Proceedings of the 2012 9th International Pipeline Conference IPC2012 September 24-28, 2012, Calgary, Alberta, Canada

IPC2012-90406
INTEGRITY MANAGEMENT CONTINUOUS IMPROVEMENT
J. Andrew Drake Spectra Energy Houston, Texas, USA Daniel B. Martin El Paso Corporation Houston, Texas, USA Mark L. Hereth The Blacksmith Group/P-PIC Houston, Texas, USA Terry D. Boss INGAA Washington, D.C, USA Jeryl Mohn Mohn Consulting LLC Houston, Texas, USA

ABSTRACT 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 preregulation 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. INTRODUCTION Natural gas is a tremendous resource that will be a key to our nations energy future. It is abundant, affordable, clean and domestic. To realize its potential, natural gas must be delivered in a reliable and safe manner. Over time, we have seen the safety performance of pipelines steadily improve. From the inception of engineering standards in the 1930s, through the adoption of federal regulations in the 1970s, and integrity management today, there have been requirements to design, build, operate and maintain the natural gas infrastructure with integrity. Our improvement over the years has been the result of a concerted effort and, generally speaking, the pipeline industrys safety record is a good one. But, as we have seen recently, it is far from perfect.

Copyright 2012 by ASME

We still have work to do and we are committed to that work. 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. NGAAs board of directors adopted five aspirational, guiding principles, anchored by the goal of zero pipeline incidents. INGAAs Guiding Principles for Pipeline Safety 1. 2. 3. 4. 5. 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 industrys 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 levelso they understand and can participate in reducing risk.

TRANSPARENCY INGAA and its members are committed to being thought leaders in natural gas pipeline safety, and that role demands being transparent in our thinking, sharing our safety performance, and soliciting feedback and information from the other members of the pipeline safety community. Months before the filing deadline, INGAA filed policy-level comments1 on PHMSA dockets to inform other stakeholders of INGAAs positions and to provide a focal point for stakeholder feedback. INGAA and its members spent last summer and fall meeting with stakeholders, discussing proposals, exchanging information and views, and enhancing the process for implementing the IMCI plan to reflect what was heard. INGAA formed a team directed at collecting and analyzing data critical to supporting the IMCI work efforts and periodically communicating about safety performance; hence, the name of the team DATCOM. DATCOM efforts will concentrate in three areas; they are: 1. Support for and effectiveness of the IMCI teams, 2. Support for PHMSA in collecting data to meet their legislative mandates, and 3. Safety performance of INGAA and the industry. INGAA is actively promoting the guidance developed by the Pipelines and Informed Planning Alliance (PIPA).2 INGAA has formed a working group to work with public interest groups such as the Pipeline Safety Trust as well as PHMSA to define how to apply the recommendations developed by PIPA. EXTENDING INTEGRITY MANAGEMENT PRINCIPLES Current regulations apply to HCAs, appropriately capturing the goal of integrity management: protecting people on a risk-prioritized basis. INGAA and its members knew this was a beginning. The present HCA definition has already provided a kick start to applying integrity management principles outside of HCAs. A recent INGAA survey confirms that when the baseline assessments under the current Integrity Management Programs are completed (December 2012), more than 64 percent of total INGAA natural gas transmission mileage will have been assessed utilizing integrity management principles even though just over four percent of the mileage is located within HCAs. Based on the integrity management principle of continuous improvement, the IMCI action plans framework of voluntary commitments, summarized below, will apply integrity management principles to INGAA members entire natural gas transmission system, phasing in this expansion based on protecting people. PHMSA should use this framework, rather than redefining HCAs, to expand the application of integrity management principles to natural gas transmission pipelines.

With its goal and guiding principles established, INGAAs members developed a plan to put its aspirations into action. A task force of top pipeline executives developed an action plan that INGAAs board of directors formally adopted last July. The roadmap to achieving the goal of zero is integrity management and continuous improvement, IMCI, the name of the action plan. The technical steering team defined nine initiatives and assembled teams to address each area. This paper will report at a high level on the completion of work and the integration of efforts. Pipeline safety is a complex issue. Simple solutions or a one-size-fits-all approach will distract our focus and not yield sustainable improvements. This paper provides a summary of commitments made by INGAA members, progress on and plans of the work to achieve those commitments.

Copyright 2012 by ASME

1.

2.

3.

4.

INGAA IMCI Action Plan: Expansion of Integrity Management 90 Percent of Population Integrity Management Principles by 2012. By the end of 2012, INGAA members will have applied some degree of integrity management on pipelines covering roughly 90 percent of the population living within the PIR. Pipe inside an HCA will be subject to the processes required in 49 CFR Part192, Subpart O. Integrity management for pipe outside an HCA will range from full Subpart O, to either full American Society of Mechanical Engineers (ASME)/American National Standards Institute (ANSI) B31.8S3 or a focus on the most significant threats (e.g., Stress Corrosion Cracking (SCC) or corrosion). To cover 90 percent of population within the PIR, INGAA members will apply integrity management principles to roughly 60 percent of their total pipeline mileage. 90 Percent of Population Complete ASME/ANSI B31.8S by 2020. By 2020, INGAA operators will perform integrity management on pipelines covering 90 percent of the population living within the PIR. At a minimum, all ASME/ANSI B31.8S requirements will be applied, including mitigating corrosion anomalies and applying integrity management principles. 100 Percent of Population Integrity Management Principles by 2030 By 2030, INGAAs goal is to apply integrity management principles to pipelines covering 100 percent of the population living within the PIR. The integrity management principles applied to the increment between 90 percent and 100 percent of the population will draw upon ASME/ANSI B31.8S as well as improved and newly emerging pipeline assessment technology. To cover 100 percent of population within the PIR, INGAA members will apply integrity management principles to roughly 80 percent of their total pipeline mileage. Remaining 20 Percent of On-Shore Pipeline Miles with No Population The remaining 20 percent of on-shore pipeline miles with no population within the PIR pose a low risk to the public. In addition, this mileage poses significant technical challenges due to a number of factors, e.g., small diameter pipelines, multi-diameter pipelines, pipelines lines with low flow rate, complex geometry, and single-source feeds to customers (necessitating complete service disruptions). INGAAs members are committed to applying improved integrity management principles to these pipelines after 2030.

IMPROVED RISK ASSESSMENT AND INTEGRITY ASSESSMENT TOOLS A key to a well-run risk-management system is quality information about the inventory and characteristics of the pipeline. Knowledge gained during investigations of pipeline failures can help focus pipeline data collection efforts. Data collection and analysis are essential to effective risk assessment. ASME/ANSI B31.8S emphasizes the importance of collecting and utilizing data. One of the key lessons learned from the first 10 years of applying integrity management is the importance of collecting the right data. It also is imperative that the right data is integrated into an overall risk assessment. INGAA members are working collaboratively to develop tools and methods to better integrate data, not only to support risk analysis, but also to support decisions concerning the selection of post-assessment excavation sites and the prevention and mitigation measures that better manage threats to integrity. The data integration process must demonstrate how risk analysis is being applied on an ongoing and consistent basis. It must be reviewed and monitored by executive management. INGAA believes a need exists to apply progressively more advanced engineering and critical assessments within the framework of ASME/ANSI B31.8S and its revisions. Any system should include a basis for analyzing interacting threats. An INGAA team is examining how to improve evaluation and management of interactive threats. The team has joined an 18-month project through the INGAA Foundation being led by the Gas Technology Institute taking a renewed look at interactive threats. RECORDS VERIFICATION, MAOP VALIDATION AND MANAGEMENT OF PRE-REGULATION PIPE Transmission pipeline operators have used records management systems for acquiring and validating data for project work conducted on the pipeline system, including maintenance and integrity work, since their systems were initially constructed. From the 1920s and 1930s there have been consensus standards in place covering line pipe and appurtenances to provide guidance to operators individual procedures or specifications that define how line pipe and appurtenances (such as valves and fittings) are manufactured. These are complementary to an operators standards, procedures, specifications, and ultimately regulations that cover manufacture, installation, operation and maintenance as well. These specifications and procedures, including their data validation and documentation requirements, collectively form a quality management system. As these systems have evolved and become more robust and sophisticated, moving from widely scattered paperbased systems to the storage and registry of large amounts of electronic information, they are increasingly used for integrating this data. Improved data integration not only

Copyright 2012 by ASME

facilitates overlaying various data aspects and attributes, but also enhances the assessment of data consistency and the identification of data discrepancies for resolution. Such systems also facilitate the availability of information and data to the people who need it for assessment and decision making on remediation, prevention and mitigation of threats. INGAA is currently working on guidelines for operators to use to determine whether the appropriate systems are in use and whether they are being employed appropriately for maximum effectiveness. Operators design the data storage indexing and analysis portions of their records management systems to satisfy ongoing needs. As analytic or regulatory requirements change, these systems have to be redesigned. For example, the amount of information needed for reference and analysis has changed considerably from what was needed three decades ago, so operators had to reorganize their record keeping systems completely. In January 2011, PHMSA issued an Advisory Bulletin (ADB-11-01)4 directing operators to ensure their pipeline records are traceable, verifiable and complete. Since then, INGAA members have made a concerted effort to reorganize, validate and index historical records, such as mill inspection reports and hydrostatic pressure test records. Transmission operators are undertaking a physical review of historical records, and the results are being used to document and verify the pipe attribute data used in operator data systems, geographical information systems (GIS) and integrity management programs. These efforts have received significant support within the IMCI structure, including a workshop on various methodologies and techniques in the Fall of 2011. Extensive data reviews by INGAA members have shown that most of the pipeline data required to calculate maximum allowable operating pressure and perform threat assessments is available in various forms. However, some pipe properties and elements can be verified only through direct or indirect examination, while certain data elements cannot be evaluated or may be difficult to positively determine through nondestructive inspection. Examples of data elements that may not be easily independently verified with nondestructive methods include actual pipe grade, seam type (in some instances), year of installation, and mechanical and chemical properties. A process was developed to address the fitness for service (FFS) of pre-regulation pipe given concerns raised by the 2011 Advisory Bulletin, the National Transportation Safety Board (NTSB) following their investigation of the Pacific Gas and Electric Incident in San Bruno, California, and Section 23 of the recently enacted pipeline safety legislation, Pipeline Safety, Regulatory Certainty and Job Creation Act of 2011. The process is designed to make use of existing records and where records do not exist demonstrating a historical pressure test,

moves the operator in a direction such that each decision becomes more and more conservative. FFS is an accepted set of processes to demonstrate the mechanical integrity of in-service equipment, including pipelines. FFS analysis is specifically designed and has been demonstrated to support decisions on future disposition of equipment. The methods currently used in FFS evaluations have been applied in the petroleum refining, petrochemical, nuclear, paper and steam electric power industries as well as the pipeline industry since the 1980s. One of the first acknowledged threat specific applications was actually in the pipeline industry with the development of ASME B31G, a method for calculating the remaining strength of pipelines in areas with metal loss, first published in 1984. In the late 1990's, subject matter experts across a number of these industries created a compendium of methods to address a breadth of flaw types. The document was first published in 2000, as American Petroleum Institute (API) recommended practice (RP) 579. It was updated in 2007 and again in 2010 through a joint effort between API and the ASME and published as API RP 5791/ASME FFS 1. Implementing the FFS process will require time to evaluate pipelines in a prioritized manner, manage customer service impacts and implement necessary actions. At a high level there are eight cases addressed by the process, they are: 1. Pipe segments in HCAs, Class 3 or 4 that have a strength test to at least 1.25xMAOP can continue to operate under 49 CFR 192, subject to the Continual Evaluation requirements of 49 CFR 192.937. 2. Pipe segments in HCAs, Class 3 or 4 that have a strength test to at least 1.1xMAOP that are piggable can: a. Conduct a pressure test to 1.25xMAOP, b. Run ILI that identifies and characterizes long seam and pipe body anomalies, c. Reduce pressure to 80% of the established MAOP or d. Replace the pipe not meeting these conditions. 3. Pipe segments in HCAs, Class 3 or 4 that have a strength test to at least 1.1xMAOP that are not piggable or those that do not have a strength test of at least 1.1xMAOP can: a. Conduct a pressure test to 1.25xMAOP, b. Reduce pressure to 80% of the established MAOP or c. Replace the pipe not meeting these conditions. 4. Pipe segments in Class 1 or 2 that have a strength test to at least 1.1xMAOP that do not contain pipe with known long seam issues can continue to operate under 49 CFR 192.

Copyright 2012 by ASME

5.

6.

7.

8.

Pipe segments in Class 1 or 2 that contain pipe with known a history of long seam issues that are also piggable can: a. Run ILI that identifies and characterizes long seam and pipe body anomalies, b. Conduct a pressure test to 1.25xMAOP, reduce pressure to 80% of the established MAOP or c. Replace the pipe not meeting these conditions. Pipe segments in Class 1 or 2 that contain pipe with known a history of long seam issues that are nonpiggable segments can: a. Conduct a pressure test to 1.25xMAOP, b. Reduce pressure to 80% of the established MAOP or c. Replace the pipe. Pipe segments in Class 1 or 2 that contain pipe with no known history of long seam issues can continue to operate under 49 CFR 192, subject to the Continual Evaluation requirements of 49 CFR 192.937. Pipe segments that are not HCAs, Class 3 or 4, operating below 30% SMYS can continue to operate under 49 CFR 192, subject to the Continual Evaluation requirements of 49 CFR 192.937.

(ILI) platforms, including a timeline for implementation of the advanced platforms. A team is working with ILI providers to improve the identification and characterization of long seam and girth weld anomalies that would pose a threat to integrity by taking advantage of multiple technologies. MANAGEMENT SYSTEMS AND SAFETY CULTURE Management systems are central to pipeline system assets throughout their lifecycle. As part of the IMCI initiative, INGAA formed one team to examine how management systems can be applied more broadly in verifying pipeline integrity. There was a second team formed with a more tightly focused scope on how quality management system (QMS) can be applied to improve pipeline construction. The value of a management system in verifying pipeline integrity was recognized during the development of ASME/ANSI B31.8S. Four elements of a management system, quality assurance/quality control, management of change, communication and performance measurement were embodied into ASME/ANSI B31.8S when initially published in 2002, to provide a first step of integrating a management system as part of verifying pipe line integrity. These elements of the standard have already been incorporated into regulation by PHMSA. The IMCI team working on management systems began its work by providing guidelines on improving safety culture, and improving management of change practices. The team began with safety culture as many INGAA members have embraced a goal of zero incidents within their personnel safety programs. Understanding how operators have designed their personnel safety programs to achieve the goal of zero was the place to begin working, as safety culture is one element of a broad-based management system. The team developed an overview of management systems in industries where the consequences of failure can be unacceptable, including the chemical manufacturing, petroleum refining, nuclear power, and aviation industries, as well as the medical field. In many instances, the regulators in these industries have elected to use management systems to audit and evaluate the effectiveness of safety, as well as environmental programs. Standards reviewed included those of the Federal Aviation Administration, the Occupational Safety and Health Administration, and the Environmental Protection Agency, as well as those adopted by leading companies in chemical manufacturing, petroleum refining, nuclear power, and aviation industries, as well as the medical field. VALVES AND INCIDENT MITIGATION MANAGEMENT Valve spacing, selection and operation are all important but they only address one aspect of mitigating the consequences of an incident. To achieve the comprehensive response this issue deserves, incident mitigation is best handled through the creation and implementation of an approach referred to as Incident Mitigation Management (IMM)

An operator can always choose to conduct a 49 CFR 192, Subpart J pressure test and demonstrate fitness to operate at its MAOP. The FFS process prioritizes the right place to start as pipelines within HCAs that have incomplete strength test records. The testing, repair, remediation or replacement of these pipelines within HCAs will be accomplished over a defined time frame, and during that period findings will be continually evaluated to derive lessons learned for future work. Implementing the FFS process will require time to evaluate pipelines in a prioritized manner, manage customer service impacts and implement necessary actions. RESEARCH, DEVELOPMENT AND COMMERCIALIZATION The phasing strategy employed in extending integrity management principles and managing pre-regulation pipe is based on anticipated improvements and availability of technology and processes in the future. INGAA and its research partners have begun development a road map for the requisite research and development. To help meet this aggressive goal, INGAA is engaging the research community and technology providers to improve and develop new inspection and assessment tools (platforms as well as sensors) that can reliably address hard-to-assess areas. This effort is consistent with Recommendation P-11-32 from the National Transportation Safety Boards San Bruno investigation report, which asks INGAA and the American Gas Association to report on the development and introduction of innovative in-line inspection

Copyright 2012 by ASME

developed by an INGAA team. Operators will develop plans that are built on the risk management principles and performance objectives that underlie operators baseline assessment plans and other elements of their IM programs. IMM plans provide a comprehensive approach to incident mitigation. IMM plans would use information from previous risk assessments to help drive decisions for targeting mitigation improvements. These decisions would include various components of incident management, including methods for detecting ruptures; decision criteria for activating mainline isolation valves; standards governing the placement, automation and remote operation of valves; procedures for quickly evacuating the gas from affected segments to make them safe for responders; and procedures that strive to expand operators coordination efforts with emergency responders. IMM is consistent with INGAAs commitment to shorten pipeline isolation and response time to one hour in populated areas, and, being performance-based, IMM will produce a far better public safety outcome than prescriptive valve placement requirements. Operators would integrate IMM plans with existing integrity management and risk management plans, with all of them designed both to identify and rank risk and to design appropriate prevention and mitigation efforts. IMM plans would also incorporate the portions of operators public awareness plans addressing outreach and communication with various emergency responders. IMM plans would set out approaches that, in the unlikely event of a failure, would maximize the mitigation of consequences. Each plan would contain an implementation priority, so its substantive provisions would be implemented first where consequences of a failure are greatest. While the initial effort would focus on pipeline in HCAs, operators would strive to consult with emergency responders to see if any priorities should be adjusted. IMM plans would include: Criteria governing the operators decisions on types and locations of automatic and/or remote valves, including crossover operation The location of any connecting distribution lines and the potential for back flow Standards for operating looped lines or other take offs as common or separate and the effect on identifying a rupture Standards for preparing gas controllers to act on valve closure, including decision support Plans for responding to specific locations, including after-the-fact evaluation of response times Priorities for determining the need and timing for automation The design philosophy for how a type of operator is

chosen (manual, automatic control or remote control) Procedures for evacuating gas and rendering locations safe for responders, including the use of blow-off valves An analysis of component and system reliability and an overall hazard assessment that considers potential nuisance failures of automated valves, including consideration of the relative consequences of a delayed closure vs. an unintended, inappropriate closure A planned, coordinated communication process with emergency responders A training process for improving the situational awareness of gas controllers A process for consulting with local 911 districts on notification procedures An approach to increasing the awareness of first responders to pipeline location, product, diameter; the location of valves, boxes and vaults; the approximate time to isolate; and any other factors determined to be of interest at the local level A plan for training, tabletop and full-scale emergency exercises with responders, as appropriate and as responders are willing and able, planned on a risk-tiered basis

CONSTRUCTION QUALITY AND MATERIAL PROCUREMENT QUALITY MANAGEMENT SYSTEMS Implementing a QMS on pipeline construction projects improves material and construction quality by providing a structured approach to quality management. Through effective QMS, pipeline construction project sponsors can achieve consistent conformance to established quality standards and specifications, reducing rework and unexpected material quality and construction issues. Project sponsors, suppliers, contractors and service providers, all need to work together to embrace higher standards of quality through the application of QMS principles. Achieving a consistent and uniform level of quality management across the pipeline construction industry is a challenge well suited for the INGAA Foundation, Inc. (Foundation), which represents pipeline operators, suppliers, contractors and service providers. INGAA formed the Foundation in 1990 to advance the use of natural gas and to facilitate the efficient construction and safe, reliable operation of the North American natural gas pipeline system. The Foundation has proven to be an effective forum to tackle construction issues because all key industry sectors are represented. The Foundation has sponsored and will continue to sponsor workshops aimed at achieving a consistent and uniform level of quality management across the pipeline construction industry.

Copyright 2012 by ASME

The Foundation also has successfully addressed similar challenges in other areas, including environmental construction requirements promulgated by the Federal Energy Regulatory Commission, project permitting and pipe quality. The Foundation published five white papers related to QMS in early 2012, each addressing different elements of improved construction practices. These Foundation white papers are: 1. Overview of Quality Management Systems Principles and Practices for Pipeline Construction5 2. Pipeline Construction, Fabrication, and Testing Training Guidance for Construction Workers and Inspectors for Welding and Coating6 3. Field Applied Coatings Best Practices7 4. Best Practices in Applying API 1104, Appendix A8 5. Specification and Purchase of Segmentable Induction Bends and Elbows9 UNDERGROUND STORAGE A collaboration of interested stakeholders, including regulators, is developing a risk-based ANSI certified standard governing the operational integrity of interstate underground natural gas storage facilities. INGAAs underground gas storage operators have achieved an admirable track record of facility integrity and safety over their decades of operating history. This strong level of performance has been accomplished through the development of and conformance to sound engineering practices that are both geographically and geologically appropriate. The safety and integrity of the nations underground gas storage infrastructure will be further enhanced by the development and application of a recognized industry standard that is based on the collective operating experience of INGAAs members and others and that provides all operators with flexible, performance based methods for the monitoring and assessment of storage facility operational integrity. The process is being stewarded by the American Petroleum Institute (API), with work having commenced in 2012 and a targeted duration for completion of 18 24 months. The final result envisioned is an API Recommended Practice (RP), similar in nature to the API RP 1114 and 1115, which were developed for liquid products storage in leached caverns. A strong, performancebased federal standard would ensure that broad industry knowledge and experience is fully leveraged and maximized, that flexible, appropriate and effective methodologies for operational integrity management are achieved at a national level and that the duplication of effort and the complexity of managing multi-jurisdictional regulation are minimized.

CONCLUSION This paper describes the plan to put the INGAA Boards aspirations into action and work towards achieving the ultimate goal of zero. It provides a summary of work completed as well as on-going and future work being conducted by nine teams under the auspices of INGAA IMCI. ACKNOWLEDGMENTS The authors wish to acknowledge the technical input and review provided by members of INGAA Integrity Management Continuous Improvement Initiative Steering Team including, Pete Kirsch, Bill Taylor and Chris Bullock, CenterPoint Energy; Bennie Barnes, Daron Moore and Charlie Childs, El Paso; Vern Meier and David Chittick, TransCanada; Eric Amundsen and David Johnson, Energy Transfer;, Larry Hjalmerson, Joe Neave, Greg Ford and Kevin Wilson, Williams; Susan Waller and Robert Travers, Spectra Energy; Chad Zamarin, NiSource; Mike McGonagill, and Tracey Scott, Alliance; and, Stacey Gerard, Bernie Selig and Keith Leewis, P-PIC. REFERENCES 1. Interstate Natural Gas Association of America, Policy Level Comments, filed with the U.S. Department of Transportation, Pipelines and Hazardous Materials Safety Administration, on an Advanced Notice of Proposed Rulemaking, Safety of Gas Transmission Pipelines, Docket No. PHMSA-2011-0023, November 2, 2011. 2. U.S. Department of Transportation, Pipelines and Hazardous Materials Safety Administration, Partnering to Further Enhance Pipeline Safety In Communities Through Risk-Informed Land Use Planning: Final Report of Recommended Practices, November 17, 2010. 3. Anon., Managing System Integrity of Gas Pipelines, Supplement to Gas Transmission and Distribution Piping Systems, American Society of Mechanical Engineers Code for Pressure Piping, B31.8S-2010, ASME, New York, New York 10016. 4. Anon., Pipelines and Hazardous Materials Safety Administration, U.S. Department of Transportation, Advisory Bulletin ADB-11-01, January 10, 2011. 5. INGAA Foundation, Overview of Quality Management Systems Principles and Practices for Pipeline Construction, May 1, 2012. 6. INGAA Foundation, Pipeline Construction, Fabrication, and Testing Training Guidance for Construction Workers and Inspectors for Welding and Coating, 2012. 7. INGAA Foundation, Field Applied Coatings Best Practices, March 13, 2012 8. INGAA Foundation, Best Practices in Applying API 1104, Appendix A, 2012. 9. INGAA Foundation, Specification and Purchase of Segmentable Induction Bends and Elbows, Phase 1 and Phase 2, developed by a Joint Industry Project, DNV, Columbus, Ohio, December 6, 2011.

Copyright 2012 by ASME