The Pipeline Safety Improvement  Act of 2002 extended the integrity management program to gas  transmission pipelines, which include about 20,000 miles of pipeline  segments located in high consequence areas.subject to PHMSA’s integrity management program, operators must still  meet the minimum safety standards noted above. According to the 2002 act, operators are then required to complete  reassessments of these pipelines at least every 7 years. Gas  transmission pipeline operators completed most baseline assessments by  December 17, 2012, and reassessments are currently under way. Data Show Critical Pipeline Repairs Are Being Made, but Cannot Be Used to Determine an Appropriate Maximum Reassessment Interval for All Pipelines Nationwide

		Assessments Have Resulted in Critical Pipeline Repairs

PHMSA’s baseline assessment and reassessment data from 2004 to  2011 show that pipeline operators have identified and are making critical  repairs in high consequence areas, specifically for conditions requiring  repairs immediately or within one year. PHMSA data show that from 2004 to  2009, pipeline operators reported making 1,080 immediate repairs and  2,261 scheduled repairs (see fig. The 7-Year Reassessment Requirement Provides a Safeguard, but Is Not Fully Consistent with Risk-Based Practices

		Maximum Reassessment Intervals Provide a Safeguard

Maximum reassessment intervals—such as the 7-year reassessment  requirement—provide a safeguard and allow regulators and operators to  identify and address problems on a continual basis. Because  the 7-year reassessment requirement is a more frequent interval than  those in the industry consensus standards, it provides greater assurance  that operators are regularly monitoring their pipelines to identify and  address threats before they result in a leak or rupture. The 7-Year Reassessment Requirement Is Not Fully Consistent with Risk- Based Practices

Risk-based management has several key characteristics that help to  ensure safety—it (1) uses information to identify and assess risks; (2)  prioritizes risks so that resources may be allocated to address higher  risks first; (3) promotes the use of regulations, policies, and procedures to  provide consistency in decision making; and (4) monitors performance. For example, the 7- year reassessment requirement does not permit operators to apply the  information that they have collected from their assessments: even though  operators must determine an appropriate reassessment interval based on  the threats facing their pipelines in high consequence areas, they must  reassess those pipelines at least for corrosion threats every 7 years  regardless of the risks identified. For instance, inspecting  and evaluating risk-based reassessment intervals beyond 7 years could  create additional workload, staffing, and expertise challenges for  regulators, such as PHMSA and state pipeline safety offices, for example:
PHMSA officials told us that allowing all operators to participate in  risk-based reassessment intervals beyond 7 years could add  significantly to the agency’s workload in terms of inspecting operators’  integrity management programs, including review of their calculated  reassessment intervals. Moreover,  PHMSA has already experienced some workload problems with  inspections, which could be worsened by allowing operators to use  risk-based reassessment intervals beyond 7 years. Based on our interviews, operators appear to  vary in the extent to which they currently calculate reassessment intervals  and use the results of the data analyses, for example:
Some operators we spoke with told us that they perform a less  rigorous determination of their reassessment intervals and default to  the 7-year interval if they determine that there are no problems with  their pipelines. PHMSA Has Previously Considered an Approach to Implementing Risk- Based Reassessment Intervals beyond 7 Years, but More Information on Resource Requirements Is Needed

In 2008, PHMSA provided a detailed statement at the request of  Congress to explain how the agency would establish and enforce risk- based criteria for extending the 7-year reassessment interval. Further, there is a lack of guidance to assist  regulators and operators in developing the risk models currently used to  calculate reassessment intervals. Given these potential challenges, more information might help decision- makers better understand the resource requirements needed in allowing  risk-based reassessment intervals beyond 7 years. To better identify the resource requirements needed to implement risk- based reassessment intervals beyond 7 years for gas transmission  pipelines, we recommend that the Secretary of Transportation direct the  Administrator for the Pipeline and Hazardous Materials Safety  Administration to collect information on the feasibility of addressing the  potential challenges of implementing risk-based reassessment intervals  beyond 7 years, for example by preparing a report or developing a  legislative proposal for a pilot program, in consultation with Congress, that  studies the impact to regulators and operators of a potential rule change. The department did not agree or disagree with  the recommendations, but provided technical comments that we  incorporated as appropriate. In particular, this report examines: (1) the  extent to which the Pipeline and Hazardous Materials Safety  Administration’s (PHMSA) assessment data provides information on  repairs made and the appropriateness of the 7-year reassessment  requirement, (2) the impact of the 7-year reassessment requirement on  regulators and operators, and (3) the potential challenges of  implementing risk-based reassessment intervals beyond 7 years.
Why GAO Did This Study

About 300,000 miles of gas transmission pipelines cross the United States, carrying natural gas from processing facilities to communities and large-volume users. These pipelines are largely regulated by PHMSA. The Pipeline Safety Improvement Act of 2002 established the gas integrity management program, which required gas transmission pipeline operators to assess the integrity of their pipeline segments in high consequence areas by December 2012 and reassess them at least every 7 years.
The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 directed GAO to examine the results of these baseline assessments and reassessments and the potential impact of making the current process more risk-based. GAO analyzed (1) PHMSAs assessment data on repairs made and the appropriateness of the 7-year reassessment requirement, (2) the impact of the 7-year reassessment requirement on regulators and operators, and (3) the potential challenges of implementing risk-based reassessment intervals beyond 7 years. GAO analyzed assessment data; reviewed legislation and regulations; and interviewed pipeline operators, federal and state regulators, and other stakeholders.

What GAO Found

Baseline assessment and reassessment data collected by the Department of Transportation's (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) since 2004 show that pipeline operators are making repairs in highly populated or frequented areas ("high consequence areas"). For example, from 2004 to 2009, operators made 1,080 immediate repairs. While operators can use assessment data to determine reassessment intervals for specific pipelines, PHMSA's data are aggregated and cannot indicate an appropriate maximum interval for all pipelines nationwide. Such a determination requires, for example, collaboration of subject matter experts and analysis of technical studies.
The current 7-year reassessment requirement provides a safeguard by allowing regulators and operators to identify and address problems on a continual basis, but is not fully consistent with risk-based practices. The 7-year reassessment requirement is more frequent than the intervals found in industry consensus standards and provides greater assurance that operators are regularly monitoring their pipelines to address threats before leaks or ruptures occur. However, this requirement--which was established in a 2002 act as part of the gas integrity management program rather than by rulemaking--is not fully consistent with risk-based management practices, which ask operators to, for example, use information to identify, assess, and prioritize risks so that resources may be allocated to address higher risks first. While operators are required to determine an appropriate reassessment interval based on the threats to their pipelines in high consequence areas, they must reassess those pipelines at least every 7 years regardless of the risks identified.
Implementing risk-based reassessment intervals beyond 7 years would require a statutory change from Congress and could exacerbate current workload, staffing, and expertise challenges for regulators and operators. For example, PHMSA is facing workload problems with inspections, which could be worsened by allowing operators to use risk-based reassessment intervals beyond 7 years; PHMSA has an initiative under way that could help address this issue. Further, some operators told us that extending reassessment intervals beyond 7 years would likely require additional data analyses over what is currently required. Operators GAO met with varied in the extent to which they currently calculate reassessment intervals and use the results of data analyses. Guidance to calculate reassessment intervals is lacking, and as a result, operators may perform a less rigorous determination of their reassessment intervals at this time. At Congress's request, in 2008 PHMSA described how it would establish and enforce risk-based criteria for extending the 7-year reassessment interval. PHMSA proposed retaining the current 7-year reassessment requirement, but establishing a process by which operators could use risk-based reassessment intervals beyond 7 years if they met certain potential criteria, such as demonstrating sound risk analysis. While PHMSA and GAO have supported the concept of risk-based reassessment intervals beyond 7 years, given the breadth of potential challenges with implementation, more information might help decision-makers better understand the resource requirements for this change. For example, PHMSA has used pilot programs to collect such information and study the effects prior to rule changes.

What GAO Recommends

DOT should (1) develop guidance for operators to calculate reassessment intervals and (2) collect information on the resources needed to implement risk-based reassessment intervals beyond 7 years. DOT did not agree or disagree with the recommendations, but provided technical comments.