviews,
but it still needs to resolve several issues to fully develop and
implement its security oversight approach.[Footnote 30]
Currently, OPS‘s regulations have few specific requirements pertaining
to security. The agency has decided not to develop new security
regulations because it believes that progress can be achieved more
quickly by encouraging companies to voluntarily improve their security
practices following industry guidelines. In addition, OPS officials are
concerned that the inherent openness of the rulemaking process would
require the agency to publish sensitive information, such as
definitions of critical facilities and specific protective measures.
Furthermore, RSPA‘s Office of the Chief Counsel has determined that OPS
currently has enough statutory and regulatory authority to take
enforcement actions if it finds that security at a critical pipeline
facility is inadequate. Industry representatives told us that they
prefer a nonregulatory approach, citing concerns about the need for
flexibility in designing security programs suitable for each facility.
However, some state pipeline safety officials, as well as some Members
of Congress, have suggested that new security regulations may be needed
to ensure that operators improve their security programs and practices.
Legislation has been proposed that would require DOT to prescribe
standards for pipeline security programs and approve or disapprove each
operator‘s program on the basis of their adherence to these
standards.[Footnote 31]
Before fully implementing its security oversight approach, OPS must
reach agreement with pipeline operators on certain aspects of its
security reviews, including the identification of critical pipeline
facilities.[Footnote 32] A representative of the hazardous liquid
pipeline industry told us that pipeline companies are concerned about
this issue because of the cost of increased security at critical
facilities, particularly if higher threat levels are declared. OPS has
worked with the pipeline industry to develop guidance on how to
determine which pipeline facilities are critical and what protective
measures need to be taken at these facilities for various threat
levels.[Footnote 33] According to OPS officials, during security
reviews of individual operators, OPS and state inspectors will review
whether each operator has appropriately applied this guidance to its
facilities. OPS must also reach agreement with the pipeline industry on
what sensitive company security information inspectors will need to
examine when reviewing pipeline security programs. Industry
representatives have told us that operators are reluctant to share such
information with OPS because the agency may not be able to prevent its
public disclosure under the Freedom of Information Act.[Footnote 34]
OPS officials have told us that they will try to address such concerns
by having inspectors review sensitive documents on-site and take with
them only those documents they need.
OPS will also need to determine how best to deploy its existing
resources as well as those of its state partners for carrying out
pipeline security oversight, because it does not anticipate obtaining
additional resources for this purpose. This effort will involve
determining the role of state inspectors in conducting security reviews
and identifying the training that OPS and state inspectors will need to
conduct these reviews. OPS officials have told us that states will play
a key role in conducting these reviews, but some state pipeline safety
officials have told us that they have not received clear guidance from
OPS on their role in security oversight. One official noted that states
have very limited resources and would need additional staff to conduct
security reviews of pipeline operators. Furthermore, several state
officials emphasized to us that their inspectors would need security-
related training to be able to conduct security reviews of pipeline
operators. However, according to an official of the Transportation
Safety Institute, which trains OPS and state inspectors, the institute
has not yet developed such training for these inspectors.
OPS officials have told us that the agency‘s next step in developing
its security oversight approach is to communicate with its state
partners regarding their role in implementing this approach. The agency
intends to work with states in refining its protocols for security
reviews and in developing security-related training for OPS and state
inspectors. However, the lack of a workforce plan and a strategy for
communicating with its state partners, as discussed in the next section
of this report, may hamper OPS‘s ability to ensure that it has the
resources and expertise it needs to oversee pipeline security and that
it is effectively involving states in this effort.
OPS‘s Plan for Obtaining Resources and Expertise Is Not Complete or
Adequately Communicated to State Partners:
OPS‘s efforts to ensure it has the resources and expertise needed to
implement its integrity management approach are hampered by the lack of
an up-to-date assessment of current and future staffing and training
needs and an examination of the workforce‘s deployment across the
organization--essential elements of a workforce plan.[Footnote 35]
Although OPS has estimated the number of inspectors it needs to hire to
implement its integrity management approach and has developed a
curriculum to train federal and state inspectors, the agency has not
prepared a workforce plan--an important component of successful human
capital management. Furthermore, the resource estimates are outdated
and cover only the initial phases of implementation. Also, although OPS
says it will need to augment its own resources with those of states to
implement integrity management, the agency has acknowledged that its
efforts to communicate with states about their role in integrity
management have been limited. This limited communication has left some
states uncertain of their role and uncertain about whether they will be
prepared to carry out their expected responsibilities under OPS‘s
integrity management approach. OPS has several initiatives that may
address some of these issues, such as using teams of inspectors and
developing inspection protocols and guidance, but no initiative to
estimate its long-term resource needs. Finally, while the agency
intends to hold some discussions with states about their role in
integrity management, it lacks a strategy for communicating how it will
involve states in implementing this new regulatory approach.
OPS Lacks a Workforce Plan:
OPS is hampered in its efforts to ensure that it has the resources and
expertise to successfully implement its integrity management approach
by the lack of a workforce plan. By workforce planning, we mean the
short-and long-term strategies to identify OPS‘s current and future
staffing needs; the appropriate workforce deployment across the agency;
the knowledge, skills, and abilities needed for staff to implement
integrity management; and the training to fulfill these needs. OPS has
estimated that it needs to hire 28 inspectors by fiscal year 2003, an
increase of 50 percent from fiscal year 2001, to inspect approximately
1,000 individual integrity management programs for hazardous liquid and
gas transmission operators. This estimate is in addition to the
approximately 100 of about 400 state inspectors that OPS plans to train
and use to assist with inspecting integrity management programs,
although some states may need to hire additional inspectors. OPS based
these estimates on the proposed integrity management rule for operators
of large liquid pipelines. However, OPS made several significant
changes between the proposed and final rules but did not adjust its
estimates to account for these changes.[Footnote 36] The following are
examples of the outdated and incomplete components of OPS‘s resource
estimates:[Footnote 37]
* OPS added inspections to its implementation process. The agency based
its resource estimates on the assumption that inspectors would perform
one inspection but has since revised its procedures to include two
different inspections. This change should have increased the original
resource estimates.
* Resource estimates cover only the first two phases of a four-phase
implementation process. According to OPS officials, their ultimate goal
is to hire enough inspectors to carry out the third and fourth phases-
-conducting inspections every 2 years and responding to notifications
from operators of changes in integrity management programs. However,
OPS has not determined its resource needs for the third and fourth
phases.
According to OPS officials, they informally updated their resource
estimates for integrity management for each fiscal year budget request
but did not document the changes.
Furthermore, OPS does not have an agencywide estimate of the resources
it needs to maintain its entire range of pipeline safety oversight
activities. In addition to the new integrity management inspection
responsibilities, OPS must still conduct its standard inspections.
However, OPS could not tell us how the coordination of time and
resources for all types of inspections will take place. Because OPS has
not created a workforce plan, it is unclear how the implementation of
its integrity management approach will affect the resources it needs to
fulfill other obligations.
Another important element of a workforce plan is training. OPS has
developed a training curriculum designed to prepare state and federal
inspectors for successfully implementing the integrity management
approach. The agency is working with the Transportation Safety
Institute to design and teach several new training courses specifically
on OPS‘s hazardous liquid integrity management approach. OPS
anticipates that about 180 inspectors (80 federal and 100 state) will
complete the training by spring of 2003. The training involves
classroom courses and on-the-job training. The classroom training
involves eight core classes, which have already been taken by most
state and federal inspectors, and an additional seven classes
specifically designed for integrity management. The additional classes
cover such issues as the requirements and basic concepts of using smart
pigs to assess the integrity of pipelines and integrity management
program inspection and compliance requirements. For on-the-job
training, OPS is using a ’team approach“ to conduct integrity
management inspections, in which trainees will attend inspections led
by OPS‘s senior inspectors who have been involved in all phases of
implementing the integrity management approach. Each team will consist
of staff from multiple regions, including its most experienced
inspectors and inspectors-in-training, as well as external experts.
Starting in August 2002, when OPS will begin its comprehensive
inspections of hazardous liquid operators, state representatives will
also be included in these teams. This approach will allow senior
inspectors to serve as mentors to the trainees, provide on-the-job
training, and help inspectors make the transition to this new approach.
When OPS finalizes the rule on the gas transmission integrity
management requirements, inspectors will require additional training.
OPS‘s training may help ensure that inspectors have the technical
expertise to conduct integrity management inspections, but making the
transition to this new approach may present a challenge for some
inspectors. Pipeline operators, industry associations, environmental
organizations, and OPS officials acknowledge that the integrity
management approach represents a fundamental shift in how OPS oversees
the pipeline industry. Federal and state inspectors that are accustomed
to following an approach for inspecting pipelines for compliance with
uniform standards will now have to evaluate programs that are unique to
individual operators. One OPS regional office official stated that this
new approach ’will require a different thought process,“ and that not
making the transition adequately could result in inconsistent
inspections between OPS regions and states. However, according to OPS
headquarters officials, the agency‘s detailed inspection protocols and
guidance as well as inspector training will help ensure that integrity
management inspections are conducted consistently.
OPS Has Not Adequately Communicated Its Plans to State Partners:
OPS officials told us that they will use the assistance of state
pipeline safety inspectors to achieve their ambitious schedule for
inspecting the integrity management programs of pipeline operators, but
OPS has had only limited communications with its state partners about
their role in implementing integrity management. This limited
communication could result in states not being adequately prepared to
meet the demands of the integrity management approach. State pipeline
safety inspectors are an invaluable resource for OPS because they are
familiar with pipeline safety issues unique to their states and can
improve safety by increasing the frequency and thoroughness of
inspections of pipeline operators. OPS plans to leverage federal and
states‘ resources to inspect the integrity management programs of more
than 1,000 hazardous liquid and gas transmission operators. For
example, states will be primarily responsible for inspecting the
programs of an estimated 156 intrastate hazardous liquid and 520
intrastate gas transmission operators.
Despite the important role of the states, state pipeline officials we
spoke with said that they have had little to no communication with OPS
about how states will be involved in integrity management inspections.
For example, one state‘s officials assumed OPS would contact them to
participate in the quick hit inspection, but these officials did not
know that states were being excluded from these inspections. OPS did
not allow state inspectors to participate in the quick hit inspections
because the agency felt it would be too difficult to coordinate the
inspections within its self-imposed time frame.[Footnote 38] OPS‘s
apparent lack of communication with states leaves some states unsure if
they will have the resources and expertise to meet the demands of the
integrity management initiative. State officials told us that they are
unsure how many of their inspectors will be trained by OPS over the
next few years, and that they do not know enough about OPS‘s integrity
management approach to determine whether they need to change some of
their own in-house training, hire more inspectors, or both. One state‘s
officials said that, because OPS has not provided any information to
their state, they could only speculate about states‘ roles under the
published final rule and could not justify requests for additional
resources in preparation for the new integrity management approach.
Another state official said that, given the availability of training in
the past, it could take about 10 years to train just that state‘s
inspectors. When we raised this concern to OPS officials, they
responded that the agency has changed its training schedule and will be
capable of training more people.
Although OPS has described its relationship with its state partners as
an important component of the integrity management program, OPS
officials acknowledge that in their initial phase of implementing
integrity management, they have not focused on communicating with
states regarding their plans for implementing the new approach. The
officials explained that they have delayed communicating this
information to states because states were not involved in the first
phase of implementation, which included quick hit inspections of
hazardous liquid operators. OPS officials further noted that since
September 11, 2001, their communications with states have focused on
security-related issues. (However, as previously described, some state
pipeline safety officials told us that they have not received clear
guidance from OPS on their role in security oversight.) According to
agency officials, they are starting to contact states that will be
involved in their first comprehensive inspections of hazardous liquid
operators, scheduled to begin in August 2002, and will communicate
further with states about their role in integrity management as these
inspections continue. In addition, OPS officials explained that the
agency plans to hold an annual meeting with states in September 2002
and a planning exercise with states in January 2003; both of these
events will provide opportunities for OPS to communicate with states
about their role in the integrity management initiative. However, these
annual meetings do not address the need for OPS to formally communicate
with states throughout the implementation process in order to
effectively coordinate the use of both federal and state inspectors.
OPS Is Taking Action to Improve Data Quality:
Obtaining complete and accurate data on reportable pipeline incidents
is important to OPS for monitoring operators‘ safety performance,
identifying safety trends, and planning future initiatives. Under the
integrity management approach, useful and reliable data are also
important, because OPS is using its data to, among other things,
measure the effectiveness of this approach in improving pipeline
safety. According to a joint government and industry task force report
on hazardous liquids,[Footnote 39] complete and accurate information on
pipeline incidents is essential for the successful implementation of a
risk management system.
In the past, we, the Safety Board, DOT‘s Office of the Inspector
General, and others have identified problems with the completeness and
accuracy of OPS‘s data. For example, as we testified earlier this year,
OPS‘s former incident report forms included so few cause categories
(seven or fewer, depending on the form) that about one-fourth of all
pipeline incidents were attributed to ’other“ causes--a category too
broad for useful analysis. In addition, OPS‘s incident forms did not
provide for collecting data on hazardous liquid spills of less than 50
barrels or for measuring the total impact of an incident, particularly
its damage costs. In addition, OPS did not require liquid pipeline
operators to submit data on the characteristics of their pipeline
infrastructure (e.g., age or size), which it needed to analyze trends
and compare the operators‘ safety performance, nor did it collect
complete data from natural gas pipeline operators. Finally, OPS did not
have a procedure for following up with operators to ensure that their
incident reports included any necessary revisions.
To improve the completeness and accuracy of its data, OPS is
undertaking several initiatives, most of which it plans to have
implemented for the collection of 2002 data. To more accurately
determine the causes of incidents, OPS revised its incident report
forms in 2001 and early 2002 for natural gas transmission and hazardous
liquid incidents, respectively, to include 25 categories of causes. The
agency plans to revise the form for natural gas distribution incidents
by the end of 2002. The revised forms for hazardous liquid operators
also require these operators to report spills of 5 gallons or more
(instead of 50 barrels or more) and to provide more complete
information on the total costs of an incident. To enable it to better
analyze trends and compare operators‘ performance, OPS revised its
annual report forms for natural gas transmission pipeline operators for
2001 data and intends to revise these forms for natural gas
distribution pipeline operators for 2002 data. In July 2002, the agency
proposed instituting annual reports for liquid pipeline operators for
2002 data. To ensure that operators complete incident reports in an
accurate and timely manner, OPS has assigned an inspector in each
region to review incident report forms for completeness and accuracy.
It has also instituted new electronic notification procedures to ensure
that operators submit revised incident reports, if necessary. These and
other major data improvement initiatives are summarized in table 2.
Table 2: OPS‘s Data Quality Initiatives:
Data problem: Data provided on incident reports were not complete or
accurate.; Initiative: Revise incident report forms to include more
cause categories, a wider range of hazardous liquid spills, and more
information on total costs of an incident; revised forms also use
electronic notification procedures to ensure completeness.; ; Inspector
in each region will be responsible for regularly reviewing incident
reports for relevance, completeness, and accuracy.; Status of
initiative:
Gas transmission and hazardous liquid forms revised in 2001 and early
2002
for 2002 data.; ; Revision of gas distribution form expected to be
completed
by the end of 2002 and usable to collect 2003 data.; ; Existing staff
will
be used in 2002 to review incident reports while new inspectors are
being
hired and trained.
Data problem: Data to analyze trends and compare operators‘ performance
were not sufficient.; Initiative: Revise existing annual report forms
for natural gas pipeline operators to require more information (e.g.,
pipeline mileage, age, and type).; ; Institute annual reports for
hazardous liquid pipeline operators.; Status of initiative: Form for
natural gas transmission annual report revised in 2001 for 2001
report.; ; Form for natural gas distribution annual report expected to
be revised by the end of 2002, in time to collect data for 2002
report.; ; New form for hazardous liquid annual report expected to be
finalized in 2002, in time to collect data for 2002 report.
Data problem: OPS staff made errors entering data from operators‘
reports into OPS‘s database.; Initiative: Have operators file reports
electronically to eliminate errors and expedite filing.; Status of
initiative: Direct electronic filing by operators began in January
2002.
Data problem: States collect data in different formats, limiting OPS‘s
ability to compare and consolidate data from different states.;
Initiative: Establish a team to develop uniform data elements and
reporting procedures.; Status of initiative: Completion expected by the
end of 2003.
Data problem: OPS lacks complete understanding of the causes of
incidents, which is needed to focus oversight efforts on the greatest
risks.; Initiative: Hire contractors to analyze incident causes--focus
in 2002 is on the consequences of incidents on gathering lines and the
benefits of increasing the regulation of gathering lines.; Status of
initiative: Contractors to provide reports by the end of 2002 and on a
regular basis thereafter.
Source: GAO analysis of information provided by OPS.
[End of table]
According to OPS officials, OPS plans to use the data that it collects
to, among other things, help measure the effectiveness of its integrity
management approach, focus its oversight efforts on the greatest risks
to pipeline safety, and prioritize research and development projects.
One performance measure that OPS plans to develop using the new
incident report forms is the number of high consequence areas affected
by pipeline incidents. This number should decrease over time as
operators focus their efforts on these areas through their integrity
management programs. To focus its oversight efforts on the greatest
risks, OPS plans to analyze the improved data on incident causes to
better understand the greatest safety risks and deploy staff
accordingly to address these risks. OPS also plans to use the data on
incident causes to identify the research and development projects that
are most critical to improving pipeline safety.
Although OPS‘s initiatives appear to address past criticisms,
government and industry officials believe it is too early to say
whether further improvements are needed. According to the Safety Board,
state pipeline safety officials, industry groups, and pipeline
operators, OPS‘s initiatives address the agency‘s underlying data
problems and will enable OPS to better understand the causes of
incidents so it can focus its efforts to improve safety. However,
officials from the Safety Board noted that these initiatives are merely
a first step, and they emphasized that OPS should periodically reassess
its forms and procedures and take steps to revise them as necessary. In
addition, a state pipeline safety official noted that although there
are now 25 cause categories on the incident forms, there will still be
some uncertainty, since operators have the option of choosing ’other.“
Finally, officials from industry groups told us that it will be several
years before OPS has sufficient data for analyzing trends in incidents.
Conclusions:
OPS is aggressively pursuing its integrity management approach and
taking action to improve the quality of its data. If properly
implemented, these initiatives should improve pipeline safety. However,
OPS still has significant challenges to overcome in implementing its
new regulatory approach. Although OPS is carrying out a variety of
activities aimed at overcoming these challenges, the agency lacks a
workforce plan containing current and future resource estimates for
these initiatives. The absence of such a plan could hamper OPS‘s
ability to meet its ambitious time frames and successfully implement
its new regulatory approach. Furthermore, OPS does not have an
effective strategy for communicating with its state partners and, as a
result, these states may not be fully aware of the role OPS expects
them to play in implementing integrity management and may not be
adequately prepared for this role. If states are not adequately
prepared, OPS will probably not be able to meet its ambitious time
frame for inspecting pipeline operators‘ integrity management programs.
Finally, the lack of a workforce plan and strategy for communicating
with states may hamper OPS‘s ability to ensure that it has the
resources and expertise it needs to oversee pipeline security and that
it is effectively involving states in this effort.
Recommendations for Executive Action:
We recommend that the Secretary of Transportation direct OPS to:
* develop a workforce plan that contains an updated assessment of OPS‘s
current and future staffing and training needs and an examination of
the workforce‘s deployment across the organization and:
* develop a strategy for communicating to the states what role they
will play in conducting integrity management inspections and other
oversight activities.
Agency Comments and Our Evaluation:
We provided a draft of this report to DOT for its review and met with
DOT officials, including OPS‘s Associate Administrator, to obtain their
comments. In addition, DOT‘s Assistant Secretary for Administration
provided written comments, which are reprinted in appendix I. The DOT
officials generally agreed with the draft report‘s recommendations.
Regarding workforce planning, they noted that OPS intends to formulate
detailed plans for the longer term after it has completed the final
integrity management rule for gas transmission pipelines. While we are
encouraged that OPS intends to develop a workforce plan, we believe
that the agency needs to ensure that its planning efforts encompass
both its short-term and long-term staffing and training needs. In
particular, the agency should develop a strategic workforce plan now in
order to establish a solid foundation for implementing integrity
management and accomplishing its mission and programmatic goals. Such a
plan should identify the resources and expertise OPS needs to carry out
its initiatives, including how it will leverage its resources with
those of its state partners. A workforce plan will help the agency meet
its ambitious time frame for implementing the integrity management
approach and address challenges it faces in doing so. OPS should
monitor and periodically update the plan to address changing needs.
Regarding communicating with the states, the DOT officials explained
that OPS is trying to define what role the states will play in
integrity management inspections and is currently engaged in
discussions with states regarding their involvement in this initiative.
Although we believe that this is a step in the right direction, the
agency needs to formulate and adopt a strategy for communicating with
its state partners that will help ensure that the agency effectively
involves states in integrity management and other oversight efforts
over the longer term.
OPS officials also provided some technical clarifications, which we
have incorporated in this report as appropriate.
Scope and Methodology:
To examine OPS‘s steps to implement the integrity management approach,
identify the challenges OPS faces in implementing this approach, and
assess OPS‘s plans for obtaining the resources and expertise needed to
oversee pipeline safety under this approach, we reviewed OPS documents,
analyzed OPS‘s resource estimates, visited states, and interviewed OPS
and pipeline industry officials as well as others with pipeline safety
expertise. OPS documents that we reviewed included the proposed and
final rules that establish the integrity management requirements,
comments on the proposed rule, OPS‘s documentation on its plans for
implementing the integrity management approach, and OPS‘s resource
estimates and training schedule. We analyzed OPS‘s resource estimates
to determine their accuracy and consistency. We also visited state
pipeline agencies in Texas, Washington, New York, and Virginia. We
chose to visit these states because their pipeline oversight agencies
are among the most active of OPS‘s state partners in implementing the
integrity management approach. For example, officials in these states
provided comments on OPS‘s proposed integrity management rules and/or
have been involved in efforts to develop integrity management program
requirements. In addition, Texas has its own integrity management rule
for natural gas and hazardous liquid pipeline operators. We also
conducted in-person and telephone interviews with the following:
representatives from state and national pipeline industry associations;
officials at several pipeline companies; pipeline safety officials in
those states we visited; representatives from environmental advocacy
organizations; officials from the Environmental Protection Agency and
the National Transportation Safety Board; representatives from Cycla
Corporation, a contractor that is working for OPS on some components of
implementing integrity management; a representative from the
Transportation Safety Institute, which provides the training for state
and federal pipeline safety inspectors; and officials from OPS‘s
headquarters and five regions.
To determine OPS‘s major initiatives to improve the quality of its data
on pipeline incidents, we reviewed and compared the agency‘s new data-
collection forms with its previous forms. We also interviewed officials
working for pipeline companies that fill out these forms. We
interviewed officials from the Safety Board and the DOT Office of the
Inspector General, OPS officials who implement the data-collection
activities, representatives from pipeline industry associations, and
state pipeline agency officials.
We conducted our work from November 2001 to July 2002 in accordance
with generally accepted government auditing standards.
As arranged with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after its date. At that time, we will send copies of this report to
congressional committees and subcommittees with responsibilities for
transportation safety issues, the Secretary of Transportation, the
Administrator of the Research and Special Programs Administration, and
the Director of the Office of Management and Budget. We will make
copies available to others upon request. In addition, this report will
be available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please
contact me at (202) 512-2834 or guerrerop@gao.gov. Key contributors to
this report were Susan Fleming, Judy Guilliams-Tapia, Michael Horton,
Wyatt Hundrup, and Sara Vermillion.
Sincerely yours,
Peter F. Guerrero
Director, Physical Infrastructure Issues:
Signed by Peter F. Guerrero:
[End of section]
Appendix I: Comments from the U.S. Department of Transportation:
U.S. Department of Transportation:
Assistant Secretary
for Administration:
400 Seventh St SW
Washington D C 20590:
August 7, 2002:
Mr. Peter Guerrero
Director:
Physical Infrastructure Issues
U.S. General Accounting Office
441 G Street N.W. Washington, D.C. 20548:
Dear Mr. Guerrero:
We appreciate the opportunity to provide comments on the U.S. General
Accounting Office (GAO) draft report regarding the status of efforts by
the Research and Special Program Administration‘s (RSPA) Office of
Pipeline Safety (OPS) to implement its Integrity Management Program and
improve the quality of data on pipeline incidents. OPS has achieved
significant progress in both its integrity and data initiatives.
Setting and enforcing higher pipeline safety standards through the
Integrity Management Program is already producing results for hazardous
liquid pipelines. RSPA demonstrated that it is prepared to enforce
these standards with its recently completed ’quick hit“ inspections.
These inspections:
*Included all large hazardous liquid pipeline operators,
*Covered over 70,000 miles of pipelines, and:
*Resulted in enforcement actions on 85 percent of those operators.
At a recent public meeting in July, OPS unveiled its new complete
inspection protocols for the comprehensive hazardous liquid pipeline
inspections and answered many implementation questions. We wish to
emphasize:
*OPS received overwhelmingly positive feedback from inspectors and
industry representatives alike regarding the effectiveness of the
protocols in achieving consistent enforcement of the hazardous liquid
Integrity Management Program. *OPS is staffed, organized, and prepared
to fully and effectively implement its final rules.
*The Integrity Management Program incorporates key attributes
recommended by the National Transportation Safety Board and mandated by
Congress, to ensure that pipelines continue to operate as safely as
possible.
OPS is dedicated to completing the remaining tasks according to plan.
The proposed rule for natural gas transmission pipelines is nearly
completed. OPS is working with state agencies and the industry to fine
tune performance measures.
To ensure that state partners are aware of their roles, OPS is
finalizing policy documents to clarify expectations. Our comprehensive
discussions with state pipeline safety partner agencies are:
*Clarifying a vision for state inspectors‘ participation in integrity
management inspections,
*Identifying state needs,
*Addressing training needs for state personnel,
*Improving overall communications, and:
*Making the Integrity Management Program plan review more efficient.
OPS has also been pursuing a logical, building block approach to
formulating detailed workforce plans.Detailed inspection protocols are
the basis for understanding the scope of tasks ahead, along with the
inspection time and resources required.While OPS is finalizing the
notice of proposed rulemaking on natural gas transmission pipelines, it
is premature to detail inspection protocols. Similarly the training
program, which is underway for hazardous liquids, can only be developed
for natural gas once the final rule is completed. Once all of the
critical building blocks come together, OPS will use these elements to
complete analytically based workforce planning to ensure that long-term
needs are met. While OPS has the resources it needs for the current
workload, it is clear that additional inspection resources are needed
to conduct inspections for both the Integrity Management Program and
other traditional inspection and oversight activities. The President
requested significant additional inspection resources for this purpose
for FY 2003.
While the GAO draft report recognized OPS‘ data improvement efforts, it
should be noted that RSPA has several initiatives to improve the
completeness and accuracy of its data to improve its oversight of
pipeline safety. Specifically, OPS has:
*Issued the first rulemaking requiring an annual report for hazardous
liquid pipelines - an essential step in improving the completeness and
value of pipeline data, and *Modified incident and accident report
forms to better reflect incident causes.
Overall, OPS is dedicated to effectively implementing the Integrity
Management Program and the data improvements. Work is complete in many
key areas and is underway to address remaining issues. While its
schedule is ambitious and the challenges formidable, OPS has already
demonstrated it is up to the challenge.
Once again, we appreciate the opportunity to offer these comments.
Please contact Martin Gertel on 202-366-5145 with any questions.
Sincerely,
Melissa Allen:
Signed by Melissa Allen:
FOOTNOTES
[1] U.S. General Accounting Office, Human Capital: A Self-Assessment
Checklist for Agency Leaders, GAO/OCG-00-14G (Washington, D.C.:
September 2000).
[2] See 49 U.S.C. 60105.
[3] See 49 C.F.R. pts. 190-199 (2002).
[4] P.L. No. 104-304, 110 Stat. 3793 (1996).
[5] U.S. General Accounting Office, Pipeline Safety: The Office of
Pipeline Safety Is Changing How It Oversees the Pipeline Industry, GAO/
RCED-00-128 (Washington, D.C.: May 15, 2000).
[6] For hazardous liquid pipelines, a ’high consequence area“ is
defined as a populated area, an area unusually sensitive to
environmental damage, or a commercially navigable waterway. See 49
C.F.R. 195.450 (2002). For natural gas transmission pipelines, OPS has
developed a definition that focuses on populated or frequented areas.
See 67 Fed. Reg. 1108, 1114 (Jan. 9, 2002).
[7] See 67 Fed. Reg. 2136, 2137 (Jan. 16, 2002).
[8] OPS is considering issuing requirements for integrity management
programs for operators of natural gas distribution pipelines after the
agency completes the rulemaking process for natural gas transmission
pipelines.
[9] The final rule for OPS‘s integrity management program for large
hazardous liquid pipeline operators was published in December 2000. See
65 Fed. Reg. 75378 (Dec. 1, 2000) (to be codified at 49 C.F.R. pt.
195). The final rule for small hazardous liquid pipeline operators was
published in January 2002. See 67 Fed. Reg. 2136 (Jan. 16, 2002).
[10] OPS plans to review all notifications received from operators and
to respond in a timely manner to those in which it finds the proposed
approach unacceptable.
[11] OPS requires operators to prioritize repairs in three categories:
repair immediately, repair within 60 days, or repair within 6 months.
See 49 C.F.R. 195.452(h)(4)(2002).
[12] However, the agency may combine the inspections in phases 1 and 2
for these pipelines if the agency determines that it would be more
efficient and equally effective to have one inspection.
[13] OPS‘s standard inspections verify whether pipeline operators are
in compliance with minimum safety standards. They include ’unit
inspections“ of an individual operating unit of a company‘s pipeline
system as well as ’systemwide inspections“ of all of a company‘s
related operating units.
[14] For example, OPS is issuing its integrity management rules
partially in response to a 1987 Safety Board recommendation that the
agency require pipeline operators to periodically inspect pipelines.
See U.S. General Accounting Office, Pipeline Safety: Progress Made, but
Significant Requirements and Recommendations Not Yet Complete,
GAO-01-1075 (Washington, D.C.: Sept. 28, 2001).
[15] In response to concerns that we and others raised, OPS began an
effort in 2000 to strengthen the enforcement of all its rules,
including increasing the use of fines. See U.S. General Accounting
Office, GAO/RCED-00-128 and Pipeline Safety: Status of Improving
Oversight of the Pipeline Industry, GAO-02-517T (Washington, D.C.: Mar.
19, 2002).
[16] For assessments using smart pigs, the flow of gas generally has to
be reduced by about 30 percent for 1 day.
[17] See 49 C.F.R. 195.452(j)(5)(2002).
[18] External corrosion is the only threat for which industry standards
for the application of direct assessment have been developed.
[19] Texas has implemented an integrity management program for
intrastate pipeline operators. It is the only state with an intrastate
integrity management program.
[20] Variance from the 5-year interval is allowed in two limited
situations, provided the operator provides notification and
justification to OPS. These situations are when there is an engineering
basis for a longer period and when the best technology needed to assess
the segment is temporarily unavailable. See 49 C.F.R. 195.452(j)(4)
(2002).
[21] In a notice of proposed rulemaking, OPS proposed a definition of
high consequence areas for natural gas transmission pipelines that is
based on populated and frequented areas. See 67 Fed. Reg. 1108, 1114
(Jan. 9, 2002).
[22] These standards, which provide guidance to natural gas operators
on how to implement integrity management programs, were developed by a
task force that included representatives from the natural gas pipeline
industry, OPS, and the Safety Board.
[23] According to OPS officials, these measures will be included in
DOT‘s budget proposal and performance plan for fiscal year 2004.
[24] These incident data are accessible to the public through OPS‘s Web
site.
[25] These measures would be made available to OPS electronically,
either through a company Web site or a computer (modem) connection.
[26] In spring 2002, the American Petroleum Institute began to collect
similar data from hazardous liquid operators on a voluntary basis.
However, the institute intends to use these data for industrywide
analyses and does not intend to report information on individual
operators‘ programs.
[27] The responsibility for oversight of pipeline security may change
in the future. DOT‘s Transportation Security Administration was created
in November 2001 and has statutory responsibility for the security of
all modes of transportation, although it has focused its initial
efforts on aviation security. In June 2002, the President proposed
legislation to create a new Department of Homeland Security. Under this
proposal, federal responsibilities for securing transportation systems
would be transferred to this department.
[28] OPS gathered some preliminary information on operators‘ security
practices immediately after September 11, 2001, through a survey of
major pipeline operators.
[29] A critical facility is one whose failure would have a high
consequence.
[30] OPS has undertaken a number of other security-related initiatives
since September 11, 2001. For example, the agency has worked with the
Department of Energy, the Federal Energy Regulatory Commission, state
pipeline agencies, and industry to address issues related to rapid
response and recovery of pipeline service in the event of an attack and
has solicited research and development proposals to protect pipeline
infrastructure.
[31] Pipeline Infrastructure Protection to Enhance Security and Safety
Act, H.R. 3609, 107th Cong. (2001).
[32] We have previously reported that the identification of critical
facilities is important for prioritizing protection efforts. See U.S.
General Accounting Office, Homeland Security: A Risk Management
Approach Can Guide Preparedness Efforts, GAO-02-208T (Washington, D.C.:
Oct. 31, 2001).
[33] In March 2002, the Office of Homeland Security announced the
creation of a Homeland Security Advisory System in order to disseminate
information on the risk of terrorist attacks. The system includes five
levels of threat to characterize this risk and associated suggested
protective measures. The office has requested comments on the system
and plans to finalize it by September 2002. 67 Fed. Reg. 12047 (Mar.
18, 2002).
[34] Some legislation has been proposed that would protect such
information. For example, H.R. 4 and H.R. 3609 would allow the
Secretary of Transportation to withhold information on pipeline
vulnerabilities from public disclosure. Energy Policy Act of 2002, H.R.
4, Secs. 741-783, 107th Cong. (2002) and Pipeline Infrastructure
Protection to Enhance Security and Safety Act, H.R. 3609, 107th Cong.
(2001).
[35] GAO/OCG-00-14G.
[36] OPS‘s proposed rule was published in April 2000, 65 Fed. Reg.
21695 (Apr. 24, 2000), and the final rule was published in December
2000, 65 Fed. Reg. 75378 (Dec. 1, 2000).
[37] OPS‘s original resource estimates are also miscalculated. By
incorrectly multiplying numbers, for example, OPS estimated that 1,640
work weeks were required in the regions for implementing the small
liquid integrity management rule, but the corrected figure is 2,495.
[38] OPS made an exception in the case of Texas by allowing Texas
inspectors to accompany OPS on the quick hit inspections, mostly
because Texas has its own integrity management rule.
[39] The Joint Government/Industry Risk Assessment Quality Team, Risk
Management within the Liquid Pipeline Industry, sponsored by OPS and
the American Petroleum Institute, June 20, 1995.
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