Pipeline Safety: Public Workshop on Integrity Verification Process

These are comments submitted on behalf of INGAA (received on October 11, 2013)

Attached please find the comments from Kinder Morgan

Attached are INGAA's comments on the Integrity Verification Process that was presented at the August 7 workshop.

INGAA's Fitness for Service: Originally released in November 2011, the attached document describes INGAA's Fitness for Service methodology for pre-regulation pipe. This plan, developed not only by INGAA to align with INGAA's goal of driving incidents to zero, was also developed to address the spirit of the legislative intent of the Section 23 of the Pipeline Safety Act of 2011: (d) TESTING REGULATIONS.— (1) IN GENERAL.—Not later than 18 months after the date of enactment of this section, the Secretary shall issue regulations for conducting tests to confirm the material strength of previously untested natural gas transmission pipelines located in high-consequence areas and operating at a pressure greater than 30 percent of specified minimum yield strength. (2) CONSIDERATIONS.—In developing the regulations, the Secretary shall consider safety testing methodologies, including, at a minimum— (A) pressure testing; and (B) other alternative methods, including in-line inspections, determined by the Secretary to be of equal or greater effectiveness

INGAA summary document describing the role of Fitness for Service in managing construction and material defects.

INGAA's Fitness for Service (Summary): The attached document is a summary of the INGAA Fitness for Service White Paper also attached to the docket.

INGAA summary document commenting on pre-regulation pipe records, re-validating MAOP where necessary and the alignment of INGAA Fitness for Service.

INGAA's Expanding IM Commitment: The attached document details INGAA's commitment to expanding integrity management beyond HCAs. This plan, developed not only by INGAA to align with INGAA's goal of driving incidents to zero, was also developed to address the spirit of the legislative intent of Section 5 of the Pipeline Safety Act of 2011: SEC. 5. INTEGRITY MANAGEMENT. (a) EVALUATION.—Not later than 18 months after the date of enactment of this Act, the Secretary of Transportation shall evaluate— (1) whether integrity management system requirements, or elements thereof, should be expanded beyond high-consequence areas; and (2) with respect to gas transmission pipeline facilities, whether applying integrity management program requirements, or elements thereof, to additional areas would mitigate the need for class location requirements.