HCA - INTRODUCTION 

The Integrity Management Program (IMP or program) is Northern’s system for controlling physical risk to its pipeline facilities. IMP further ensures that risks associated with pipeline integrity are more effectively managed and that the public, Northern’s employees, and the environment are better protected from pipeline incidents. While the processes, programs and procedures set forth in this program only apply to pipelines located within High Consequence Areas (HCA), Northern will work diligently to incorporate IMP into its existing programs, procedures and standards for managing risk elsewhere on its system. This fusion will take place as more understanding is gained through application of the IMP in high consequence areas.

The following provides a brief overview of each of the program elements:
		Integrity Management Plan – The integrity management plan is a collection of processes and procedures to comply with the Gas Integrity Management Rule. In this plan, procedures have been established for identifying HCAs; gathering, reviewing and integrating data; performing risk and integrity assessments; applying prevention, mitigation and remediation measures; and, assigning reassessment intervals to continually evaluate the integrity of covered segments.
		Performance Plan – The performance plan contains processes and procedures for measuring the effectiveness of IMP per the requirements of the final rule and per criteria set forth by Northern.
		Communications Plan – The communications plan contains processes and procedures for communicating internally and externally the results from the performance plan and other information pertinent to IMP.
		Management of Change Plan – The management of change plan provides a philosophy and processes and procedures for accounting for changes to the pipeline system or IMP that could affect the integrity of covered segments.
		Quality Management Plan – The quality management plan contains processes and procedures to ensure the requirements of the integrity management program are being met, documented and continually improved.