December 30, Christopher A. Hart National Transportation Safety Board Washington, DC 20954

Transcription

1 December 30, 2016 Christopher A. Hart National Transportation Safety Board Washington, DC Re: Joint INGAA and AGA Response to Safety Recommendations P and P Chairman Hart, The Interstate Natural Gas Association of America (INGAA) and the American Gas Association (AGA) respectfully submit this response to the National Transportation Safety Board (NTSB) Safety Recommendations P and P These recommendations were issued to AGA and INGAA on February 10, 2015 as a result of the safety study Integrity Management of Gas Transmission Pipelines in High Consequence Areas. INGAA is a trade association comprised of 25 members, representing the vast majority of the interstate natural gas transmission pipeline companies in the U.S. and comparable companies in Canada. INGAA s members operate approximately 200,000 miles of pipelines, and serve as an indispensable link between natural gas producers and consumers. AGA represents more than 200 local energy companies that deliver natural gas throughout the United States. There are more than 72 million residential, commercial and industrial natural gas customers in the U.S., of which 95 percent just under 69 million customers receive gas from AGA members. The North American natural gas pipeline system is an energy highway integral to U.S. energy infrastructure. AGA and INGAA agree on the importance of our roles as trade associations in promoting tools for enhancing risk assessment and modeling in the interests of elevating safety in the natural gas industry. AGA, INGAA, and their members have a long history of working collaboratively with a variety of stakeholders to enhance risk modeling and risk assessment for natural gas pipelines, including the U.S. DOT (PHMSA), the NTSB, and State agencies. The following memorandum describes the comprehensive strategy and the actions of AGA and INGAA to assist in improving the availability and quality of data for gas pipeline risk modeling. Based on these actions, we request that the NTSB designate recommendation P and P 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. Sincerely, Dave McCurdy President and CEO American Gas Association Donald F. Santa, Jr. President and CEO Interstate Natural Gas Association of America cc: The Honorable T. Bella Dinh-Zarr cc: The Honorable Robert L. Sumwalt cc: The Honorable Earl F. Weener, PhD cc: Robert Hall

2 INGAA AND AGA RESPONSE TO NTSB SAFETY RECOMMENDATIONS P AND P INTEGRITY MANAGEMENT OF GAS TRANSMISSION PIPELINES IN HIGH CONSEQUENCE AREAS December 22,

3 Recommendations P & P-15-25: Development of Data to Enhance Risk Models The Interstate Natural Gas Association of America (INGAA) and the American Gas Association (AGA) respectfully submit this joint response to the National Transportation Safety Board (NTSB) Safety Recommendations P and P These recommendations were issued to AGA and INGAA on February 10, 2015 as a result of the safety study Integrity Management of Gas Transmission Pipelines in High Consequence Areas. The recommendations are: to collect data that will support the development of probabilistic risk assessment models, and share these data with gas transmission pipeline operators. INGAA and AGA support the NTSB s goal to improve risk assessment processes for integrity management programs by advancing data quality and availability. Thus, we have developed and implemented a comprehensive strategy for encouraging the continuous improvement of data quality and availability for use in risk models. The strategy leverages the associations membership networks and focuses on two sets of actions: 1. All modeling methods can benefit from incorporating historical incident data that quantifies historical incident frequencies and consequences. INGAA has developed a sophisticated software tool for analyzing Incident Report data published by the Pipeline and Hazardous Materials Safety Administration (PHMSA). This platform allows users to quickly filter PHMSA reportable incident data based on over 50 attributes and generate summary tables to understand historical frequencies and consequences of reportable incidents throughout all transmission pipelines. Operators can also import their own near miss and incident data into the tool. Operators can use this data to aid in quantifying the probability of a specific type of incident occurring and the magnitude of the associated consequence, and ultimately to enhance or validate their risk models. INGAA has tested this Incident Report Analysis Tool through a variety of recent efforts and conducted workshops with operators to build awareness of and familiarity with this resource. 2. On a continuous basis, INGAA and AGA participate in a variety of efforts to enhance the availability and quality of data for use in risk modeling. INGAA and AGA are active contributors to PHMSA s Risk Modeling Work Group, which meets on an ongoing basis to review state of the art pipeline risk management processes, assemble data and experiences from a variety of operators and risk modeling subject matter experts, and work towards the goal of publishing a Risk Modeling Guidance Document in INGAA and AGA have also worked with PHMSA on revisions of various Information Requests to assure data collected reflects the most important attributes for risk identification and mitigation. Risk assessment, modeling and data availability are frequently discussed at regular meetings of INGAA and AGA operators. Details on these initiatives follow. 2

4 Detailed Response INGAA Incident Report Analysis Tool Natural gas transmission operators utilize a variety of risk modeling approaches for assessing risk. These include: relative risk models, semi-quantitative models, and mathematical models. With adequate data inputs to support the assumptions and processes of a given model, any of these modeling approaches is capable of informing risk management decisions. All modeling methods can benefit from incorporating historical incident data that quantifies incident frequencies and consequences. However, due to the low frequency of incidents on gas pipeline assets, individual operators generally have a limited sample size of historical incident data on specific threats and consequences. Therefore, pipeline operators may need to utilize external datasets to enhance or validate their risk models. The PHMSA public Incident Report database is the most comprehensive historical incident data source for gas transmission pipelines. 1 The current version of PHMSA s Incident Report Form contains over 500 selectable fields to characterize the nature of an incident and the associated pipeline, facilities, and equipment. 2 A few examples of key fields include: Cause (Corrosion Failure, Equipment Failure, Excavation Damage, Incorrect Operation, Material Failure of Pipe or Weld, Natural Force Damage, Other Incident Cause, Other Outside Force Damage) Class Location Equipment Failure Type (Compressor or Compressor-Related Equipment, Failure of Equipment Body, Vessel Plate, or Other Material, Malfunction of Control/Relief Equipment, Non-Threaded Connection Failure, Other Equipment Failure, Threaded Connection Coupling Failure, Defective or Loose Tubing or Fitting) Gas Volume Released (Intentional and Unintentional) Number of Injuries (Employee, Contractor, Emergency Room, Worker, General Public) PHMSA s database could be used to develop probability estimates for the likelihood and magnitude estimates for consequence of an incident based on specific threats and the unique characteristics of a gas transmission pipeline. The current PHMSA Incident Report Database contains a massive amount of data in spreadsheet format; however, this spreadsheet contains minimal logic (e.g. macros, pivot tables, etc.) to enable parsing of the data by pipeline/facility or incident characteristics. Manually sorting for specific pipeline/facility, threat, or consequence characteristics through over 500 selectable fields is a time-intensive task requiring expert 1 PHMSA Distribution, Transmission & Gathering, LNG, and Liquid Accident and Incident Data, 2 PHMSA Accident/Incident/Annual Reporting Forms, 3

5 familiarity with the PHMSA Incident Report Form and database. INGAA s Incident Report Analysis Tool allows users to quickly filter the PHMSA incident data based on over 50 attributes and generate summary tables to understand historical frequencies and consequences of reportable incidents throughout all transmission pipelines. 3 Figures 1 3 present an example of how INGAA s platform can be used to generate data to enhance risk assessments. Figure 1 depicts filters that an operator would use to view only those incidents involving corrosion/material failure on a transmission pipeline right-of-way. After the selection of these filters, the Tool automatically generates a series of tables, shown in Figure 2, which provide a count and better breakdown of the causes of these corrosion/material failure incidents. Users can then generate a new sheet containing all data for only the incidents included in the selected filters. The Tool also generates tables describing the consequences of the selected incidents, as shown in Figure 3. The data contained in these tables can be used by operators in quantifying the probability of a specific type of incident occurring and the magnitude of the associated consequence. Whether qualitative or quantitative risk modeling is currently being used, this data can be employed to enhance and/or benchmark the accuracy of the model processes and outputs. Based on feedback from operators, an additional feature of the Tool is the ability for operators to input their own company-specific data and generate statistics based on the combined industry and company dataset. This capability would allow an operator to greatly expand the dataset beyond publicly available information to include data from non-reportable incidents and near misses. These leading metrics can be important in enhancing the accuracy of risk models. INGAA has disseminated the Incident Report Analysis Tool for testing and has provided introductory training to INGAA and AGA members on the use of the Tool to enhance risk assessment. The Tool was presented at INGAA s Pipeline Database and Incident Lessons Learned Workshop in September 2016 and AGA s Operations Safety Regulatory Action Committee Meeting in December INGAA s Incident Report Analysis Tool currently incorporates PHMSA reportable incident data from 2010 present. PHMSA s Incident Report Form F underwent a major update for 2010, adding a substantial degree of detail to incident reporting that is particularly useful for historical incident data analysis. 4

6 Figure 1: Example of filter sections for analysis of corrosion/material failure incidents on gas transmission pipelines. Filters filled with a blue background are selected, filters with a white background are not selected, and filters with a grey background are not applicable based on other selections. 5

7 Figure 2: Incident count and cause breakdown for the selections made in Figure 1. (NOTE: Based on PHMSA data file as of 11/30/2016) 6

8 Figure 3: Consequence data for incidents caused by corrosion/material failure since (NOTE: Based on PHMSA data file as of 11/30/2016) 7

9 Continuous Efforts In INGAA and AGA s role as trade associations, we undertake a variety of activities on a continuous basis that encourage the improvement of data quality and availability for use in risk models. PHMSA Risk Modeling Work Group INGAA and AGA are active contributors to PHMSA s Risk Modeling Work Group (RMWG). The RMWG Mission Statement includes Identify and, if necessary in specific areas, develop a range of state-of-the-art methods and tools capable of addressing the spectrum of pipeline risk management applications The RMWG meets on an ongoing basis to review the range of risk models and tools available to support pipeline risk management processes. The group is assembling data and experiences from a variety of operators and risk modeling subject matter experts, working towards the goal of publishing a Risk Modeling Guidance Document. The RMWG has reviewed a variety of techniques for modeling pipeline incident likelihood and consequence magnitude for both pipelines and facilities (e.g. compressor and metering stations). Best practices and lessons learned from the full range of risk modeling approaches, including probabilistic risk models, have been shared with the RMWG. INGAA and AGA presence on this team provides a highway for sharing data between operators, subject matter experts, and PHMSA. 4 PHMSA Information Collection Requests INGAA and AGA collaborate with PHMSA in various efforts to improve the availability and quality of data used in risk modeling. PHMSA s Data Quality and Analysis Team are co-chaired by PHMSA and AGA and is made up of representatives from government, industry and the public. The team analyzes the data that PHMSA collects and determines opportunities to improve pipeline safety based on the analysis. The team is also identifying gaps in the data that are collected by PHMSA and others, ways to improve the collected data, and is working on consistent messages based on the pipeline incident data. INGAA and AGA have also provided feedback (through working groups, workshops, and public comment) to PHMSA on proposed changes to the Incident Report 5 and National Pipeline Mapping Systems (NPMS). 6 This feedback has focused on identifying the most important attributes for risk identification and mitigation and assuring that data requirements are consistent across various rulemakings (Incident Report, Annual Report, NPMS, and Gas Transmission 4 Minutes and presentations from PHMSA s Risk Modeling Work Group meetings are publicly available on PHMSA s website: 5 Pipeline Safety: Information Collection Activities: Agency Information Collection Activities; Proposals, Submissions, and Approvals, 6 Pipeline Safety: Request for Revision of a Previously Approved Information Collection National Pipeline Mapping System Program, 8

10 NPRM). Consistency in reporting requirements is critical in continuing to leverage the publiclyavailable data to enhance operators risk modeling. Committees, Workshops, and Forums INGAA and AGA recognize that participation in industry committees and forums helps to educate stakeholders on potential advancements in risk modeling, including the availability and use of quality data. As such, the associations provide numerous opportunities for operators to attend committee meetings, forums and workshops where they can share their experiences with risk modeling, learn about advancements in the industry, and discuss data integration challenges. These programs operate on a continuous and recurring basis. Members of the committees who attend these forums and workshops are leaders of their organizations integrity management and risk modeling programs, and are integral to decision making on how to improve the quality and availability of data for use in risk models. One recent example of a workshop on this topic was INGAA s Pipeline Database and Incident Lessons Learned Workshop in September, As previously mentioned, INGAA s Incident Analysis Tool was presented at this Workshop, along with a variety of other strategies for leveraging data from several sources to enhance risk models, including data from In-Line Inspection and Geographic Information System databases. Conclusion The NTSB s Safety Recommendations P and P-15-25, issued to AGA and INGAA, are to collect data that will support the development of probabilistic risk assessment models, and share these data with gas transmission pipeline operators. AGA and INGAA believe we have a comprehensive strategy for encouraging the continuous improvement of data quality and availability for use in risk models. INGAA has developed a sophisticated software tool for analyzing Incident Report data published by the PHMSA. Operators can use quantitative information from INGAA s Incident Report tool to enhance and/or validate their risk models. The initial roll-out of this tool was completed this year, with ongoing updates based on operator feedback and new incident report data/structures. On a continuous basis, INGAA and AGA participate in a variety of efforts to enhance the availability and quality of data for use in risk modeling. INGAA and AGA are active contributors to PHMSA s Risk Modeling Work Group, which meets on an ongoing basis and has assembled data and experiences from a variety of operators and risk modeling subject matter experts. INGAA and AGA have also worked with PHMSA on the Data Quality and Analysis Team and provided comments on revisions of various Information Requests to assure data collected reflects the most important attributes for risk identification and mitigation. Risk assessment and modeling and data availability are frequently discussed at regular meetings of INGAA and AGA operators. 9

11 Supporting advancement for pipeline risk modeling and assessment is a goal of AGA, INGAA, and our operators. This is an evergreen process. AGA and INGAA believe we have a comprehensive strategy for encouraging the continuous improvement of data quality and availability for use in risk models, and we request this recommendation be moved to a Closed Acceptable Response status. 10