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In This Issue

  1. DOT Pipeline Compliance Workshop – August 7-9, 2012
  2. PHMSA Advisory Bulletin (ADB–2012–07) Mechanical Fitting Failure Reports
  3. PHMSA Pipeline Act 2011 / Section 24 Workshop July 13, 2012 – Washington, DC
  4. Introducing MaxOp*
  5. MAOP Validation Services
  6. Office of Inspector General Report about IMP Oversight
  7. Integrity Management Services
  8. PHMSA’s Request for Comments on 811 Public Service Announcement
  9. Revised Louisiana Dig Laws Effective August 1!
  10. Public Awareness Effectiveness Program Inspections
  11. Advisory Committee Meetings – July 2012
  12. Pipeline Regulations for iPhone
  13. RCP’s DOT Workshop Survey
  14. Summer / Fall Industry Conferences
  15. API Damage Prevention Workshop September 12 -13, Houston, TX

Office of Inspector General Report about IMP Oversight

Report Number: AV-2012-140

On June 18, the Office of Inspector General (OIG) issued a report on the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) oversight of hazardous liquid pipeline operators’ integrity management (IM) programs. These programs include plans, processes, and procedures aimed at reducing the likelihood and severity of pipeline accidents in High Consequence Areas. PHMSA initiated an inspection program to oversee operators’ implementation of their IM programs in 2002. Since then, the program has accomplished much, but still faces challenges that impact the Agency’s oversight of operators’ IM programs. These challenges include:

  • managing a growing backlog of inspections,
  • identifying IM weaknesses through field inspections, and
  • onsite accident investigations, and transitioning to a new risk-based inspection program.

In addition, PHMSA’s oversight of non-line pipe facilities (such as valves, pump and meter stations, and storage tanks) is limited by less rigorous IM requirements, despite recent technological advances that would allow more rigorous oversight of these facilities. Although PHMSA has established a corrective action plan to address long-standing data management deficiencies, the Agency has not yet resolved key deficiencies or established meaningful analysis capabilities to improve its oversight. The OIG made 9 recommendations to improve PHMSA’s oversight; PHMSA concurred with seven and partially concurred with two. However, PHMSA’s responses did not fully meet the intent of six of the recommendations, and the OIG is requesting additional information for these recommendations:

1. Categorize IM requirements as a high priority within the Agency’s integrated inspection and enforcement program. (Did not meet the intent of OIG’s recommendations.)
2. Establish target dates for resolving remaining data system and risk analysis issues affecting PHMSA’s inspection program. (Did not meet the intent of OIG’s recommendations.)
3. Implement a pilot program to determine whether the IM Field Implementation Directive provides sufficient onsite field testing of operator’s IM program implementation. (Resolved but open pending completion of PHMSA’s planned actions.)
4. Expand accident investigation criteria to conduct more Agency onsite reviews of significant accidents potentially involving IM-detectable causes. (Did not meet the intent of OIG’s recommendations.)
5. Update IM requirements to mandate baseline and recurring assessments for non-line pipe facilities, given the availability of new assessment technologies and methodologies. (Resolved but open pending completion of PHMSA’s planned actions.)
6. Establish additional quality assurance procedures to verify the accuracy of operator annual reports and accident data. (Did not meet the intent of OIG’s recommendations.)
7. Develop and implement a program of systematic analyses to better assess pipeline risks, identify safety trends, and focus oversight activities. (Did not meet the intent of OIG’s recommendations.)
8. Create a database of pipeline physical characteristics, accidents, and inspections-including geographic location-of individual pipeline units in order to identify and monitor at-risk pipelines. (Did not meet the intent of OIG’s recommendations.)
9. Develop and implement specific performance measures to assess the impact of the IM program and its individual components on pipeline safety. (Resolved but open pending completion of PHMSA’s planned actions.)

For a copy of Report Number: AV-2012-140 on PHMSA’s IMP Oversight, contact Jessica Roger.