1. 1 PHMSA Pipeline Incident and IM Data: What They Do and Do Not Tell Us Pipeline Safety Trust Conference November 20, 2008 New Orleans, LA Carol Parker (Placitas, NM) Board Member, Pipeline Safety Trust www.pstrust.org Lois Epstein, P.E. (Anchorage, AK) President, LNE Engineering and Policy

2. 2 What’s Happened with Incident Reporting Since 2000? More analysis within and outside of PHMSA to detect incident causes and trends State-level incident data on PHMSA’s website Reporting of gross, not just net releases; graphics show incident trends (more accurate than volume trends) PHMSA’s mapping system offers the opportunity for geographic analysis of data

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4. 4 Note: Significant incidents include all serious incidents. New Mexico All Pipeline Systems: 1998-2008 YTD YearNumberFatalitiesInjuriesProperty DamageGross Barrels LostNet Barrels Lost 1998601$352,903728637 19991101$1,541,3076,5041,086 20003120$1,733,5972,5372,250 2001605$413,6641302 2002800$314,8042,5402,274 2003711$837,7774,2001,170 2004602$352,3331,9831,927 2005601$463,4442,7942,694 2006503$687,7471,956791 2007620$995,32900 2008 YTD602$726,6234,6534,605 Totals701516$8,419,53328,02517,436 3 Year Average (2005- 2007) 611$715,5071,5831,162 5 Year Average (2003- 2007) 611$667,3272,1871,316 10 Year Average (1998- 2007) 621$769,2912,3371,283

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6. 6 What Incident Data Problems Persist? Environmental consequences ignored: “significant” and “serious” incident analyses focus on injuries, fatalities, and property damage Incident data do not include reports from pipelines not regulated by PHMSA (exempt pipelines, certain offshore pipelines) Too many unknown incident causes reported (see graphics)

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8. 8 What Incident Data Problems Persist (continued)? Incident reports do not track releases that “could affect,” versus those that “did affect,” High Consequence Areas (proposed change) Incident reports do not distinguish 1 st, 2 nd, and 3 rd party damage (proposed change) No reporting of mileage of HCA pipe versus non- HCA pipe in each state and nationally – this would allow comparison of accident rates and a measurement of effectiveness of HCA measures

9. 9 Solutions to Incident Data Problems Track environmental damages Analyze and present annual data Report HCA mileage versus total mileage of each type of pipeline for both state and national data Unregulated pipelines should be required to report incidents and mileage to PHMSA “Unknown” category should be zero or near zero; audit reports and fine operators for inadequate reports PHMSA accepting comments on revised incident forms through December 12

10. 10 IM Performance Measure Reporting These are relatively new data posted on PHMSA’s website for hazardous liquid and gas transmission pipelines Performance measures differ for HL and NG pipelines, with all NG pipeline operators reporting incidents, leaks, and failures in High Consequence Areas

11. 11 NG Pipelines Short-Term Results

12. 12 IM Performance Measure Reporting: Observations Reporting incidents, leaks, and failures in HCAs enhances effectiveness of IM; this performance measure should be extended to HL pipelines Does not evaluate 1 st & 2 nd party excavation damage No unknown incident causes in HCAs?