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  #1  
Old 03-28-2012, 03:45 PM
Cynthia.Quarterman Cynthia.Quarterman is offline
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Default PHMSA Strategic Plan

The mission of the Pipeline and Hazardous Materials Safety Administration (PHMSA) is to protect people and the environment from the risks of hazardous materials transportation. PHMSA has completed a final draft of its 2012-2016 Strategic Plan outlining how the agency intends to meet its mission. PHMSA seeks comments and suggestions from the public to assist the agency in developing a final version of its Strategic Plan.

PHMSA is accepting comments until April 30, 2012 and they can be submitted by clicking on the POST REPLY button below. All comments will be published. For more information about submitting comments, please see below.

PHMSA encourages public input; your ideas and suggestions are important to us. We want to share your comments, but we expect the information to follow the conventions of polite discourse. Please note that we will not comments that contain:
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We will not edit inappropriate comments. Only comments that comply with this policy will be approved for posting.
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File Type: pdf PHMSA SP Draft (2-9-2012).pdf (1,014.2 KB, 753 views)
  #2  
Old 04-11-2012, 09:17 AM
Thomas Miller
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Default Pipeline Safety

As a 27 year veteran of the fire service, a Fire Service Instructor, and a first responder whose fire department has responded to several pipeline incidents, I proffer the following:

a) PHMSA needs to require pipeline operators to do a better job at outreach to response organizations. Specifically, the response agencies need to be included in drills and/or emergency exercises at least once every two (2) years. Often pipeline operators conduct only, "in-house" drills/exercises and then operate in their own little universe when an incident occurs. They then have the expectation that responders will operate under, "their plan(s)" and get upset if the responding entity orders evacuations and/or makes other decisions that are contrary to their plan and/or made without consulting them as the operator. Further, training materials need to focus more on response planning and less on "damage control" and/or preventing pipeline, "encroachment" which is often beyond the scope and/or control of rural first responders.

b) Pipeline operators need to submit their safety trainings to the authority(ies) having jurisdiction [AHJ] (State Fire Commissions, Community and Technical Colleges, etc.) for review and/or distribution so that the materials can be delivered on a broader basis to more responders. Currently many operators only offer one(1) training once per year - usually on an evening in the middle of the week - that is not always conducive to volunteer organizations.

c) Pipeline operators need to communicate any and/or all subcontracted parts of their operations. We had one incident where one (1) company owned the pipeline but had leased it to another company who then subcontracted the maintenance of the line to another company and the upkeep of the right-of-way to a fourth entity. When the leak occurred we, as the responding agency, had a problem sorting out who was responsible for handling the leak. The operators need to clarify these reponsibilities to the AHJs.

d) PHMSA needs to have some more teeth to back up its "bark". With the aging of America's pipeline network and its criticality to the economy, coupled with the Appalachian Marcellus Shale boom which will further tax that system, the likelihood of serious incidents will increase. Pipeline operators will, if they are not already, do that age-old risk (risk = profit) versus benefit (benefit = safety) and push their systems to their limits in order to generate revenue. Whether those "teeth" are delegated to the States for enforcement or retained at the Federal level is not a first responder issue but, in either case, it will, if nothing else, provide a sentinel effect to help ensure public safety is a priority.

e) PHMSA also needs to be a player in deciding who will regulate the well site to transmission line issue. This is a huge void in the regulatory framework. As referenced in item (d) of this post, the Marcellus boom as well as the boom in drilling in the Dakotas and other parts of the country necessitate some safety centered regulations. This is not to say that it has to be so onerous that it makes it uneconomical to explore for new sources of energy, but one that defines clearer responsibilities and culpabilities in the unfortunate event of an incident.

I appreciate the opportunity to provide comment on the PHMSA report and wish the agency success in the implementation of the plan.

Respectfully,

Thomas D. Miller
Fire Instructor III
tmiller@station26.org
Sissonville, WV
  #3  
Old 04-27-2012, 05:49 PM
Shana.Childs Shana.Childs is offline
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Default On Behalf of Lawrence W. Bierlein, Association of Hazmat Shippers, Inc. (AHS)

Please see the attachment for comments.
Attached Files
File Type: docx AHS final comments on Strategic Plan.docx (85.3 KB, 555 views)

Last edited by Shana.Childs; 04-30-2012 at 03:25 PM.
  #4  
Old 04-30-2012, 12:58 PM
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Default AAR Comments to PHMSA 2012 - 2016 Strategic Plan

Date: April 30, 2012
To: Pipeline and Hazardous Materials Safety Administration (PHMSA)
Subject: 2012-2016 PHMSA Strategic Plan

On behalf of its member railroads, the Association of American Railroads (AAR) submits the following comments in response to PHMSAís request for comments to its 2012-2016 Strategic Plan. U.S. freight railroads originated over 1.8 million carloads of hazardous materials in 2011 and have an interest in the safe transportation of those materials, and hence have a keen interest in PHMSAís strategic plan.

Bulk transportation of hazmat that is toxic by inhalation (TIH)

In the 2012-2016 Strategic plan, PHMSA acknowledges participation in the Advanced Tank Car Collaborative Research Program (ATCCRP), and the development of a Next Generation tank car (NGTC) built under a hazmat special permit. AAR does not think this goes far enough. The intent of the ATCCRP is for government and industry to work together to further reduce the risk of TIH transportation. The goal is not to stop at the NGTC (current technology), but to exceed it, and promulgate new regulations that make TIH transportation even safer than what is anticipated for the NGTC and closer to what was proposed in PHMSAís 2008 notice of proposed rulemaking . AAR would like PHMSA to commit to promulgating new regulations for TIH tank cars as soon as the ATCCRP is complete.

Work with the Department of Homeland Security to refine the response standards and isolation distances in the Emergency Response Guide

Every four years, PHMSA re-publishes the Emergency Response Guidebook (ERG). The ERG has a section outlining protective actions to be taken in the event of a release of listed hazardous materials that is based on non-validated air dispersion models, or models that have not been completely validated using empirical data.

PHMSA is about to publish a new Table 3 in the 2012 edition of the ERG. Table 3 has new protection distances for a select group of TIH for various package sizes, including tank cars. For chlorine, the protect distance for a tank car quantity release is 7 miles, two more miles than the 2008 ERG guideline for a large spill release of chlorine. Recent field experience with accidental releases of toxic inhalation hazard (TIH) materials indicates that inconsistencies exist between collected chemical concentration data and model-predicted TIH material behavior. In addition, the current ERG bases protective actions on toxicity endpoints that may not be appropriate and may need to be changed for certain TIH materials.

AAR would like PHMSA to consider evaluating the existing air dispersion model for TIH materials, CASRAM, for amendment. AAR believes CASRAM is limited by the exclusion of crucial information including chemical reactivity with surfaces and organic materials and the effects of topography on chemical dispersion.

Hundreds of thousands of real-time and analytical data points have been collected (and could be made available) soon after accidental releases of TIH materials including chlorine and anhydrous ammonia. Recent events include high-profile incidents at Graniteville, SC; Minot, ND; and Macdona, TX. In addition, real-time data were collected during experimental releases of chlorine and anhydrous ammonia at Dugway National Chemical and Biological Proving Grounds in Dugway, UT. Air dispersion models were conducted during these experimental releases and calibrated based on real-time data collected in the field resulting in better estimation of TIH behavior in uncontrolled releases. These extensive data sets lend themselves for significant analysis and comparison and exploration of the effects of chemical deposition and reaction during large-scale TIH releases.

Further analysis and publication of these data will contribute to a better scientific understanding of TIH behaviors, and we would like PHMSA to perform this analysis and data publication to allow calibration of models used to drive protective actions such as those published in the ERG. The outcome of the study will provide more realistic and scientifically defensible models and actual data to make better decisions to protect the public during hazardous materials incidents. Finally, more accurate protect distances in the ERG will minimize the inconvenience people are subjected to during TIH releases, while providing the safety the public expects.

Non-Accident Releases (NARís)

AAR members are very interested in reducing the number of NARís on railroad property. While the number of NARís has declined 49% since 1996, they have only declined 4% since 2004, and in 2011 there were 611 NARís. AAR is very active in reducing NARís, and supports the NAR Reduction Task Force. Data indicates that most NARís are caused by the shipper or consignee doing something wrong at the loading or unloading site which results in an NAR in transportation. AAR would like to see PHMSAís strategic plan recognize NARís as an issue which should be addressed and establish a specific reduction goal.

Thank you for considering AARís input into the 2012-2016 Strategic Plan.

Sincerely,



Robert E. Fronczak
  #5  
Old 04-30-2012, 03:24 PM
Shana.Childs Shana.Childs is offline
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Default On behalf of Cynthia Hilton, Institute of Makers of Explosives

Please see the attachment for comments.
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File Type: pdf PHMSA SP Draft (2-9-12) IME Comments.pdf (1,015.1 KB, 221 views)
Old 05-04-2012, 03:34 PM
Marlise Soria
This message has been deleted by Shana.Childs. Reason: repeat
  #6  
Old 05-04-2012, 03:52 PM
Shana.Childs Shana.Childs is offline
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Join Date: Mar 2012
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Default Comment Period is Now Closed

Thank you for reviewing the 2012-2016 PHMSA Strategic Plan. The period to post comments ended on Monday, April 30th.
 

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