GAO Looks At Pipeline Regs

The GAO first assessed the absence of performance measures that indicate the desired or typical amount of time it takes a pipeline operator to respond to a pipeline failure. Second, the GAO notes inconsistency in the industry about whether large pipelines should be equipped with automated valves (AVs). There are two types of AVs. Automatic shutoff valves (ASVs) cut off the flow of product without human intervention based on sensor readings. Remote control valves (RCVs) can be closed via command from a control room. Many pipelines are also equipped with manual valves that require that a person arrive on-site and either turn a wheel crank or activate a push-button actuator.

AVs are not required on pipelines primarily because there are situations where they are not the optimal way to stem the escape of a pipeline product. Also, an AV that malfunctions can create a host of dangerous conditions. Given these factors, the GAO believes the industry should have access to more complete information about the advantages and disadvantages of AVs.

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2011 Pipeline Act

The GAO report—Better Data and Guidance Needed to Improve Pipeline Operator Incident Response—was required by the Pipeline, Regulatory Certainty, and Job Creation Act of 2011. To a large degree, that law was a direct response to a September 2010 explosion of a gas pipeline that killed 8 people and damaged 100 homes in San Bruno, California. The Act instructed the GAO to examine the ability of pipeline operators to respond to a hazardous liquid or natural gas release from an existing pipeline segment. The Act also directed the secretary of transportation to consider additional regulations requiring the use of AVs where economically, technically, and operationally feasible on new transportation facilities. Subsequently, the Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) contracted with Oak Ridge National Laboratory (ORNL) to draft a study that found that AVs were feasible under certain conditions.

The GAO developed its own report by interviewing operators with pipelines in densely populated and environmentally sensitive areas (called high-consequence areas [HCAs]) as well as operators with pipelines in diverse geographical areas. PHMSA regulations require that operators with pipelines in HCAs consider installing AVs. Also, after investigating the San Bruno incident, the National Transportation Safety Board (NTSB) recommended that PHMSA require that natural gas pipeline operators install AVs in all HCAs.

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Response Time

The GAO found that there are no federal guidelines indicating target response times for types of incidents on transmission pipelines. (Transmission pipelines carry hazardous liquid or natural gas, sometimes over hundreds of miles, to communities and large-volume users, such as factories.) Transmission pipelines tend to have the largest diameters and operate at the highest pressures of any type of pipeline. PHMSA estimates there are more than 400,000 miles of hazardous liquid and natural gas transmission pipelines in the United States.

Quick response time is critical to controlling the impact of a pipeline failure, but response times can vary widely based on many conditions. The GAO found that operators are able to control five factors that affect incident response time: leak detection capabilities, location of qualified operator response personnel, type of valve, control room management, and relationships with local first responders. Four other variables are outside an operator’s control: type of release (e.g., leak or rupture), time of day, weather conditions, and other operator’s pipeline in the same area. Depending on whatever combination of all nine factors occurs, a response to an incident can range from several minutes to days.

According to the GAO, PHMSA should consider instituting a performance-based approach to incident response times. The GAO defines a “performance-based approach” as one that focuses on desired, measurable outcomes rather than prescriptive processes, techniques, or procedures. PHMSA’s current language on response times is nonspecific. PHMSA states that operators must respond to certain incidents—specifically emergencies that require an immediate response—in a “prompt and effective” manner. But neither PHMSA’s regulations nor its guidance describes ways to measure progress toward meeting this goal. PHMSA informed the GAO that each incident presents unique circumstances, and whether or not a response was prompt and effective must be determined by PHMSA inspectors on a case-by-case basis.

But the GAO found that some state regulatory agencies have established specific response times for pipeline incidents. For example, the GAO notes that the New Hampshire Public Utilities Commission requires that natural gas distribution companies respond to reported leaks in time frames ranging from 30 to 60 minutes. Also, members of the Interstate Natural Gas Association of America have committed to achieving a 60-minute response time for incidents involving large-diameter (greater than 12 inches) natural gas pipelines in highly populated areas.

See tomorrow’s Advisor for more on the GAO report.