April 26, The Honorable Deborah A. P. Hersman National Transportation Safety Board 490 L Enfant Plaza, SW Washington, DC 20594

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1 April 26, 2013 The Honorable Deborah A. P. Hersman National Transportation Safety Board 490 L Enfant Plaza, SW Washington, DC Dear Chairman Hersman: As a result of the investigation of the natural gas transmission pipeline accident in the town of San Bruno California, the National Transportation Safety Board (NTSB) issued a series of recommendations, one of which was directed to the American Gas Association (AGA) and the Interstate Natural Gas Association of America (INGAA). It stated: Report to the National Transportation Safety Board on your progress to develop and introduce advanced in-line inspection platforms for use in gas transmission pipelines not currently accessible to existing in-line inspection platforms, including a timeline for implementation of these advanced platforms. (P-11-32) (emphasis added.) AGA and INGAA agree that it is critical for the pipeline industry to learn from this tragic accident. We have, and will continue to, work to demonstrate this through our actions and ultimately the industry s safety performance. AGA and INGAA worked with other stakeholders and submitted to the NTSB a report entitled Report to the National Transportation Safety Board on Historical and Future Development of Advanced In-Line Inspection Platforms for Use in Gas Transmission Pipelines on March 26, The report described traditional and non-traditional in-line inspection (ILI) platforms, also referred to as pigs, that are used to inspect gas transmission pipelines. Traditional ILI platforms use the flow of gas to provide the motive force to propel the tool through the pipeline. These are referred to as free-swimming tools. The report also described the circumstances that render a pipeline inaccessible (or unpiggable ) to the use of ILI. A pipeline can be unpiggable due to its physical configuration or flow constraints and, in some instances, may be unpiggable due to both factors. Finally, the report included details on platforms and sensor technologies currently available as well as those under development, including a timeline for such development. After reviewing the report, the NTSB responded with a correspondence dated June 20, 2012, stating that the response by AGA and INGAA concerning recommendation to P had been classified Open Acceptable Response. The NTSB requested that AGA and INGAA provide additional information about when advanced platforms were expected to be available. 1

2 Research, development and commercialization of such platforms have continued at a rapid pace. The objective of this letter is to report on that progress and demonstrate that there is commitment and market demand for the commercialization of technology for unpiggable pipelines. Recognizing the urgency of the need to address unpiggable pipelines, organizations have commercialized technology solutions in two ways: 1. Fundamental research, development and demonstration; and 2. Technology transfer (from other industrial applications) Fundamental research, development and demonstration Some of the most noteworthy advances in technology solutions for unpiggable pipelines have been made by NYSEARCH, a research consortium of natural gas distribution companies focused on natural gas research, development, demonstration and commercialization. NYSEARCH, working with the Pipeline & Hazardous Materials Safety Administration (PHMSA), has mobilized research, development, demonstration and commercialization of robotic ILI platforms and sensors. Its work has resulted in commercially available tools that are offered by PipeTel Technologies in 6-to-26 inch tools. A second research consortium, Operations Technology Development (OTD), has advanced research to improve pipeline assessments. OTD is a not-for-profit research consortium made up of natural gas distribution operators that was formed to develop, test and implement new technologies. OTD is supporting technology transfer of inspection platforms from the offshore industry to on-shore unpiggable pipe. OTD is also developing a tethered magnetic flux leakage (MFL) tool to inspect short segments of unpiggable pipe such as casings and crossings and is partnering with others to develop an electromagnetic acoustic transducer (EMAT) sensor for unpiggable pipe. Equally noteworthy is a complementary program managed by the Pipeline Research Council International (PRCI). PRCI s programs are focused primarily on developing sensor technology and demonstrating sensor capabilities via extensive pull testing and other controlled studies using pipe removed from operating transmission systems. The premise of this approach is that platforms to carry these improved sensors will be developed concurrently by entities such as NYSEARCH and others described below. PRCI also is working to develop complete systems for new inspection technologies that can be used on difficult-to-inspect pipelines. These include an integrated cleaning and inspection tool (i.e., a tool that gathers data using sensors mounted on standard cleaning pigs) and a tethered inspection technology that uses an electromagnetic impedance technology (EMIT) sensor. Providers of traditional free-swimming ILI technologies have developed platforms for unpiggable pipelines in response to market demand for these tools and platforms. For example, Rosen, which has one of the largest fleets of free-swimming tools, has commercialized robotic platforms and now offers them in a variety of sizes. Rosen also has developed bi-directional tools with a selfadapting tractor drive and a high-resolution MFL inspection unit to enable operators to inspect short unpiggable segments. 2

3 Technology transfer Transfer or adaptation of technology from other industrial applications has been essential to meet the growing needs for inspecting unpiggable natural gas transmission pipeline segments. One example is the transfer of technology from offshore applications. Oceaneering International, Inc. has brought forth robotic platforms, bi-directional tools and pump in-pump out tools in the range of 6-to-52 inches in diameter. A second example of technology transfer is from the nuclear and electric power generation industries, where inspection of piping and pressure vessels is often difficult. Diakont has adapted technology developed in these industries based on its identification of the need for pipeline tools. In 2012, Diakont began offering robotic platforms for 20-to-60 inch applications in North America. Progress on advanced in-line inspection platforms Attached to this letter are two tables that demonstrate the progress achieved in designing and manufacturing pipeline inspection platforms and the full breadth of technology that can be applied to natural gas transmission pipelines that cannot accommodate traditional free-swimming ILI tools. Table 1 shows the state of technology as of 2010, while Table 2 shows the current state of technology and the vast improvement that has been made in just three years in the development and availability of non-piggable platforms. While manufacturers have the ability to build devices for the pipeline sizes listed on the table, they will build only the size and number required by the market. The service providers are listed in the first column and the platform options are organized into technology groups of platform designs in the columns that follow. The last columns list the kinds of sensors that can be mounted on these platforms. Green indicates that particular sensors can be mounted on these platforms. Yellow indicates that the technology is very close to market. Red indicates that a sensor is not available. The number of red fields reflects the fact that certain technologies (e.g., Remote Field Eddy Current) either are intended for very specific, focused applications or are tailored to the physics of the particular sensing system and other factors. As research has progressed and technologies have entered the market, there have been conferences, workshops and webinars sponsored by AGA, INGAA and their partner organizations. AGA and INGAA look to partner organizations to help refine the articulation of what the industry needs and identify the technology options that are available for operators. These conferences, workshops and webinars are listed in Table 4. AGA, INGAA and their partner organizations will continue to provide forums at which operators will be updated on advances and commercialization of ILI and unpiggable technologies, and technology providers will be informed on industry s particular needs for tools and platforms to address unpiggable pipelines. AGA and INGAA believe that their technology development partners, PRCI, NYSEARCH, and OTD, have taken significant steps on multiple fronts to advance ILI technologies and bring technology to market for unpiggable pipelines. AGA and INGAA are committed to continuing our support of these efforts. In addition, commercial technology providers have brought technology from other industrial applications and have developed technology on their own. 3

4 Clarion and Tiratsoo Technical, providers of high-level technical training courses on pipeline engineering topics, have provided forums for operators to learn about the development and commercialization of technology, and for the technology providers to learn about industry s needs. Many of the operators that also are PRCI, NYSEARCH and OTD members use their own experience and the knowledge shared in roundtables, technical conferences and other forums to inform the ongoing research and development road mapping process. In this process, capabilities are matched against needs and any gaps identified then become the goals of the research programs. In summary, advanced platforms already are available and will continue to evolve and be refined to be fully functional for the variety of unpiggable pipeline segments. The pipeline industry, its research partners and its contractors will continue to support technology advances in traditional in-line inspection pigs and technologies that will make currently unpiggable pipeline segments piggable. On this basis, we request that the NTSB designate recommendation P as Closed-Acceptable Response. Please let us know if you have 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 Attachments cc: The Honorable Christopher A. Hart cc: The Honorable Mark R. Rosekind cc: The Honorable Robert L. Sumwalt cc: The Honorable Earl F. Weener cc: Stephen Klejst cc: Robert Hall 4

5 Table 1: 2010 Service Providers with Abilities to Examine Pipelines that Cannot Utilize Traditional ILI Technology (In Market in 2010 & shown with 2010 capabilities) Service Provider Motive Power Manufacturing Capability Pipeline Diameter (in) Smallest Largest Axial Magnetic Flux Leakage (MFL) Transverse Circumferential / Helical MFL Sensor technologies that can be adapted to platform Remote Field Eddy Current Ultrasonic Electromagnetic Acoustic Transmitter Tethered Cable/Rod A. Hak Industrial Services Rod 4 60 Liquid Only AGR Field Operations Cable 6 52 Applus RTD Cable 4 60 Liquid Only BJ Baker/Hughes Cable " 32" 14" 32 " Diakont Motorized Gas Only TD Williamson Cable 6 12 Rosen Cable 3 56 Weatherford Pipeline Cable 6 56 Caliper Line Stays In Service Bi Directional BJ Baker/Hughes Bi Directional 3 32 Quest integrity Bi Directional 3 24 Liquid Only Rosen Bi Directional Liquid Only TD Williamson Pump in/pump out 4 48 Robotic/Tractor AGR Field Operations Motorized 6 52 Packing Gland Diakont Motorized Gas Only Packing Gland Pipetel (NYSearch) Motorized 6 8 5

6 Table 2: 2013 Service Providers with Abilities to Examine Pipelines that Cannot Utilize Traditional ILI Technology (In Market & shown with current capabilities) Service Provider Motive Power Manufacturing Capability Smallest Largest Axial Magnetic Flux Leakage (MFL) Transverse Circumferential / Helical MFL Sensor Technologies that can be adapted to Platform Remote Field Eddy Current Ultrasonic Electromagnetic Acoustic Transmitter Tethered Cable/Rod A. Hak Industrial Services Cable 4 60 Liquid Only UT Oceaneering Pipetech (AGR) Cable 6 52 Applus RTD Cable 4 60 Liquid Only BJ Baker/Hughes Cable " 16" 14" 32" CUDD Energy Services Cable 6 30 Diakont Cable Gas Only GE Cable (conv tools) 6 30 KTN AS Norway Cable 4 48 INLINE Devices /Mears Cable 2 12 Innospection Cable 6 36 SLOFEC Rosen Cable 3 64 Liquid Only Russel technologies Cable 2 12 TD Williamson Cable 4 12 Weatherford Pipeline Cable 6 56 Liquid Only Caliper Line Stays In Service Bi Directional 3P services Pump in/pump out 3 42 Liquid Only A. Hak Industrial Services Pump in/pump out 4 60 Liquid Only UT Oceaneering Pipetech (AGR) Pump in/pump out 3 32 BJ Baker/Hughes Bi Directional 3 32 Half Wave Bi Directional ART No Liquid Needed itrobotics Pump in/pump out 5 16 Oceaneering Pipetech Bi Directional 6 56 Liquid Only Quest integrity Bi Directional 3 24 Liquid Only Rosen Bi Directional 6 42 TD Williamson Pump in/pump out 6 32 Robotic/Tractor Oceaneering Pipetech (AGR) Motorized 6 52 Packing Gland Diakont Motorized Gas Only Packing Gland GE PII 'UT Surveyer' Motorized 6 12 Water Coupled GE PII 'SLOFEC Surveyer' Motorized 6 30 Subsea Integrity Group 'Pipecrawler' Brush Driver soon EMIT Liquid Only Packing Gland Pipetel (NYSearch) Motorized Transverse MFL (30 36 soon) Packing Gland Remote Inspection Technologies Motorized 6 36 LIDAR Packing Gland Rosen Motorized 3 64 External Robotic Pipeway Motorized 4 46 From OD Rosen Motorized 6 12 EMAT Transverse From OD SPECTRUM Motorized 4 46 EMAT Transverse From OD Applus RTD ROV 4 56 PEC Underwater Outside from Sea Innospection ROV & Crawler 4 56 SLOFEC Underwater Outside from Sea Film Ocean ROV 4 56 Underwater Outside from Sea Oceaneering Pipetech (AGR) ROV Underwater Outside from Sea Remote Inspection Technologies ROV & Crawler Sonar LIDAR Outside from Sea Seabotix ROV 4 56 Underwater Outside from Sea SONOMATIC ROV 6 56 Underwater Outside from Sea Subsea Integrity Group ROV/Permanent/Diver 6 26 g PIMS Outside from Sea 6

7 Table 3: Keys to Terminology in Tables 1 and 2 ART EMIT From OD Gas Only g PIMS Liquid Only Outside from Sea Packing Gland PEC ROV SLOFEC Acoustic Resonance Technology Electromagnetic Impedance Tomography Tool runs on the outside of the pipe Laser ID profile by time of flight through gas (few liquids) G2 Wavemaker Guided Wave Piezoelectric Ultrasonic (requires a liquid couplant) Diver Attached or ROV Manipulated Sealing is needed to retain the product in the pipeline, but requires a packing gland that permits a cable to connect to the tool is required Proximity Eddy Current Remotely Operated Vehicle (undersea) Specialized Non contact Eddy Current 7

8 Table 4: Conferences, Workshops, and Webinars Date Subject Sponsored by Details Jan-11 Transmission Integrity Management Workshop AGA Mar-11 Unpiggable Pipeline Solutions Forum Clarion and Tiratsoo Technical May-11 Operations Conference, Exhibition and Spring Committee Meetings AGA Jul-11 Roundtable Discussion Southern Gas Association Multiple presentations, exhibitions and roundtables on advancements in ILI and unpiggable technologies and lessons learned Operational issues with unpiggable segments and status of technology development Sep-11 Webinar on Status of Unpiggable Solutions Southern Gas Association Sep-11 Operations Technical Committee AGA Presentations and roundtables Dec-11 Workshop on ILI Technology Issues INGAA Feb-12 Feb-12 Reauthorizations and Transmission Design, Construction & Operations Workshop Unpiggable Pipeline Solutions Forum AGA Clarion and Tiratsoo Technical May-12 Advanced ILI Workshop Southern Gas Association Including technology for unpiggable pipelines May-12 Operating Conference and Spring Technical Committee Meetings AGA Presentations and roundtables on unpiggable technology and ILI advancements Jul-12 Roundtable Discussion Southern Gas Association Issues with unpiggable segments and status of technology development Sep-12 Operations Technical Committee AGA Presentations and roundtables Sep-12 International Pipeline Conference and Exposition ASME Dec-12 & Jan- 13 Feb-12 & Feb- 13 Technology Vendor Meetings INGAA Annual Research Exchange Meetings PRCI Included a significant number of sessions on inspection technology and sensor/nde advancement Mar-13 Transmission Pipeline Workshop AGA May-13 Operating Conference, Exhibition and Spring Technical Committee Meetings AGA Presentations, exhibitions and roundtables on unpiggable technology and ILI advancements May-13 Unpiggable Pipeline Solutions Forum Clarion and Tiratsoo Technical 8