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

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

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

4. Safety Study vs. Accident Investigation DifferencesDifferences Proactive vs. reactiveProactive vs. reactive Breadth vs. depthBreadth vs. depth “Parties” to investigation“Parties” to investigation SimilaritiesSimilarities Written reportWritten report Findings and safety recommendationsFindings and safety recommendations Public board meetingPublic board meeting 4

5. Safety Study Process Internal assessment of topic suitabilityInternal assessment of topic suitability Board approval of research proposalBoard approval of research proposal Field work and analysisField work and analysis Internal and external technical reviewInternal and external technical review Board meetingBoard meeting Safety advocacySafety advocacy Tracking of safety recommendationsTracking of safety recommendations 5

6. Recent Safety Studies Safety of Experimental Amateur-Built AircraftSafety of Experimental Amateur-Built Aircraft Curbside Motorcoach SafetyCurbside Motorcoach Safety Crashes Involving Single-Unit TrucksCrashes Involving Single-Unit Trucks 6

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

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

9. 16 Integrity Management Program Elements Identification of all high consequence areas Baseline Assessment Plan Identification of threats to each covered segment, including by the use of data integration and risk assessment 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 A performance plan including the use of specific performance measures Recordkeeping provisions 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 9

10. Focus on Select Elements Identification of all high consequence areas Baseline Assessment Plan Identification of threats to each covered segment, including by the use of data integration and risk assessment 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 A performance plan including the use of specific performance measures Recordkeeping provisions 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 10

11. Focus Areas 11

12. Quantitative & Qualitative Research 12 Incidents Annual Reports NPMS Progress Reports Enforcement Accident Reports Literature Operators Industry Associations Researchers Inspectors Relevant Firms NTSB Investigators ReviewData AnalysesInterviews & Discussions Technical Review OperatorsInspectors

13. Operators’ Perspectives 7 companies7 companies IM plans and relevant documentsIM plans and relevant documents Semi-structured discussion with focus topicsSemi-structured discussion with focus topics Multiple staff with various responsibilitiesMultiple staff with various responsibilities DemonstrationDemonstration Historical, current, and futureHistorical, current, and future Follow-up questionsFollow-up questions Participated in external technical reviewParticipated in external technical review 13

14. Inspectors’ Perspectives Federal inspectors and regulatorFederal inspectors and regulator Teleconference with regional directors and inspectorsTeleconference with regional directors and inspectors Close coordinationClose coordination State inspectorsState inspectors 5 states5 states NAPSRNAPSR 14

15. Safety Recommendations 28 new recommendations28 new recommendations 22 to PHMSA22 to PHMSA 2 to AGA2 to AGA 2 to INGAA2 to INGAA 1 to NAPSR1 to NAPSR 1 to Federal Geospatial Data Committee1 to Federal Geospatial Data Committee 1 reiterated recommendation to DOT1 reiterated recommendation to DOT 15

16. HCA Identification Dependent on GIS and geospatial dataDependent on GIS and geospatial data Need of bufferingNeed of buffering Identified sitesIdentified sites 16

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

18. Threat Identification & Risk Assessment Eliminating a threat from considerationEliminating a threat from consideration Interactive threatInteractive threat Dynamic segmentationDynamic segmentation Complex risk assessmentComplex risk assessment Relative risk approach versus othersRelative risk approach versus others Use of “weights”Use of “weights” Consequence of failureConsequence of failure Desire for probabilistic modelDesire for probabilistic model 18

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

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

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

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

23. Data Integration Vaguely defined, hard to evaluationVaguely defined, hard to evaluation Emergence of GISEmergence of GIS Authoritative data source within the organizationAuthoritative data source within the organization Empowering stakeholders at all levels within the organizationEmpowering stakeholders at all levels within the organization Very different levels of adoptionVery different levels of adoption 23

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

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

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

27. Data Collection & Analysis Add HCA method, risk assessment method, and piggable pipe mileage to annual report form (PHMSA)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)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)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)In NPMS, add HCAs and increase positional accuracy of data (PHMSA) 27

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

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

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