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Safety and Public Awareness / Integrity Management Program

Date Requested: May 27 2024 8:26 PM

Printable Version


The Integrity Management Program (IMP) is used by Northern Natural Gas to control physical risk to its pipeline facilities. The IMP 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 the IMP, 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 pursuant to the requirements of the Pipeline and Hazardous Materials Safety Administration and pursuant to criteria established 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 processes and procedures to account 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.

Northern is committed to protecting the public, its employees and the environment; improving the performance of its pipeline business; protecting its reputation as a reliable provider of natural gas transportation services; enhancing its risk profile; and, ensuring compliance with all applicable state and federal integrity management regulations. Accordingly, executive management has approved the processes and procedures within this program, and has mandated adherence to them. Employees at all levels of the organization are responsible for leading and engaging in tasks to meet IMP goals and objectives.


The Pipeline and Hazardous Materials Safety Administration (PHMSA) finalized the Gas Integrity Management Rule on December 15, 2003, that requires all gas transmission companies institute integrity management programs for high-consequence areas (HCA). This rule mandates pipeline operators identify all HCAs and increase pipeline integrity measures to ensure greater safety in these areas. Each operator is to conduct a baseline assessment and subsequent reassessments of all pipeline segments in HCAs and characterize applicable threats to segments' mechanical integrity. The rule further requires that operators mitigate and/or remediate significant defects and monitor the effectiveness of their integrity management program.

Northern began development of its program in 2002 and began integrity assessments in 2003, prior to PHMSA finalizing the Gas Integrity Management Rule. During 2004 and 2005, Northern implemented a system to identify HCA based on the impact area of a potential pipeline failure and the surrounding population. Next, Northern performed risk-of-failure calculations to determine, on a relative basis, which HCA pipeline segments had the highest risk of failure. This information was then used to prioritize the HCA segments to determine how best to assess the integrity of the segments and the appropriate order and timeframe to do so. Northern currently addresses the HCA segments by inspecting the line using sophisticated tools that provide information about the integrity of the pipeline, using water to pressure the line beyond its maximum allowable operating pressure to ensure the line can hold gas to the required pressure, rerouting the pipeline around the HCA, or abandoning the pipeline. All of these methods of addressing the HCA provide a safety measure against pipeline ruptures in HCAs.


As part of its integrity management program for HCAs, Northern is actively identifying locations considered to be an HCA. An identified site is one of the following:

  • An outside area or open structure that is occupied by 20 or more persons on at least 50 days in any 12 month period. The days need not be consecutive. Examples include but are not limited to, beaches, playgrounds, recreational facilities, camping grounds, outdoor theaters, stadiums, recreational areas near bodies of water, or areas outside a rural a building such as a religious facility.
  • Religious facilities, office buildings, community centers, general stores, 4-H facilities, or roller skating rinks or other buildings of the like, that are occupied by 20 or more people on at least five days a week for 10 weeks in a 12-month period (the days and weeks need not be consecutive); OR
  • Prisons, schools, day-care facilities, retirement facilities, assisted-living facilities, or other facilities occupied by persons who are confined, are of impaired mobility, or who would be difficult to evacuate.
  • If you believe your facility or location should be considered an identified site, or if you know of any other facilities or locations that should be considered an identified site, please fill in the Feedback Form. Northern will use this information to help prioritize segments of its pipeline system for integrity assessment. Your assistance will help Northern better ensure it is making its system safe for the public, its employees and the environment. Thank you for your help.
  • When new rights of way are acquired or dedicated, the costs for pipeline modifications will generally be borne by the developer, state, county or city highway department.

For FAQ’s regarding the Pipeline and Hazardous Material Safety Administration (PHMSA) Gas Integrity Management rule please click the following link​​