Safety Study Integrity Management of Gas Transmission Pipelines

Safety Study: Integrity Management of Gas Transmission Pipelines in High Consequence Areas Ivan Cheung 2015 Pipeline Safety Trust Annual Conference November 19, 2015 1

NTSB Background • Independent federal agency • No regulatory authority • Responsible for investigating accidents in aviation, railroad, highway, marine, and pipeline transportation modes • “Board” made up of 5 members appointed by President • Supported by about 400 staff in DC and 4 regional offices • Four modal offices and one technical support office 2

NTSB Research Mandate • NTSB authorization calls for accident investigation as well as safety research “Conduct special studies on matters pertaining to safety in transportation and the prevention of accidents. ” 3

Safety Study vs. Accident Investigation • Differences • Proactive vs. reactive • Breadth vs. depth • “Parties” to investigation • Similarities • • Written report Findings and safety recommendations • Public board meeting 4

Safety Study Process • • 5 Internal assessment of topic suitability Board approval of research proposal Field work and analysis Internal and external technical review Board meeting Safety advocacy Tracking of safety recommendations

Recent Safety Studies • Safety of Experimental Amateur-Built Aircraft • Curbside Motorcoach Safety • Crashes Involving Single -Unit Trucks 6

Objective of This Study • Evaluate the need for safety improvements to gas transmission integrity management programs 7

Motivation • Palm City, FL May 4, 2009 • San Bruno, CA September 9, 2010 • Sissonville, WV December 11, 2012 8

16 Integrity Management Program Elements • Identification of all high consequence areas • A performance plan including the use of specific performance measures • Baseline Assessment Plan • Recordkeeping provisions • Identification of threats to each covered segment, including by the use of data integration and risk assessment • Management of Change process • Quality Assurance process • Communication Plan • Procedures for providing to regulatory agencies copies of the risk analysis or integrity management program • Procedures to ensure that integrity assessments are conducted to minimize environmental and safety risks • A process to identify and assess newly identified high consequence areas • A direct assessment plan, if applicable • Provisions for remediating conditions found during integrity assessments • A process for continual evaluation and assessment • A confirmatory direct assessment plan, if applicable • A process to identify and implement additional preventive and mitigative measures 9

Focus on Select Elements • Identification of all high consequence areas • A performance plan including the use of specific performance measures • Baseline Assessment Plan • Recordkeeping provisions • Identification of threats to each covered segment, including by the use of data integration and risk assessment • Management of Change process • Quality Assurance process • Communication Plan • Procedures for providing to regulatory agencies copies of the risk analysis or integrity management program • Procedures to ensure that integrity assessments are conducted to minimize environmental and safety risks • A process to identify and assess newly identified high consequence areas • A direct assessment plan, if applicable • Provisions for remediating conditions found during integrity assessments • A process for continual evaluation and assessment • A confirmatory direct assessment plan, if applicable • A process to identify and implement additional preventive and mitigative measures 10

Focus Areas 11

Quantitative & Qualitative Research Review Data Analyses Interviews & Discussions Accident Reports Incidents Progress Reports Operators Inspectors Literature Annual Reports Enforcement Industry Associations Relevant Firms Researchers NTSB Investigators NPMS Technical Review 12

Operators’ Perspectives • • 13 7 companies IM plans and relevant documents Semi-structured discussion with focus topics Multiple staff with various responsibilities Demonstration Historical, current, and future Follow-up questions Participated in external technical review

Inspectors’ Perspectives • Federal inspectors and regulator • Teleconference with regional directors and inspectors • Close coordination • State inspectors • 5 states • NAPSR 14

Safety Recommendations • 28 new recommendations • • • 22 to PHMSA 2 to AGA 2 to INGAA 1 to NAPSR 1 to Federal Geospatial Data Committee • 1 reiterated recommendation to DOT 15

HCA Identification • Dependent on GIS and geospatial data • Need of buffering • Identified sites 16

HCA Identification • Publish standards for geospatial data used by pipeline operators (PHMSA, FGDC) • Develop a national repository of geospatial data resources for HCA identification (PHMSA) • Assess limitations of current HCA identification processes (PHMSA) 17

Threat Identification & Risk Assessment • • 18 Eliminating a threat from consideration Interactive threat Dynamic segmentation Complex risk assessment Relative risk approach versus others Use of “weights” Consequence of failure Desire for probabilistic model

Threat Identification • Establish minimum criteria for eliminating threats; documentation guidance (PHMSA) • Update guidance for evaluating interactive threats (PHMSA) • List of threat interactions to evaluate • Acceptable evaluation methods 19

Risk Assessment • Develop risk assessment training for inspectors (PHMSA) • Evaluate safety benefits of 4 approaches (PHMSA) • Update risk modeling guidance (PHMSA) • • • Weighting factors Consequence of Failure calculations Risk metrics and aggregation of risk • Collect and share data to support probabilistic models (AGA, INGAA) • Require all IM personnel to meet minimum professional qualification criteria (PHMSA) 20

Integrity Assessment • In-line inspection (ILI) vs direct assessment (DA) • Usage difference of ILI between interstate and intrastate pipelines 21

Integrity Assessment • Implement plan for eliminating the sole use of DA for integrity assessment (PHMSA) • Develop methods to eliminate operational complications that prevent use of ILI (PHMSA) • Implement strategy for increasing use of ILI, especially for intrastate (AGA, INGAA) • Require all transmission pipelines to be piggable (PHMSA) 22

Data Integration • • • Vaguely defined, hard to evaluation Emergence of GIS Authoritative data source within the organization • Empowering stakeholders at all levels within the organization • Very different levels of adoption 23

Data Integration • Implement plan for all segments of pipeline industry to improve data integration through GIS (PHMSA) 24

Federal and State Oversight • State-to-state and federal-to-state difference • Lack of coordination • State inspectors need additional guidance, supports, and resources • National Pipeline Mapping System (NPMS) needs improvement 25

Federal and State Oversight • Assess and improve protocol guidance, mentorship program, and availability of PHMSA SMEs for consultation (PHMSA) • Modify state program to include federalstate coordination in inspections (PHMSA) • Formalize program to increase state coordination (PHMSA, NAPSR) 26

Data Collection & Analysis • Add HCA method, risk assessment method, and piggable pipe mileage to annual report form (PHMSA) • Add previously identified threats and results of previous assessments to incident report form, and allow multiple root causes (PHMSA) • Analyze relationship between incident occurrences and these threat ID and risk ID factors (PHMSA) • In NPMS, add HCAs and increase positional accuracy of data (PHMSA) 27

Current Status • Held Board meeting on January 27 • Published report and sent recommendations • Government agencies have 90 days to respond • Meeting with organizations that received recommendations • Performing safety advocacy 28

Recommendation update • PHMSA has provided initial responses; majority of them are considered open-acceptable • No response from other recipients at this point 29

For More Information • ivan. cheung@ntsb. gov • nathan. doble@ntsb. gov • www. ntsb. gov • Click on “News & Events” to see presentations from the 1/27/2015 board meeting • Click on “Publications” then “Safety Studies” to read the report 30