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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
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Extend Risk Management
Apply Risk Management beyond High Consequence Areas (HCAs)
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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Verify Integrity of Older Pipelines
Demonstrate Fitness for Service on Pre-Regulation 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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Mitigate Consequences of Incidents
Shorten Pipeline Isolation and Response Time to 1 Hour in Populated Areas
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
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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
Effective pipeline safety is a shared responsibility - and requires active
engagement between operators, the government and the public
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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=PHMSA2011-0023
• 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
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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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Manage Corrosion Anomalies
Raise the Standards for Corrosion Anomaly Management
INGAA member commitments:
• Apply the standard for corrosion anomaly management
outside HCAs to the same as used inside HCA
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Collect & Use Pipeline Data
Improve Integrity Management Communication and 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 Best Practices
Implement the PIPA Guidance
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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Advance Understanding of Threats
Evaluate, Refine and Improve Threat Assessment and Mitigation
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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Foster a Culture of
Continuous Improvement
Raise the Standard for Use of Management Systems across INGAA Members
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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Engage Public Officials
Provide Forums for Information Exchange with Stakeholders
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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