Transmission pipelines carry hazardous liquid or natural gas,  sometimes over hundreds of miles, to communities and large-volume  users, such as factories. PHMSA has estimated there are more than 400,000 miles of  hazardous liquid and natural gas transmission pipelines across the  United States. Performance-Based Approach Offers Opportunity to Improve Incident Response, but Better Data Are Needed

The ability of transmission pipeline operators to respond to incidents,  such as leaks and ruptures, is affected by a number of variables—some  of which are under operators’ control—resulting in variances in response  time; for a given incident, that time can range from minutes to days. Incident Response Time Depends on Multiple Variables, Some of Which Operators Can Control

According to PHMSA officials, pipeline safety officials, and industry  stakeholders and operators, multiple variables—some controllable by  transmission pipeline operators—can influence the ability of operators to  respond quickly to an incident. Location of qualified operator response personnel. Type of valves. Weather conditions. We and others have recommended that the federal government move  toward performance-based regulatory approaches to allow those being  regulated to determine the most appropriate way to achieve desired,  measurable outcomes. Other organizations in the pipeline industry, including some state  regulatory agencies, have developed methods for measuring the  performance of operators responding to incidents by using specific  incident response times. Although defining performance measures and targets for incident  response can be challenging, one way for PHMSA to move toward a  more quantifiable, performance-based approach would be to develop  strategies to improve incident response based on nationwide data. However, the data  currently collected by PHMSA do not enable them to accurately  determine incident response times for all recent incidents for two reasons:  1) operators are not required to fill out certain time-related fields in the  PHMSA incident-reporting form and 2) when operators do provide these  data, they are interpreting the intended content of the data fields in  different ways. Improved Information Sharing about Evaluating Automated Valve Advantages and Disadvantages Could Inform Operators’ Decisions

The primary advantage of installing automated valves is reducing the time  to shut down and isolate a pipeline segment after a leak or rupture  occurs, while disadvantages include the potential for accidental closures  and monetary cost. PHMSA has several opportunities to assist operators  in making these evaluations, including communicating guidance and  sharing information on some methods operators use to make these  decisions. Improved Response Times, Potential for Accidental Closures, and Costs Should be Evaluated on a Case-by-Case Basis

Research and industry stakeholders indicate that the primary advantage  of installing automated valves is related to the time it takes to respond to  an incident. Specifically, automated valves  can lead to accidental closures, which can have severe, unintended  consequences, including loss of service to residences and businesses. Operators Have Developed Approaches to Evaluate Advantages and Disadvantages of Installing Automated Valves

Operators we met with are using a variety of methods for determining  whether to install automated valves. This spill modeling typically considered topography,  operating pressure, and placement of existing valves. Reliable data would improve PHMSA’s  ability to measure incident response and assist the agency in exploring  the feasibility of developing a performance-based approach for improving  operator response to pipeline incidents. However, not all operators  we spoke with were aware of existing PHMSA guidance and PHMSA  does not formally collect or share evaluation approaches used by other  operators to make decisions about whether to install automated valves. Recommendations for Executive Action

We recommend that the Secretary of Transportation direct the PHMSA  Administrator to take the following two actions:
To improve operators’ incident response times, improve the reliability  of incident response data and use these data to evaluate whether to  implement a performance-based framework for incident response  times. Appendix I: Objectives, Scope, and Methodology

The objectives of our review were to determine (1) the opportunities that  exist to improve the ability of transmission pipeline operators to respond  to incidents and (2) the advantages and disadvantages of installing  automated valves in high-consequence areas and ways that the Pipeline  and Hazardous Materials and Safety Administration (PHMSA) can assist  operators in deciding whether to install valves in these areas. We conducted a literature review of previous  research on pipeline incidents. Appendix II: How Select Operators Determined Whether to Install Automated Valves

We conducted site visits to eight hazardous liquid and natural gas  pipeline operators with different amounts of pipeline miles in or affecting  high-consequence areas. Pipeline operator: Enterprise Products  Product type: Hazardous liquid and natural gas  Number of pipeline miles: 23,012 (total); 8,783 (could affect or in high- consequence areas)
Decision-making approach: The operator assesses each pipeline  segment using spill-modeling software to determine the amount of  product release and extent of damage that would occur in the event of an  incident.
Why GAO Did This Study

The nation's 2.5 million mile network of hazardous liquid and natural gas pipelines includes more than 400,000 miles of "transmission" pipelines, which transport products from processing facilities to communities and large-volume users. To minimize the risk of leaks and ruptures, PHMSA requires pipeline operators to develop incident response plans. Pipeline operators with pipelines in highly populated and environmentally sensitive areas ("high-consequence areas") are also required to consider installing automated valves.
The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 directed GAO to examine the ability of transmission pipeline operators to respond to a product release. Accordingly, GAO examined (1) opportunities to improve the ability of transmission pipeline operators to respond to incidents and (2) the advantages and disadvantages of installing automated valves in high-consequence areas and ways that PHMSA can assist operators in deciding whether to install valves in these areas. GAO examined incident data; conducted a literature review; and interviewed selected operators, industry stakeholders, state pipeline safety offices, and PHMSA officials.

What GAO Found

The Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) has an opportunity to improve the ability of pipeline operators to respond to incidents by developing a performance-based approach for incident response times. The ability of transmission pipeline operators to respond to incidents--such as leaks and ruptures--is affected by numerous variables, some of which are under operators' control. For example, the use of different valve types (manual valves or "automated" valves that can be closed automatically or remotely) and the location of response personnel can affect the amount of time it takes for operators to respond to incidents. Variables outside of operators' control, such as weather conditions, can also influence incident response time, which can range from minutes to days. GAO has previously reported that a performance-based approach--including goals and associated performance measures and targets--can allow those being regulated to determine the most appropriate way to achieve desired outcomes. In addition, several organizations in the pipeline industry have developed methods for quantitatively evaluating response times to incidents, including setting specific, measurable performance goals. While defining performance measures and targets for incident response can be challenging, PHMSA could move toward a performance-based approach by evaluating nationwide data to determine response times for different types of pipeline (based on location, operating pressure, and pipeline diameter, among other factors). However, PHMSA must first improve the data it collects on incident response times. These data are not reliable both because operators are not required to fill out certain time-related fields in the reporting form and because operators told us they interpret these data fields in different ways. Reliable data would improve PHMSA's ability to measure incident response and assist the agency in exploring the feasibility of developing a performance-based approach for improving operator response to pipeline incidents.
The primary advantage of installing automated valves is that operators can respond quickly to isolate the affected pipeline segment and reduce the amount of product released; however, automated valves can have disadvantages, including the potential for accidental closures--which can lead to loss of service to customers or even cause a rupture--and monetary costs. Because the advantages and disadvantages of installing an automated valve are closely related to the specifics of the valve's location, it is appropriate to decide whether to install automated valves on a case-by-case basis. Several operators we spoke with have developed approaches to evaluate the advantages and disadvantages of installing automated valves. For example, some operators of hazardous liquid pipelines use spill-modeling software to estimate the amount of product release and extent of damage that would occur in the event of an incident. While PHMSA conducts a variety of information-sharing activities, the agency does not formally collect or share evaluation approaches used by operators to decide whether to install automated valves. Furthermore, not all operators we spoke with were aware of existing PHMSA guidance designed to assist operators in making these decisions. PHMSA could assist operators in making this decision by formally collecting and sharing evaluation approaches and ensuring operators are aware of existing guidance.

What GAO Recommends

DOT should (1) improve incident response data and use these data to evaluate whether to implement a performance-based framework for incident response times and (2) share guidance and information on evaluation approaches to inform operators decisions. DOT agreed to consider these recommendations.