Interstate Natural Gas Association of America INGAA Action Plan to Build Confidence in Pipeline Safety INGAA Integrity Management Continuous Improvement.

Interstate Natural Gas Association of America INGAA Action Plan to Build Confidence in Pipeline Safety

INGAA Integrity Management Continuous Improvement

November, 2011

INGAA Guiding Principles of Pipeline Safety

• Our goal is zero incidents - a perfect record of safety and reliability for the national pipeline system. We will work every day toward this goal.

• We are committed to safety culture as a critical dimension to continuously improve our industry’s performance.

• We will be relentless in our pursuit of improving by learning from the past and anticipating the future.

• We are committed to applying integrity management principles on a system-wide basis.

• We will engage our stakeholders - from the local community to the national level - so they understand and can participate in reducing risk.

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INGAA Members 9 Step Action Plan

Apply Risk Management beyond High Consequence Areas (HCAs)

Raise the Standards for Corrosion Anomaly Management

Demonstrate Fitness for Service on Pre-Regulation Pipelines

Shorten Pipeline Isolation and Response Time to 1 Hour in Populated Areas

Improve Integrity Management Communication and Data

Implement the Pipelines and Informed Planning Alliance (PIPA) Guidance

Evaluate, Refine and Improve Threat Assessment and Mitigation

Implement Management Systems Across INGAA Members

Provide Forums for Stakeholder Engagement and Emergency Officials

Extend Risk Management

INGAA member commitments:

• Apply integrity management principles to the entire transmission system operated by INGAA members

Currently required only for the 6% of natural gas transmission pipeline located within HCAs

• Expansion will be focused on population near the pipeline and continuing development of technology

• Will expand and consistently apply the program to: 90% of the population nearby pipelines using integrity management principles by 2012

90% of the population nearby pipelines using ASME B31.8S by 2020,

100% of the population nearby pipelines using integrity management principles by 2030

The remaining 20% of mileage with no population using integrity management principles beyond 2030

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Apply Risk Management beyond High Consequence Areas (HCAs)

Demonstrate Fitness for Service on Pre-Regulation Pipelines

Verify Integrity of Older Pipelines

INGAA member commitments:• Systematically validate records and maximum allowable

operating pressure for pipelines in HCAs that pre-date federal regulation • If records are inadequate, apply fitness for service and

remediate as necessary• Incorporate NTSB recommendations issued following the San

Bruno pipeline accident• Draw upon experience with HCAs in conjunction with

developing technology to address Class 3 and 4, and beyond

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Shorten Pipeline Isolation and Response Time to 1 Hour in Populated Areas

Mitigate Consequences of Incidents

INGAA member commitments:• Develop isolation and response plans using both valves and

deployment of personnel to meet 1-hour standard in populated areas.• Improve communications with emergency responders during

incidents to expedite situational awareness• Enhance response planning with emergency officials where

potential secondary fire consequences could be most severe

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What is Needed?

Holistic Approach to Pipeline Safety• Working together: INGAA, PHMSA, NTSB, and key stakeholders• Reauthorize Pipeline Safety Act• Stronger state and federal excavation prevention measures• Industry

R&D Share lessons learned Infuse best practices Invest in next generation of workers and safety tools Make safety culture an integral part of the pipeline industry day in and day out

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Effective pipeline safety is a shared responsibility - and requires active engagement between operators, the government and the public

Demonstrable Actions

• Filed Policy Positions describing the plan, with desire to get stakeholders engaged and weighing in on plan http://www.regulations.gov/#!searchResults;rpp=10;po=0;s=PHMSA-2011-0023 • Conducted workshop with National Association of State Fire Marshalls

and defined Incident Mitigation Management (IMM) – to improve mitigation performance and minimize overall incident impact • Defined Fitness For Service and developed a white paper providing

technical foundation• Studying other industries such as aviation, nuclear, chemical, medical,

where the consequence of failure can be catastrophic and developed safety culture white paper to help guide our efforts • Developing a Research and Development Road Map• Conducted workshops to define best practices for records management,

pipe procurement, construction and management of pre-regulation pipe 8

Summary

•Nothing less than relentless pursuit of improvement gets us to the goal of zero•Application of risk management is central to our

strategy•Our success depends upon active engagement of all

stakeholders•We are taking the next steps

We are cognizant of public opinion We will work cooperatively with all stakeholders We want to focus on real improvements to safety

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Appendix

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Raise the Standards for Corrosion Anomaly Management

Manage Corrosion Anomalies

INGAA member commitments:• Apply the standard for corrosion anomaly management

outside HCAs to the same as used inside HCA

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Improve Integrity Management Communication and Data

Collect & Use Pipeline Data

INGAA member commitments:• Improve data collection and analysis, convert this data into

meaningful industry information and communicate it to stakeholders

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Implement the PIPA Guidance

Implement Best Practices

INGAA member commitments:• Build an active coalition of INGAA member representatives to

implement PIPA recommended practices•Members also commit to collaborating with PIPA stakeholders

to increase awareness and adoption of PIPA recommended best practices

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Evaluate, Refine and Improve Threat Assessment and Mitigation

Advance Understanding of Threats

INGAA member commitments:• Initiate research to review interaction of multiple threats at

one site• Review adequacy of consensus standards for threats and

mitigation• Seek best practice for data integration to support integrity

mitigation decisions

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Raise the Standard for Use of Management Systems across INGAA Members

Foster a Culture ofContinuous Improvement

INGAA member commitments:• Better inform INGAA members to enable decision making and

control of risk• Provide guidance to members on types of practices, attributes,

and their indicators to be used to improve safety and operational culture

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Provide Forums for Information Exchange with Stakeholders

Engage Public Officials

INGAA member commitments:• Support and sponsor emergency preparedness workshops

highlighting lessons learned and current issues

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IMCI Action Teams

1. Stakeholder Outreach Two-way communication with meaningful performance measures. Actively promote PIPA (Pipeline and Informed Planning Alliance)

2. Risk Management Apply risk management concepts beyond High Consequence Areas (HCAs) with comprehensive threat analysis

3. Integrity Management Tools Enhance corrosion control methods and anomaly management protocols

4. Pipelines Built Prior to PHMSA Regulations Develop inventory and protocols to manage integrity

5. Technology Development & Deployment

• Improve crack-detection tools & management• Work with PHMSA to produce a R&D road map, and• Define assessment alternatives for non-piggable lines

6. Management Systems Apply safety culture principles to drive learning across the industry

7. Emergency Preparedness Response Update isolation valves automation and enhance public awareness

8. New Construction Fully implement the 2010/2011 INGAA Foundation Pipe and Construction Action Plans

9. Storage Clarify regulatory oversight for storage facilities

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