Operators of federally regulated gas and hazardous liquid pipelines should promptly check their compliance with all regulations governing metrics they use to evaluate the integrity of their systems.  Regulations issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) require that integrity management programs contain methods and metrics that will enable operators to identify, analyze, and understand threats to each pipeline segment. 

In a new Federal Register notice, PHMSA notes that “beginning immediately,” its inspectors will be paying special attention to reviewing operator methods and metrics for integrity management evaluation.

“PHMSA will evaluate specific metrics operators use to assess program effectiveness and how those metrics are used in a process of continuous improvement,” states PHMSA in the notice.  “PHMSA will also confirm that operators are maintaining adequate records of their program effectiveness evaluations and their performance metrics data, as well as the activities and decisions associated with all required integrity management program elements.”

NTSB recommendation

The notice and accompanying advisory bulletin are yet another response by PHMSA to a National Transportation Safety Board (NTSB) report on the September 9, 2010, gas pipeline explosion in San Bruno, California.  In that report, the NTSB found that the utility operating the pipeline conducted “superficial” self-assessments that resulted in no improvements to the integrity management program.  The NTSB also concluded that a greater focus is needed on how performance-based safety systems are implemented, executed, and evaluated and whether problem areas are being detected and corrected. 
PHMSA adds that this process is dependent on the use of meaningful metrics by operators that allow them to quantify, understand, and improve their own performance.

Larger metrics set needed

The advisory bulletin notes that the performance metrics must be reported to PHMSA annually–such as the number of miles of pipeline assessed and the number of anomalies found requiring repair or mitigation–are a small subset of the overall suite of metrics that should be used by an operator to evaluate its program.  A much larger set of operator-specific metrics is needed to effectively evaluate integrity management program performance.  Accordingly, metrics should be developed for:

• Overall effectiveness measured by the number of releases, number of injuries or fatalities, volume released, etc.
• Specific threats that include both leading and lagging indicators for important integrity threats to an operator’s systems. These include:
  • Activity measures that monitor the surveillance and preventive activities that are in place to control risk.
  • Deterioration measures that monitor operational and maintenance trends to indicate if the program is successful or weakening despite the risk control activities in place.
  • Failure measures that reflect whether the program is effective in improving integrity.
• Measurement and provision of insights into how well an operator’s processes associated with the various integrity management program elements are performing. Examples of such processes include integrity assessment, risk analysis, the identification of preventive and mitigative measures, etc.

Granular metrics

The bulletin adds that while operator-level rollups of metrics are useful for small operators, a robust program for large operators should also include metrics at a more “granular” level.  The metrics should enable operators to drill down to understand the performance of specific systems or segments within systems.

PHMSA’s notice and advisory bulletin on meaningful metrics in pipeline integrity evaluations were published in the December 5, 2012, FR.