Safety Study: Integrity Management of Gas Transmission Pipelines in High Consequence Areas Ivan Cheung 2015 Pipeline Safety Trust Annual Conference November 19, 2015 1
NTSB Background • Independent federal agency • No regulatory authority • Responsible for investigating accidents in aviation, railroad, highway, marine, and pipeline transportation modes • “Board” made up of 5 members appointed by President • Supported by about 400 staff in DC and 4 regional offices • Four modal offices and one technical support office 2
NTSB Research Mandate • NTSB authorization calls for accident investigation as well as safety research “Conduct special studies on matters pertaining to safety in transportation and the prevention of accidents.” 3
Safety Study vs. Accident Investigation • Differences • Proactive vs. reactive • Breadth vs. depth • “Parties” to investigation • Similarities • Written report • Findings and safety recommendations • Public board meeting 4
Safety Study Process • Internal assessment of topic suitability • Board approval of research proposal • Field work and analysis • Internal and external technical review • Board meeting • Safety advocacy • Tracking of safety recommendations 5
Recent Safety Studies • Safety of Experimental Amateur-Built Aircraft • Curbside Motorcoach Safety • Crashes Involving Single-Unit Trucks 6
Objective of This Study • Evaluate the need for safety improvements to gas transmission integrity management programs 7
Motivation • Palm City, FL May 4, 2009 • San Bruno, CA September 9, 2010 • Sissonville, WV December 11, 2012 8
16 Integrity Management Program Elements • Identification of all high consequence • A performance plan including the use areas of specific performance measures • Baseline Assessment Plan • Recordkeeping provisions • Identification of threats to each covered • Management of Change process segment, including by the use of data • Quality Assurance process integration and risk assessment • Communication Plan • A direct assessment plan, if applicable • Procedures for providing to regulatory • Provisions for remediating conditions agencies copies of the risk analysis or found during integrity assessments integrity management program • A process for continual evaluation and • Procedures to ensure that integrity assessment assessments are conducted to • A confirmatory direct assessment plan, minimize environmental and safety if applicable risks • A process to identify and implement • A process to identify and assess newly additional preventive and mitigative identified high consequence areas measures 9
Focus on Select Elements • Identification of all high consequence • A performance plan including the use areas of specific performance measures • Baseline Assessment Plan • Recordkeeping provisions • Identification of threats to each covered • Management of Change process segment, including by the use of data • Quality Assurance process integration and risk assessment • Communication Plan • A direct assessment plan, if applicable • Procedures for providing to regulatory • Provisions for remediating conditions agencies copies of the risk analysis or found during integrity assessments integrity management program • A process for continual evaluation and • Procedures to ensure that integrity assessment assessments are conducted to • A confirmatory direct assessment plan, minimize environmental and safety if applicable risks • A process to identify and implement • A process to identify and assess newly additional preventive and mitigative identified high consequence areas measures 10
Focus Areas HCA ¡ Identification Threat ¡ Remediation Identification Data Integration Preventive & ¡Mitigative ¡ Risk Measures Assessment Integrity Assessment 11
Quantitative & Qualitative Research Review Data Analyses Interviews & Discussions Accident Progress Incidents Operators Operators Inspectors Inspectors Reports Reports Annual Industry Relevant Literature Enforcement Reports Associations Firms NTSB NPMS Researchers Investigators Technical Review 12
Operators’ Perspectives • 7 companies • IM plans and relevant documents • Semi-structured discussion with focus topics • Multiple staff with various responsibilities • Demonstration • Historical, current, and future • Follow-up questions • Participated in external technical review 13
Inspectors’ Perspectives • Federal inspectors and regulator • Teleconference with regional directors and inspectors • Close coordination • State inspectors • 5 states • NAPSR 14
Safety Recommendations • 28 new recommendations • 22 to PHMSA • 2 to AGA • 2 to INGAA • 1 to NAPSR • 1 to Federal Geospatial Data Committee • 1 reiterated recommendation to DOT 15
HCA Identification • Dependent on GIS and geospatial data • Need of buffering • Identified sites 16
HCA Identification • Publish standards for geospatial data used by pipeline operators (PHMSA, FGDC) • Develop a national repository of geospatial data resources for HCA identification (PHMSA) • Assess limitations of current HCA identification processes (PHMSA) 17
Threat Identification & Risk Assessment • Eliminating a threat from consideration • Interactive threat • Dynamic segmentation • Complex risk assessment • Relative risk approach versus others • Use of “weights” • Consequence of failure • Desire for probabilistic model 18
Threat Identification • Establish minimum criteria for eliminating threats; documentation guidance (PHMSA) • Update guidance for evaluating interactive threats (PHMSA) • List of threat interactions to evaluate • Acceptable evaluation methods 19
Risk Assessment • Develop risk assessment training for inspectors (PHMSA) • Evaluate safety benefits of 4 approaches (PHMSA) • Update risk modeling guidance (PHMSA) • Weighting factors • Consequence of Failure calculations • Risk metrics and aggregation of risk • Collect and share data to support probabilistic models (AGA, INGAA) • Require all IM personnel to meet minimum professional qualification criteria (PHMSA) 20
Integrity Assessment • In-line inspection (ILI) vs direct assessment (DA) • Usage difference of ILI between interstate and intrastate pipelines 21
Integrity Assessment • Implement plan for eliminating the sole use of DA for integrity assessment (PHMSA) • Develop methods to eliminate operational complications that prevent use of ILI (PHMSA) • Implement strategy for increasing use of ILI, especially for intrastate (AGA, INGAA) • Require all transmission pipelines to be piggable (PHMSA) 22
Data Integration • Vaguely defined, hard to evaluation • Emergence of GIS • Authoritative data source within the organization • Empowering stakeholders at all levels within the organization • Very different levels of adoption 23
Data Integration • Implement plan for all segments of pipeline industry to improve data integration through GIS (PHMSA) 24
Federal and State Oversight • State-to-state and federal-to-state difference • Lack of coordination • State inspectors need additional guidance, supports, and resources • National Pipeline Mapping System (NPMS) needs improvement 25
Federal and State Oversight • Assess and improve protocol guidance, mentorship program, and availability of PHMSA SMEs for consultation (PHMSA) • Modify state program to include federal- state coordination in inspections (PHMSA) • Formalize program to increase state- state coordination (PHMSA, NAPSR) 26
Data Collection & Analysis • Add HCA method, risk assessment method, and piggable pipe mileage to annual report form (PHMSA) • Add previously identified threats and results of previous assessments to incident report form, and allow multiple root causes (PHMSA) • Analyze relationship between incident occurrences and these threat ID and risk ID factors (PHMSA) • In NPMS, add HCAs and increase positional accuracy of data (PHMSA) 27
Current Status • Held Board meeting on January 27 • Published report and sent recommendations • Government agencies have 90 days to respond • Meeting with organizations that received recommendations • Performing safety advocacy 28
Recommendation update • PHMSA has provided initial responses; majority of them are considered open-acceptable • No response from other recipients at this point 29
For More Information • ivan.cheung@ntsb.gov • nathan.doble@ntsb.gov • www.ntsb.gov • Click on “News & Events” to see presentations from the 1/27/2015 board meeting • Click on “Publications” then “Safety Studies” to read the report 30
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