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Reauthorization of the Natural Gas Pipeline Safety Act and the Hazardous Liquid Pipeline Safety Act
Subcommittee on Energy and Air Quality
Mr. Robert Chipkevich
Chairman
Barton and Members of the Subcommittee, I am pleased to represent the National
Transportation Safety Board before you today to discuss pipeline safety issues.
Pipelines
carry more hazardous materials in the United States than any other form of
transportation. Nearly 200,000 miles of hazardous liquid pipelines deliver
approximately 14.4 billion barrels of petroleum products annually, and more than
21 trillion cubic feet of natural gas are delivered through nearly 2 million
miles of pipe. Since its creation
in 1967, the Safety Board has issued 257 pipeline safety recommendations to the
Research and Special Programs Administration (RSPA).
RSPA's
pipeline recommendation acceptance rate, 70 percent, is the lowest of all modal
administrations, and for many years, the Safety Board has been critical of
RSPA's delay in providing needed pipeline safety improvements.
We are encouraged, however, with recent RSPA action, particularly in the
areas of pipeline integrity, data collection, and excavation damage protection. PIPELINE INTEGRITY The continued
operation of pipelines with discoverable integrity problems has been a recurring
issue in Safety Board investigations. The
Safety Board first issued a pipeline integrity recommendation in 1987, as a
result of investigations into three pipeline accidents - two in Kentucky and
one in Minnesota. The Safety Board
recommended that RSPA require periodic inspections or tests of pipelines to
identify corrosion, mechanical damage, or other time dependent defects that may
be detrimental to the continued safe operation of the pipelines.
We also recommended that RSPA establish criteria for use in determining
the frequency for performing inspections and tests.
In this regard, final
rules -- Pipeline Integrity Management in High Consequence Areas -- were
recently published that will require integrity assessments for liquid pipelines
in high consequence areas. The new
rules will require operators to assess the integrity of pipelines using in-line
inspection tools, pressure tests, or other technologies that are demonstrated to
provide equivalent results. According
to the rule, a pipeline operator must prioritize pipeline segments for baseline
and continual assessments and determine schedules for those assessments, based
on all risk factors that reflect risk conditions.
These factors must include results of previous assessments, defects that
could be found and their growth rates; pipe size, material, manufacturing
information, coating type and condition, and seam type; leak, repair, and
cathodic protection history; product transported; operating stress level;
activities in the area; local environmental factors; geo-technical hazards; and
physical support of the segment. It
is our understanding that Office of Pipeline Safety (OPS) is in the process of
drafting integrity assessment rules that will apply to gas transmission
pipelines. Mr. Chairman, the
Safety Board has provided favorable comments to much of this rule.
It is unfortunate, however, that it has taken 15 years following the
issuance of our 1987 safety recommendation for RSPA to act. As
a result of Safety Board investigations, the Safety Board has also advocated the
increased use of valve automation to reduce the consequences of pipeline
failures. The OPS' integrity
management rules will also require operators to evaluate the benefits of valve
automation in pipeline systems. According
to this rule, operators must consider the swiftness of leak detection and
shutdown capabilities, the type of commodity carried, the rate of potential
leakage, the volume that can be released, topography or pipeline profile, the
potential for ignition, proximity to power sources, location of nearest response
personnel, specific terrain between the pipeline segment and the affected area,
and the benefits expected by reducing the spill size. Risk management
principles, if properly applied, can be powerful tools to identify the risks to
pipeline integrity and should lead operators to take action to mitigate those
risks. Quantifying inputs into
various risk management models, however, can be difficult and subjective.
In a competitive environment, it may not be economically feasible for a
pipeline operator to conduct assessment and mitigation activities to prevent a
possible, but not inevitable, future pipeline failure.
To ensure that the new rules for risk-based integrity management programs
are effectively employed throughout the pipeline industry, it is imperative that
RSPA establish an effective evaluation program and aggressively examine and
monitor operators' pipeline integrity programs. An effective program
will require significant, qualified personnel and intense attention from OPS.
We note that the Administration's budget provides RSPA with resources
for additional pipeline personnel that should be helpful in establishing and
maintaining an effective program. In addition, the
principles of risk management assign highest priorities to locations subject to
the greatest damage or consequences. As
a result, a risk-based integrity management program will direct priority
resources to those areas. Pipeline
integrity management programs must ensure that pipelines located outside high
consequence areas are also adequately assessed and maintained.
The Safety Board is concerned that this was not addressed in the final
rule. Another pipeline integrity issue, corrosion, is a leading cause of hazardous liquid pipeline accidents. In 1987, the Safety Board recommended that requirements for corrosion protection include criteria against which liquid pipeline operators can evaluate the adequacy of cathodic protection systems. As recently as 1998, as a result of its investigation of a hazardous liquid pipeline accident in 1996 near Lively, Texas, the Safety Board urged RSPA to require hazardous liquid pipeline operators to determine the condition of pipeline coating when pipe is exposed and again asked them to include criteria against which the adequacy of cathodic protection systems can be evaluated. On December 27, 2001, OPS issued a final rule that we believe will improve the effectiveness of corrosion protection requirements for hazardous liquid pipelines, and addresses other issues included in our recommendations. DATA
COLLECTION As a result of Safety
Board investigations, we have for some time been critical of RSPA's collection
of accident data. We have found its
data collection to be inadequate for trend analyses and pipeline operator
performance evaluations. On May 8,
2001, OPS issued new accident reporting requirements for gas transmission
pipelines. Additionally, on January
8, 2002, OPS issued new accident reporting requirements for hazardous liquid
pipelines. The new reporting
requirements include information that the Safety Board believes will assist with
operator evaluation and trend analyses. We
understand that OPS is now working on improving accident reporting requirements
for gas distribution systems, and is implementing quality control procedures to
improve the accuracy of accident data reports.
EXCAVATION DAMAGE Excavation damage
remains a leading cause of pipeline accidents, and as a result of NTSB accident
investigations we have over the years issued numerous safety recommendations
regarding this issue. We are aware
that OPS is funding research in the following areas:
Excavation
damage prevention is an item on the Board's "Most Wanted" list of safety
issues, and we are hopeful that the on-going research, which addresses many
Safety Board recommendations, will lead to increased excavation prevention
safety. QUALIFICATION AND TRAINING REQUIREMENTS Mr. Chairman, we
mentioned previously, we are encouraged by much of the work that RSPA has
undertaken. However, the Board
believes insufficient progress has been made in the qualification and training
requirements for personnel operating pipelines. Following the 1987
Kentucky and Minnesota accidents, the Safety Board recommended that OPS require
operators to develop training and testing programs to qualify employees. Following a 1996 accident in San Juan, Puerto Rico, the
Safety Board asked RSPA to complete its rulemaking on operator qualification,
training, and testing standards. The
Safety Board also asked RSPA to require operators to test employees on safety
procedures they are expected to follow and to demonstrate that they can
correctly perform the work. In January 1999, the Safety Board commented on OPS' rulemaking regarding operator qualifications. Our comments noted that the proposed rules failed to adequately address qualification requirements or include requirements for training and testing. The final rule, issued in April 2001, allows individuals to be evaluated by written or oral examinations, observation during on-the-job performance, or work history. The rule allows individuals to be evaluated solely by their work history only until October 28, 2002, and operators will not be required to re-evaluate each individual using additional criteria until the next scheduled evaluation. In addition, the rule allows operators to determine what the interval time should be between evaluations. It is conceivable that a pipeline employee may continue to perform indefinitely safety-related tasks based solely on work history. Following the
issuance in April 2001 of the final rule on operator qualifications, the Safety
Board closed its recommendations as unacceptable response.
We believe a qualification rule should require that pipeline employees be
trained and tested to assess the success of the training, and that periodic
retraining should be provided. Mr. Chairman, that
completes my statement and I will be happy to respond to any questions you may
have.
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