Citing concerns that intrastate and small gas transmission pipeline operators may not be accurately identifying high consequence areas (HCAs) as part of their integrity management programs (IMP), PHMSA issued yet another advisory to the industry on December 12, 2016. In its seventh advisory issued this year, PHMSA explains the need for further guidance on the methodology based on recent inspections as well as a Safety Recommendation issued by the National Transportation Safety Board (NTSB) in 2015 (NTSB Recommendation P-15-06, issued in conjunction with the Board’s Safety Study of implementation of gas transmission integrity management rules).
PHMSA published an Information Collection Renewal Notice in June regarding the renewal of existing data that the Agency collects through the National Pipeline Mapping System (NPMS). 78 Fed. Reg. 36016 (June 14, 2013). Since that time, the Agency received one comment from the Pipeline Safety Trust (PST) requesting the following improvements to the data collected by the NPMS: (1) increase the accuracy of HCA data to assist local community emergency-planning efforts; (2) require that operators update NPMS information annually; and (3) require that operators provide system-specific information through the NPMS, such as pipe diameter, operating pressure, product transported, and potential impact radius. On September 18, 2013, PHMSA responded to the comment noting that it will consider these suggestions when evaluating further changes to the NPMS data requirements and by extending the comment period an additional thirty days to October 18, 2013. 78 Fed. Reg. 57455 (September 19, 2013). As discussed in a prior Pipelinelaw practice pointer on increased FOIA requests, PST’s comments touch upon issues related to sensitive infrastructure data, such as detailed information regarding pipeline location and characteristics, that may be protected from disclosure to third parties for security reasons under FOIA. The industry should be mindful of the risks inherent in making this information publicly available on the internet and possible options for limiting access to sensitive pipeline infrastructure information.