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Nationwide Data
The GAO believes that PHMSA can move toward more quantifiable response times by making use of nationwide incident data. “For example,” says the GAO, “performing an analysis of nationwide incident data—similar to PHMSA’s current analyses of fatality and injury data—could help PHMSA determine response times for different types of pipelines (based on characteristics such as location, operating pressure, and diameter); identify trends; and develop strategies to improve incident response.”
The GAO further suggests that PHMSA could explore the feasibility of integrating incident response performance measures and targets for individual pipelines into its integrity management program. For example, PHMSA might identify performance measures that are appropriate for various types of pipelines and allow operators to determine which measures and targets best apply based on the characteristics of segments. This approach would allow operators the flexibility to meet response time targets in several ways, including changes to their leak detection methods, moving personnel closer to the valve location, or installing AVs.
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The GAO notes that PHMSA will need to do a better job of collecting reliable national data that would be needed to build a framework upon which an incident response performance measure could be built. At present, operators are not required to fill out certain time-related fields in the PHMSA incident-reporting form. Also, when operators do provide these data, they interpret the intended content in the data fields in different ways. These differing interpretations occur even though guidance on PHMSA’s website instructs operators on how to complete the reporting form, including the time-related data fields.
Automated Valves
AVs are not accident preventers. Rather, once an accident occurs, an AV can mitigate subsequent damage by reducing the amount of hazardous liquid and natural gas released. For example, the NTSB found that AVs would have reduced the time taken to stop the flow of natural gas in the San Bruno incident and, therefore, reduced the severity of property damage and life-threatening risks to residents and emergency responders. The GAO notes that AVs can be especially valuable in preventing fatalities and injuries when pipeline incidents occur near facilities with people who cannot be readily evacuated, such as hospitals and prisons. Other advantages are reduced damage from secondary fires caused by released fuel and reduced environmental cleanup; providing operator personnel and emergency responders access to the affected segment more quickly and easily; and reduced monetary consequences for the operator because of lost product.
The GAO found that operators install AVs after developing solid data that indicate clear benefits. One operator interviewed by the GAO installed an RCV in a location that would take pipeline personnel 2.5 hours to reach and another 30 minutes to close a manually operated valve. Use of the RCV is expected to reduce the total response time to under an hour, including detecting the incident and making the decision to isolate the pipeline segment. Several hazardous liquid pipeline operators used spill modeling to determine if the use of AVs would result in reduced damage from product release at individual locations. Spill modeling typically considers topography, operating pressure, and placement of existing valves. For example, one hazardous liquid pipeline operator used spill modeling to make the decision to install an RCV on a pipeline segment with a large elevation change.
Malfunctions
There is also significant concern about malfunctioning ASVs. For natural gas pipelines, accidental closures can result in loss of service to utilities and critical customers (e.g., winter outages can leave people without heat). Conversely, some operators told the GAO that relying on pressure-sensing systems can be dangerous because tuning the pressure activation device in an effort to avoid accidental closures can result in situations where the valve will not automatically close during an actual emergency. Some natural gas operators told the GAO that they have developed processes to avoid unintended closure. One operator said it “believed” it developed a process that effectively adapts to pressure and flow change and minimizes or eliminates the risk of the valve accidentally closing.
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Regarding hazardous liquid pipelines, the GAO found no operator who had installed an ASV. Specifically, the operators stated that an unexpected valve closure can result in decompression waves in the pipeline system, which might cause the pipeline to rupture if operators cannot reduce the flow of product promptly.
AVs are also costly, although operators reported a wide range of costs ($35,000 to $500,000). There are also a variety of additional costs associated with temporarily shutting down the pipeline to install the valve, purging the product from the pipeline, accessing the valve location (e.g., right-of-way, permitting, and physical space to install the new equipment), updating leak detection technologies, training staff, increasing security, and inspecting the new valve.
The GAO notes that PHMSA has developed guidance to assist operators who are considering automated valves for their pipelines. For example, PHMSA’s inspection protocol for natural gas operators describes several studies on the generic costs and benefits of AVs. The GAO found that operators were not aware of this guidance. This led to GAO’s main recommendation regarding ASVs—that PHMSA more actively use its information-sharing mechanisms to alert pipeline operators about guidance on regulations affecting AVs as well as approaches used by operators considering their installation.
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