Integrity Management Continuous Improvement

At the end of 2010, recognizing that the baseline period for the integrity management of high consequence areas (HCAs) along natural gas transmission pipelines in the United States was nearly complete, INGAA members decided to reflect on the accomplishments of the first eight years and define where the overall integrity of systems could be improved. High profile incidents such as the one on the PG&E system in California heightened the need for such an analysis. There was a conscious decision to define a future path as the industry had done on many other occasions, and not simply wait for legislation and regulation. A Board level task force was formed to provide guidance and oversight and a technical steering team was constituted under the direction of Andy Drake of Spectra Energy. The technical steering team met for two months and defined a set of guiding principles and nine initiatives and assembled working groups to address each area. This paper will report at a high level on the completion of work and the integration of efforts. The first initiative is directed at improving the transparency by periodically and formally sharing measures of performance, and actively promoting the guidance developed by the Pipelines and Informed Planning Alliance (PIPA). A second initiative is directed at defining a path to extend integrity management principles beyond HCAs. A third initiative has been undertaken to examine how we can improve the tools applied in managing threats to integrity and analysis of data derived from the tools to address uncertainty. The PG&E incident showed us the need to define a process for evaluating records for pre-regulation pipe and managing pre-regulation pipe. While the role of hydrostatic testing is clear, the investment that has been made in making systems piggable has created the opportunity for a fourth initiative to define requirements for historical records and how in-line inspection can play a role in managing pre-regulation pipe. The focus of improving tools and evaluation techniques surfaced a need to intensify our efforts in research, development and commercialization. A fifth initiative has been undertaken to develop a road map for research, development and commercialization. In developing the guiding principles we studied other industries that have worked to define ways of improving safety performance, especially those where the cost of failure is unacceptable in the public eye. These included commercial aviation, medical, chemical and petroleum refining and nuclear. It has become clear that a focus on safety culture and ultimately application of a management system is a means of improving safety performance, and a sixth initiative has been undertaken to address the role of safety culture and more broadly management systems. A seventh initiative has been undertaken to examine ways to improve emergency response effectiveness including the use of automated valves, integrated mitigation plans and enhanced public awareness. There were a series of projects undertaken in 2009 and 2010 as an eighth initiative conducted under the auspices of the INGAA Foundation directed at improving material procurement and construction. Recognizing challenges in storage field operations and the criticality of storage in maintaining gas supply, a ninth initiative has been undertaken to clarify regulatory oversight of storage facilities.