NTSB Safety Recommendation P-15-026

NTSB safety recommendation P-15-026.

TO THE INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA: Work with the American Gas Association to develop and implement a strategy for increasing the use of in-line inspection tools as appropriate, with an emphasis on intrastate pipelines.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2015-02-10

Adopted Date: 2015-01-27

Overall Date Closed: 2017-03-08

Synopsis: There are approximately 298,000 miles of onshore natural gas transmission pipelines in the United States. Since 2004, the operators of these pipelines have been required by the Pipeline and Hazardous Materials Safety Administration (PHMSA) to develop and implement integrity management (IM) programs to ensure the integrity of their pipelines in populated areas (defined as high consequence areas [HCAs]) to reduce the risk of injuries and property damage from pipeline failures. An operator’s IM program is a management system designed and implemented by pipeline operators to ensure their pipeline system is safe and reliable. An IM program consists of multiple components, including procedures and processes for identifying HCAs, determining likely threats to the pipeline within the HCA, evaluating the physical integrity of the pipe within the HCA, and repairing or remediating any pipeline defects found. These procedures and processes are complex and interconnected. Effective implementation of an IM program relies on continual evaluation and data integration. The IM program is an ongoing program that is periodically inspected by PHMSA and/or state regulatory agencies to ensure compliance with regulatory requirements.

Ntsbnumber: DCA14SS002

Report Number: SS-15-01

Addressee Name: Interstate Natural Gas Association of America

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2017-03-08

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2016-12-30

Communication Type: Official Correspondence

Communication Contents: -From Dave McCurdy, President and CEO, American Gas Association and Donald F. Santa, Jr., President and CEO, Interstate Natural Gas Association of America: In response to the safety study on Integrity Management of Gas Transmission Pipelines in High Consequence Areas, the National Transportation Safety Board (NTSB) issued a series of recommendations, four of which were directed to the American Gas Association (AGA) and Interstate Natural Gas Association of America (INGAA). Two of these recommendations directed AGA and INGAA to work with each other “to develop and implement a strategy for increasing the use of in-line inspection tools as appropriate, with an emphasis on intrastate pipelines.” (P-15-24 and P-15-26) AGA and INGAA agree on the importance of our roles as trade associations in promoting the use of In-Line Inspection (ILI) tools in the interests of elevating safety in the natural gas industry. Thus, we have developed and implemented a comprehensive strategy for encouraging the continuous advancement of the use of ILI tools for intrastate transmission lines. The strategy focuses on leveraging the associations’ membership networks to facilitate dialogue on three areas critical to increasing the use of ILI tools under pipeline integrity management: 1. Highlighting New Tools and Technologies 2. Addressing Significant Challenges that Deter the Use of ILI 3. Increasing Awareness of and Confidence Around Expanding the Use of ILI Tools and Technologies The Associations have worked diligently to feature presentations and information-sharing on these topics through industry conferences, workshops, and committee meetings. Significant advancements have been made in increasing the use of ILI tools on intrastate transmission pipelines, and the associations expect these advancements to continue as the AGA and INGAA strategy continues to be implemented. The following memorandum describes the comprehensive strategy and the actions of AGA and INGAA to assist in increased usage of in-line inspection tools with an emphasis on intrastate pipelines. Based on these actions, we request that the NTSB designate recommendation P-15-24 and P-15-26 as "Closed-Acceptable Response". Please let us know if you have any questions. We are available to meet with you to discuss the subject matter of this written response.

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2016-06-15

Communication Type: Official Correspondence

Communication Contents: -From Dave McCurdy, President and CEO, American Gas Association and Donald F. Santa, Jr., President and CEO, Interstate Natural Gas Association of America: AGA and INGAA share the same goal as the NTSB in assuring the safe and reliable delivery of clean natural gas to the 70 million homes and businesses across the country that rely on this energy. Since receiving the NTSB recommendations, AGA and INGAA have been actively working with industry stakeholders to identify a comprehensive plan and specific actions that will enable NTSB to close these recommendations. We have conducted outreach to natural gas pipeline operators, in-line-inspection service providers, industry research & development organizations, academia, pipeline safety regulators, and others that can contribute to AGA and INGAA’s formal response to the NTSB safety recommendations. We are nearing completion on a draft response to P-15-24 and P-15-26 and we anticipate sending you our official response later this summer. We are also making progress on a response to P-15-23 and P-15-25 and we anticipate sending you our official response this fall. AGA and INGAA will be reaching out to NTSB staff to share a draft outline for our formal response to the NTSB recommendations in order to verify that we are on the right path to meeting the intent of the recommendations.

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2017-03-08

Communication Type: Official Correspondence

Communication Contents: We understand that INGAA and the AGA worked with industry stakeholders to identify a comprehensive plan and to develop specific actions to address these recommendations. In so doing, you reached out to natural gas pipeline operators, in-line-inspection service providers, industry research and development organizations, academia, pipeline safety regulators, and others that can contribute to joint action on these issues. You also collected data to support the development of probabilistic risk assessment models, which you will share with gas transmission pipeline operators, and you developed and implemented a strategy to increase use of in-line inspection tools, with an emphasis on intrastate pipelines. Because these actions satisfy the intent of Safety Recommendations P-15-25 and -26, they are classified CLOSED—ACCEPTABLE ACTION.

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2016-05-19

Communication Type: Official Correspondence

Communication Contents: Recipients of our safety recommendations typically complete action to address them within 3 to 5 years. Although we issued these recommendations to you over a year ago, we have received no reply from you regarding your actions or intentions to address either Safety Recommendation P 15-25 or -26. Accordingly, we would appreciate receiving a prompt update on your plans and actions to satisfy them. We are interested in knowing whether and how our recommendations are implemented, both to ensure the public the highest level of safety and to identify creative solutions that can be shared with others. Safety Recommendations P-15-25 and -26 are currently classified OPEN—AWAIT RESPONSE; unless we receive a timely reply from you, we may have to classify these recommendations in an unacceptable status.

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2016-08-02

Communication Type: Official Correspondence

Communication Contents: We understand that INGAA and AGA have been actively working with industry stakeholders to identify a comprehensive plan and specific actions to address these recommendations. We note that you have conducted outreach to natural gas pipeline operators, in line-inspection service providers, industry research and development organizations, academia, pipeline safety regulators, and others that can contribute to INGAA and AGA action on these issues. We are encouraged that you expect to update us on your actions to address Safety Recommendations P 15-24 and -26 later this summer, and on your actions to address Safety Recommendations P-15-23 and -25 sometime this fall. Pending our receipt of those updates, Safety Recommendations P-15-23 through -26 are classified OPEN—ACCFEPTABLE RESPONSE.

Addressee Acronym: INGAA

Addressee Organization Type: A-Associations

Communication Date: 2016-07-29

Communication Type: Official Correspondence

Communication Contents: We understand that INGAA and AGA have been working with industry stakeholders to identify a comprehensive plan and develop specific actions to address these recommendations. We note that you have reached out to natural gas pipeline operators, in-line-inspection service providers, industry research and development organizations, academia, pipeline safety regulators, and others that can contribute to your joint action on these issues. We are encouraged that you expect to update us on your actions to address Safety Recommendations P-15-24 and -26 this summer, and that you plan to update us on your actions regarding Safety Recommendations P-15-23 and -25 this fall. Pending our receipt of those updates, Safety Recommendations P-15-23 through -26 are classified OPEN—ACCEPTABLE RESPONSE.