1. Interstate Natural Gas Association of America INGAA Action Plan to Build Confidence in Pipeline Safety INGAA Integrity Management Continuous Improvement November, 2011

2. 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. 2

3. INGAA Members 9 Step Action Plan 3  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

4. Extend Risk Management 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 4 Apply Risk Management beyond High Consequence Areas (HCAs)

5. Demonstrate Fitness for Service on Pre-Regulation Pipelines Verify Integrity of Older 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 5

6. Shorten Pipeline Isolation and Response Time to 1 Hour in Populated Areas Mitigate Consequences of Incidents 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 6

7. What is Needed? Holistic Approach to Pipeline Safety 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 7 Effective pipeline safety is a shared responsibility - and requires active engagement between operators, the government and the public

8. 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=PHMSA- 2011-0023 http://www.regulations.gov/#!searchResults;rpp=10;po=0;s=PHMSA- 2011-0023 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 8

9. 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 9

10. Appendix 10

11. Raise the Standards for Corrosion Anomaly Management Manage Corrosion Anomalies INGAA member commitments: Apply the standard for corrosion anomaly management outside HCAs to the same as used inside HCA 11

12. Improve Integrity Management Communication and Data Collect & Use Pipeline Data INGAA member commitments: Improve data collection and analysis, convert this data into meaningful industry information and communicate it to stakeholders 12

13. Implement the PIPA Guidance Implement Best Practices 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 13

14. Evaluate, Refine and Improve Threat Assessment and Mitigation Advance Understanding of Threats 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 14

15. Raise the Standard for Use of Management Systems across INGAA Members Foster a Culture of Continuous Improvement 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 15

16. Provide Forums for Information Exchange with Stakeholders Engage Public Officials INGAA member commitments: Support and sponsor emergency preparedness workshops highlighting lessons learned and current issues 16

17. 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 17