# NTSB Safety Recommendation P-14-004 - **operation:** document - **citation:** P-14-004 - **title:** NTSB Safety Recommendation P-14-004 - **source type:** guidance - **agency:** National Transportation Safety Board - **status:** guidance - **official:** true - **published on:** 2014-03-05 - **effective on:** 2014-03-05 - **summary:** TO NISOURCE, INC. (FORMERLY COLUMBIA GAS TRANSMISSION CORPORATION): Establish a procedure to ensure that all integrity-related information gathered for pipelines located in high consequence areas is considered in the risk assessments and integrity management of other pipelines not located in high consequence areas. - **machine formats:** - **json:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-14-004.json - **markdown:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-14-004.md - **app url:** https://regulus.evalyn.ai/document/ntsb-recommendation-p-14-004 - **source url:** https://data.ntsb.gov/carol-main-public/sr-details/P-14-004 **body:** NTSB safety recommendation P-14-004. TO NISOURCE, INC. (FORMERLY COLUMBIA GAS TRANSMISSION CORPORATION): Establish a procedure to ensure that all integrity-related information gathered for pipelines located in high consequence areas is considered in the risk assessments and integrity management of other pipelines not located in high consequence areas. Priority: CLASS II Overall Status: Closed - Acceptable Action Issued Date: 2014-03-05 Adopted Date: 2014-02-19 Overall Date Closed: 2016-05-18 Synopsis: On December 11, 2012, at 12:41 p.m. eastern standard time, a buried 20-inch-diameter interstate natural gas transmission pipeline, owned and operated by Columbia Gas Transmission Corporation, ruptured in a sparsely populated area, about 106 feet west of Interstate 77 near Route 21 and Derricks Creek Road, in Sissonville, West Virginia. About 20 feet of pipe was separated and ejected from the underground pipeline and landed more than 40 feet from its original location. The escaping high-pressure natural gas ignited immediately. An area of fire damage about 820 feet wide extended nearly 1,100 feet along the pipeline right-of-way. Three houses were destroyed by the fire, and several other houses were damaged. There were no fatalities or serious injuries. About 76 million standard cubic feet of natural gas was released and burned. Columbia Gas Transmission Corporation reported the cost of pipeline repair was $2.9 million, the cost of system upgrades to accommodate in-line inspection was $5.5 million, and the cost of gas loss was $285,000. Major safety issues identified in this investigation were external corrosion mitigation of the ruptured pipeline, supervisory control and data acquisition alert setpoint configuration, use of automatic shutoff valves and remote control valves to improve isolation of high-pressure pipelines, and exclusion of pipelines in the vicinity of highways from integrity management regulation. The National Transportation Safety Board makes safety recommendations to Columbia Gas Transmission Corporation and the Pipeline and Hazardous Materials Safety Administration. Ntsbnumber: DCA13MP003 Report Number: PAR-14-01 Addressee Name: NiSource, Inc. (formerly Columbia Gas) Addressee Status: Closed - Acceptable Action Addressee Date Closed: 2016-05-18 Addressee Organization Type: P-Private Industry Communication Date: 2014-06-05 Communication Type: Official Correspondence Communication Contents: -From Shawn L. Patterson, President, Operations and Project Delivery: Columbia Gas currently uses a threat-based risk assessment model to quantify operational risk to its pipelines. The model incorporates data on pipelines, and the environment and operating criteria to define the probability and consequences of failure. These factors are represented by numerical scores that are calculated using algorithms and weights developed internally. Relative risk scores are calculated through the algorithms using data that is stored in the risk model databases. The risk scores can be compared among like-kind system assets to determine where additional preventative and mitigative measures are warranted and/or alternative system designs deployed to minimize risk. A risk profile is developed for the entire Columbia Gas pipeline system as part of the Columbia Gas Integrity Management Program (IMP), not just for High Consequence Areas. By its nature, risk assessment is a data intensive, data driven, integrated and iterative process. The process is dependent on the availability of accurate and representative data regarding the pipeline systems’ construction, materials, condition, operation and environment. As the various elements of the overall integrity management program move forward, and additional relevant data is collected and preventative and mitigative measures employed, new data is integrated into the Columbia Gas systems and utilized to model risk. This continuous data gathering and integration process helps identify and refine system-wide risk. The Columbia Gas risk discovery process is designed to prioritize covered pipeline segments in accordance with their calculated relative risk in relation to all covered segments. It should be noted that relative risk is not a calculation of the actual probability of occurrence; rather, it is a method used to compare and prioritize pipeline segments on a system-wide basis. The use of a relative risk scale provides customization based upon the Columbia Gas system and allows the comparison of the risk of one portion of the system to another portion of the system. The risk value generated through modeling is a unit-less number which provides a relative comparison of other results from the same model to produce a relative risk ranking. Relative risk scores generated by the Columbia Gas model cannot be compared to that of other operators or the numbers generated by other risk programs. Over the past several years, we have undertaken a comprehensive evaluation of our interstate transmission facilities and have identified areas for rehabilitation or replacement to modernize our system, improve system integrity, and enhance service reliability and flexibility. As the result of these efforts, we have identified specific rehabilitation and replacement projects, and launched a long term modernization program for completing such projects. Some of the initial projects involve the replacement of wrought iron pipe as well as the replacement of bare (uncoated) steel in High Consequence Areas. These segments represent some of the higher risk segments along the Columbia Gas pipeline system. Since 2012, Columbia Gas has been systematically planning, scheduling and/or implementing replacement of these high risk areas. In addition to modernizing our system assets, we continue to improve our integrity management processes, with the goal of establishing an industry-leading integrity management program. A core focus of this initiative has been to upgrade every element of the program plan and underlying procedures, as well as enhance the program’s supporting technology and business processes. As part of the upgrades, we have deployed an enhanced data management platform and are aggressively consolidating data sets and implementing several advanced visualization, analysis and data management technologies to ensure efficient data integration and decision making. In-Line Inspection (ILI) and corrosion survey data has also been incorporated into our Geographic Information System (GIS), enabling advanced data integration and analysis. Information captured in HCAs is now used to make integrity-related decisions on pipeline segments not located in HCAs. Alignment sheets integrating integrity data with other data sets including structures, land features, and pipe materials are now generated to make project and system improvement decisions, both in HCAs and along the entire Columbia Gas pipeline system. We are in the process of updating existing procedures, and developing additional procedures as necessary, to ensure that all integrity-related information gathered for pipelines located in HCAs is considered in the risk assessments and integrity management of other pipelines not located in high consequence areas. Finally, we are partnering with a data systems vendor to develop a first-of-its-kind advanced analytical program to better identify potential threats to the integrity of a pipeline. We have approved the proof of concept for this initiative and are in the process of finalizing the Statement of Work with the vendor selected. Columbia Gas will be working with the vendor to develop and implement the program throughout 2014, with full implementation scheduled for early 2015. While we remain focused on implementing improvements to facilities we own and operate, we are also sharing our experiences across the industry and driving positive change in several different ways. As an active leader within the Interstate Natural Gas Association of America, Columbia Gas personnel have been leading several industry initiatives within the larger Integrity Management Continuous Improvement program. These include increased focus on the integrity of older pipelines, verifying records and maximum operating pressures, improving valve automation and response times, and upgrading safety management systems. Columbia Gas is also leading a Southern Gas Association (SGA) workgroup focused on applying lessons learned from recent industry incidents. This effort will leverage the unique capabilities of SGA to engage a broad spectrum of companies across the gas transmission and distribution industries to advance safety management systems and best practices for preventing pipeline incidents. As we have discussed throughout the Sissonville investigation process, we remain committed to using this incident as a catalyst to improve safety practices at our company and across the natural gas pipeline industry. We appreciate the working relationship we developed with NTSB and look forward to advancing our common goal of protecting the public safety and reaching a zero incident environment. Addressee Organization Type: P-Private Industry Communication Date: 2015-01-15 Communication Type: Official Correspondence Communication Contents: -From Shawn L. Patterson, President, Operations and Project Delivery: Columbia Gas has a risk tool that evaluates all pipelines for risk regardless of HCA status. Columbia Gas currently uses a threat-based risk assessment model to quantify operational risk to its pipelines. The model breaks the entire pipeline system into dynamic segments for the risk assessment. Risk algorithms, originally developed around the threats identified in ASME B31.8S incorporate GIS data on pipeline attributes, past inspections, pressure tests, and the surrounding environment, nearby structures, and operating criteria to calculate a relative probability and consequences of failure. The risk scores are compared among like-kind system assets to identify areas where preventative and mitigative measures are warranted and/or alternative system designs incorporated to lower the operational risk. A risk profile is developed across the entire Columbia Gas pipeline system as part of the Columbia Gas Integrity Management Program (IMP), not just for High Consequence Areas (HCAs). Risk assessment is a data intensive, data driven, integrated and iterative process. The process is dependent on the availability of accurate and representative data regarding the pipeline systems’ construction, materials, condition, operation and environment. As the various elements of the overall integrity management program move forward, additional relevant data is collected, preventative and mitigative measures are employed, and new data is integrated into the Columbia Gas systems and used to model risk. This continuous data gathering and integration process helps identify and refine system-wide risk. In-Line Inspection (ILI) and corrosion survey data has been incorporated into our Geographic Information System (GIS), enabling advanced data integration and analysis. Information captured in HCAs is now used to make integrity-related decisions on pipeline segments not located in HCAs. Alignment sheets integrating integrity data with other data sets including structures, land features, and pipe materials are now generated to make project and system improvement decisions, both in HCAs and along the entire Columbia Gas pipeline system. We are in the process of updating existing procedures, and developing additional procedures as necessary, to ensure that all integrity-related information gathered for pipelines located in HCAs are considered in the risk assessments and integrity management of other pipelines not located in HCAs. In addition, to help further refine risk results, Columbia Gas is in the process of including 26 additional data elements to the existing risk algorithm. The addition of the 26 data elements will help to improve risk results and better define the potential risks on the pipeline. Of the 26 data elements, eight (8) of them have already been included into the risk algorithm. A detailed Action Plan has been developed for integrating the remaining 18 data elements and is expected to be completed by the end of 2015. Finally, Columbia Gas will continue to partner with a data systems vendor to develop a first-of-its-kind advanced analytical program to better identify potential threats to the integrity of a pipeline. Columbia Gas is working with the vendor to develop and implement the program throughout 2014, with full implementation scheduled for early 2015. While Columbia Gas remains focused on implementing improvements to facilities that are owned, operated, and maintained, Columbia Gas is also sharing these experiences across the industry and driving positive change in several different ways. As an active leader within the Interstate Natural Gas Association of America, Columbia Gas personnel have been leading several industry initiatives within the larger Integrity Management Continuous Improvement program. These include increased focus on the integrity of older pipelines, verifying records and validating maximum allowable operating pressures, improving valve automation and response times, and upgrading safety management systems. Columbia Gas is also leading a Southern Gas Association (SGA) workgroup focused on applying lessons learned from recent industry incidents. This effort will leverage the unique capabilities of SGA to engage a broad spectrum of companies across the gas transmission and distribution industries to advance safety management systems and best practices for preventing pipeline incidents. As discussed throughout the Sissonville investigation process, Columbia Gas remains committed to using this incident as a catalyst to improve safety practices at our company and across the natural gas pipeline industry. Columbia Gas appreciates the working relationship we developed with NTSB and look forward to advancing our common goal of protecting the public safety and reaching a zero incident environment. Addressee Organization Type: P-Private Industry Communication Date: 2016-04-13 Communication Type: Official Correspondence Communication Contents: -From Shawn L. Patterson, Executive Vice President and Chief Operating Officer, Operations and Project Delivery: Beginning mid-year 2014, Columbia Gas partnered with GE Digital Software and Accenture to develop a predictive analytics software platform, Intelligent Pipeline Solution (IPS), expected to improve the pipeline integrity and risk management programs. This advanced software application integrates relevant pipeline data from both external and internal source systems and increases risk resolution by overlaying data, spatially, onto the pipeline centerline. The application combines the visualization of GIS based tools with Google Map functionality and tactical information tables that display key integrity / risk related information. Data related to threats and consequence can be quickly identified from a map, by turning on layers, referring to data tables or by exporting the data to MS Excel. IPS offers immediate visualization of potential threats and consequences across all pipelines and improves the integrity and risk management programs by incorporating real-time data streams and refreshing all other data extracts on a daily basis; 1 ensuring that users have access to the latest information. The application is cloud based and acts as a system of reference, accessed through a web browser, making it available across the entire organization and mobile capable. Data sources to IPS currently include both internal and external data streams, such as: •?Work management system •?Leak reports •?Geospatial Information System (GIS) •?Past incidents / abnormal operations •?In-line inspection findings •?NOAA weather / precipitation •?SCADA (pressure, volume, temp, BTU) •?USGS fault lines •?One-call tickets •?USGS Streamflow In addition to the combined data streams and visualization of interacting threats, IPS includes a risk engine to quantify the impacts to the pipeline. With near real time data, risk calculations are performed daily, instead of annually, providing users with immediate indications and impacts related to changes in pipeline data or operating conditions. The GE risk engine is a semiquantitative model that includes both empirical and analytical threat algorithms that incorporate real-time information where available. Threat models address all of the threats defined in ASME B31.8S.2 Probability of failure results are expressed as relative scores and as an estimated failure rate per mile-year. Consequence is broken out for both leak and rupture cases. An initial version of IPS was released to an early adopter team within the Integrity Group in mid- 2015 for evaluation and, as of today, while the software is not fully implemented, it has gone through initial validations and is in use as new features are developed. At the current pace, the product is expected to deliver the next phase of features and enhancements by early 2017. IPS users have the ability to assess pipeline safety using data in a way that was not possible before and, as the software undergoes further development, Columbia Gas is working to formalize the processes around the use of this new risk tool. Columbia Gas will continue to provide updates to the NTSB on the progress towards completing this effort As IPS features continue to be implemented, Columbia Gas addresses its integrity management obligations through an index based risk model that assigns relative scores to all pipelines, regardless of class location or designation as High Consequence Area (HCA). HCA status is not a factor that is incorporated into the consequence model; therefore, the total risk values are independent of regulatory imposed definitions.3 Columbia Gas continues to rely on the index based risk model in its risk management program as it transitions to an active risk approach using IPS. The migration to an integrated data application, such as IPS, will allow engineers immediate access to all relevant and up-to-date integrity and risk information. Under this approach, critical data from one pipeline can be easily applied to the assessment of another, as will be discussed as part of this update. Recommendation P-14-4 asks that Columbia Gas ensure that all relevant integrity information associated with pipelines located in High Consequence Areas (HCAs) be applied to pipelines that are not subject to regulatory inspections. Columbia Gas believes this concept can be broadened through the use of IPS to make use of all relevant integrity-information, regardless of whether it was gathered in an HCA. The intent of P-14-4 is currently addressed, in IPS, through the use of layers and filters. An Integrity or Risk Engineer is able to turn-on specific threat and consequence layers anywhere along the pipeline and see both, the location and severity of the threat. Pipeline filters can also be applied to pinpoint pipeline segments with specific attributes, such as pipelines that are located within HCA’s or pipelines that have not been in-line inspected (Figure 2). Figure 3 represents a specific use-case related to the recommendation P-14-4. Parallel pipelines are shown (left) where only one of the three has undergone an in-line inspection. The metal-loss anomalies layer has been displayed over the pipeline centerline, highlighting the locations where metal loss features were identified from prior inspections. This metal-loss data, displayed in IPS, has gone through internal reviews and represents the most up-to-date information available.4 Each of the anomalies can be clicked to display detailed information about the feature in a pop-up dialogue box (Figure 3, right). The in-line inspection findings from one pipeline can be used in conjunction with other data in IPS and as part of a Risk or Integrity analysis of the adjacent pipelines that have not had an inline inspection. The use of multiple layer types improves the level of understanding about a particular pipeline. Layers, related to both threats and consequence, are available in IPS that allow users to perform a comprehensive analysis (Figure 4). As new datasets are identified and integrated into the platform, the list of available layers and filters will expand to include data such as geohazards5, soils information, major highways, seismic data, foreign line crossings and more. As mentioned previously, IPS quantifies the probability and consequence of failure, daily, to allow users to examine the risk of any pipeline. Changes made in any of the source systems are reflected in the next day’s risk values and available to the Integrity and Risk engineers for evaluation. The information is displayed in the threat and consequence charts and pipeline tables. Figure 5 shows how pipeline risk is broken out by threat category and displayed with current risk next to the prior day’s risk score. Additional details about the attributes, threats and risk results are located in a separate table below the chart. Realizing that data quality heavily influences the outputs from the risk engine, IPS includes a data confidence model so that users understand the impacts from the underlying data quality. Data quality initiatives are born from IPS when data quality is examined in conjunction with the risk scores. The features listed here are just a few of the capabilities being incorporated into IPS. In its current release cycle, IPS is developing a scenario based risk assessment tool or what-if feature. This functionality is also aimed at the lessons learned from the Sissonville incident and attempts to allow users to apply factors from one pipeline to another through the risk model in order to quantify the impacts to the threat profile and overall risk score. Columbia Gas believes that integrating all relevant data, in real-time, into a single tool with the ability to examine risk scores and visualize both threats and consequences to assess risk across the Columbia Gas footprint, is an improvement for the integrity and risk prog Addressee Organization Type: P-Private Industry Communication Date: 2015-03-17 Communication Type: Official Correspondence Communication Contents: We understand that you are in the process of developing new, and updating existing, procedures as necessary to address this recommendation. We note that you are including 26 additional data elements in the existing risk algorithm to better define potential risks on the pipeline and to improve risk assessment results, and that you expect to complete a detailed action plan for integrating data elements by the end of 2015. We also note that are working with a vendor to develop an advanced analytical program to better identify potential threats to pipeline integrity, and expect full implementation of the program this year. Pending completion of these efforts, Safety Recommendation P-14-4 is classified OPEN—ACCEPTABLE RESPONSE. We are pleased that you are sharing your actions and experiences with others in the industry and are leading several industry initiatives within the larger Integrity Management Continuous Improvement program, including increasing industry focus on the integrity of older pipelines, verifying records and validating maximum allowable operating pressures, improving valve automation and response times, and upgrading safety management systems. We are also pleased that you are leading a Southern Gas Association workgroup to apply lessons learned from recent industry incidents to advance safety management systems and best practices to prevent pipeline incidents across the gas transmission and distribution industries. Addressee Organization Type: P-Private Industry Communication Date: 2014-07-29 Communication Type: Official Correspondence Communication Contents: We are encouraged that you are using a threat-based risk assessment model, designed to prioritize covered pipeline segments in accordance with their calculated risk in relation to all covered segments. Further, you have evaluated your interstate transmission facilities, have identified specific rehabilitation and replacement projects to modernize your system, and have launched a long-term program to complete such projects. Your evaluation also identified ways in which you can improve system and management integrity and that you have identified ways to enhance service reliability and flexibility. We note that you have incorporated in-line inspection and corrosion survey data into your geographic information system, enabling advanced data integration and analysis, and that you use information gathered in HCAs to make integrity related decisions on pipeline segments not located in HCAs. We also note that you are working to develop a first-of-its-kind advanced analytical program to better identify potential threats to pipeline integrity and that full implementation of the program is scheduled for early 2015. Pending completion of these efforts, Safety Recommendation P-14-4 is classified OPEN—ACCEPTABLE RESPONSE. We are encouraged by your continued efforts to implement improvements to the facilities you own and operate, and by your promotion of positive change, your collaboration with the Interstate Natural Gas Association of America, and your commitment to leading industry initiatives within the larger Integrity Management Continuous Improvement program. We look forward to receiving periodic updates on your progress in implementing Safety Recommendations P-14-2 through -4. Addressee Organization Type: P-Private Industry Communication Date: 2016-05-18 Communication Type: Official Correspondence Communication Contents: We understand that, in 2014, you partnered with GE Digital Software and Accenture to develop a predictive analytics software platform, Intelligent Pipeline Solution (IPS), to improve the pipeline integrity and risk management programs. This software application integrates relevant pipeline data from both external and internal source systems and increases risk resolution by overlaying data spatially onto the pipeline centerline. It also combines the visualization of geographic information system?based tools with Google Map functionality and tactical information tables that display key integrity and risk-related information. Data related to threats and consequence can be quickly identified from a map, by turning on layers, referring to data tables, or exporting the data to MS Excel spreadsheets. Further, you integrated all relevant data into a single tool with the ability to examine risk scores and visualize both threats and consequences to assess risk across the Columbia Gas footprint in real time, giving your integrity and risk engineers immediate access to relevant data to make faster and better-informed decisions. In addition, as IPS continues to expand in functionality, through new feature development, you intend to further define and tailor your processes to ensure that these features are used to improve public safety. These actions satisfy Safety Recommendation P-14-4, which is classified CLOSED—ACCEPTABLE ACTION. - **truncated:** false - **body characters:** 27299