Pipeline Safety: Lessons Learned From the Release at Marshall, Michigan, 25990-25994 [2014-10248]
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Federal Register / Vol. 79, No. 87 / Tuesday, May 6, 2014 / Notices
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Issued in Washington, DC, on April 23,
2014.
Donald Burger,
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Ryan Air, Anchorage, AK .........................................................................................................
Codman & Shurtleff, Inc., Raynharn, MA .................................................................................
Thompson Tank, Inc., Lakewood, CA ......................................................................................
U.S. Department of Defense, (DOD) Scott AFB, IL .................................................................
Chemring Energetic Devices, Inc., Torrance, CA ....................................................................
Dockweiler, Neustadt-Glewe, Germany ...................................................................................
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U.S. Department of Defense, (DOD), Scott AFB, IL ................................................................
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[FR Doc. 2014–10069 Filed 5–5–14; 8:45 am]
BILLING CODE 4910–60–M
DEPARTMENT OF TRANSPORTATION
Pipeline and Hazardous Materials
Safety Administration
[Docket No. PHMSA–2014–0020]
Pipeline Safety: Lessons Learned
From the Release at Marshall,
Michigan
Pipeline and Hazardous
Materials Safety Administration
(PHMSA); DOT.
ACTION: Notice; issuance of advisory
bulletin.
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AGENCY:
PHMSA is issuing an advisory
bulletin to inform all pipeline owners
and operators of the deficiencies
SUMMARY:
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identified in Enbridge’s integrity
management (IM) program that
contributed to the release of hazardous
liquid near Marshall, Michigan, on July
25, 2010. Pipeline owners and operators
are encouraged to review their own IM
programs for similar deficiencies and to
take corrective action. Operators should
also consider training their control room
staff as teams to recognize and respond
to emergencies or unexpected
conditions. Further, the advisory
encourages operators to evaluate their
leak detection capabilities to ensure
adequate leak detection coverage during
transient operations and assess the
performance of their leak detection
systems following a product release to
identify and implement improvements
as appropriate. Additionally, operators
are encouraged to review the
effectiveness of their public awareness
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programs and whether local emergency
response teams are adequately prepared
to identify and respond to early
indications of ruptures. Finally, this
advisory reminds all pipeline owners
and operators to review National
Transportation Safety Board
recommendations following accident
investigations. Owners and operators
should evaluate and implement
recommendations that are applicable to
their programs.
FOR FURTHER INFORMATION CONTACT:
Linda Daugherty by phone at 816–329–
3821 or by email at linda.daugherty@
dot.gov. Information about PHMSA may
be found at https://phmsa.dot.gov.
SUPPLEMENTARY INFORMATION:
I. Background
On July 25, 2010, at 5:58 p.m. eastern
daylight time, a segment of a 30-inch-
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diameter pipeline (Line 6B), owned and
operated by Enbridge Incorporated
(Enbridge), ruptured in a wetland near
Marshall, Michigan. The rupture was
not discovered or addressed for over 17
hours. During that time period, Enbridge
twice pumped additional oil (81 percent
of the total release) into Line 6B during
two startups. The total release was
estimated to be 843,444 gallons of crude
oil. The oil saturated the surrounding
wetlands and flowed into Talmadge
Creek and the Kalamazoo River. Local
residents self-evacuated from their
homes, and serious environmental
damage required long-term remediation.
About 320 people reported symptoms
consistent with crude oil exposure. No
fatalities were reported. Cleanup and
remediation continues, and costs have
exceeded $1 billion.
The National Transportation Safety
Board (NTSB) determined that the
probable cause of the pipeline rupture
was stress corrosion cracking that grew
and coalesced from crack and corrosion
defects under disbonded polyethylene
tape coating. The NTSB also determined
the rupture and prolonged release were
caused by pervasive organizational
failures at Enbridge that included: (1)
Deficient integrity management (IM)
procedures, which allowed welldocumented crack defects in corroded
areas to propagate until the pipeline
failed; (2) inadequate training of control
center personnel, which resulted in
Enbridge’s failure to recognize the
rupture for 17 hours and through two restarts of the pipeline; and (3)
insufficient public awareness and
education, which allowed the release to
continue for nearly 14 hours after the
first notification of an odor to local
emergency response agencies.
PHMSA IM Regulations
Subpart O of 49 CFR part 192 and
§ 195.452, also known as the IM
regulations, require operators of gas
transmission and hazardous liquid
pipelines to institute a continual
process for evaluation of pipeline
integrity (see also: Guidance in
Advisory Bulletin ADB–2012–10,
‘‘Using Meaningful Metrics in
Conducting Integrity Management
Program Evaluations,’’ 77 FR 72435,
December 5, 2012). Specifically,
§§ 192.937 and 195.453(j) require that
an operator have a continual process for
the evaluation of pipeline integrity. The
evaluation must consider the results of
integrity assessments, data collection
and integration, remediation, and
preventative and mitigative actions in
evaluating pipeline integrity. The
operator must use the results from this
evaluation to identify the threats
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specific to each pipeline segment that
could impact a High Consequence Area
(HCA) and the risk represented by those
threats. The operator must perform
assessments that are specific to those
threats and then identify and implement
appropriate remedial, preventative and
mitigative measures. Sections 192.945
and 195.452(k) require that an operator
have methods to measure the
effectiveness of their integrity
management programs.
An operator’s IM program must
include the results of past and present
integrity assessments, risk assessment
information and data integrated from
throughout the pipeline system. This
information and its analysis must be
taken into account when making
decisions about remediation, preventive
and mitigative actions.
The ability to integrate and analyze
threat and integrity related data from
many sources is essential for sustaining
and continually improving safety
performance and a proactive IM
program. Operators must use the results
from this integrated evaluation to
identify the threats specific to each
pipeline segment that could impact a
HCA. The operator must then perform
assessments that are specific to the
identified threats and implement
remedial, preventive and mitigative
measures, as appropriate.
The IM regulations supplement
PHMSA’s prescriptive safety regulations
with requirements that are more
performance-based and processoriented. One of the fundamental tenets
of the IM program is that each
individual pipeline has a unique risk
profile that is dependent on factors
including the pipeline’s physical
attributes, its geographical location, its
design, its operating environment and
the commodity it transports. Pipeline
operators use this risk profile to identify
appropriate assessment tools, set the
schedule for performing integrity
assessments and identify the need for
additional preventive and mitigative
measures such as lowering operating
pressures, installing automatic or
remote control shut-off valves and
installing additional right-of-way
markers, among other safety measures. If
this risk profile information is
unknown, unknowable, or uncertain,
the pipeline should be operated more
conservatively.
Deficiencies Found in Enbridge’s IM
Program
The following facts illustrate the ways
in which Enbridge failed to institute and
maintain an adequate IM program:
In 2007, Enbridge experienced a
release on its Line 3 in Glenavon,
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25991
Saskatchewan. Following the
Transportation Safety Board of Canada’s
investigation and issuance of a report,
Enbridge changed its assessment
process to account for tool tolerances
when performing engineering
assessments. However, Enbridge did not
retroactively apply these changes to the
2005 in-line inspection (ILI) data
assessments performed on the line that
ruptured near Marshall, Michigan. In its
investigation of this incident, the NTSB
found that Enbridge’s IM program did
not incorporate a process of continuous
reassessment to all pipeline engineering
assessments, and it neglected to apply
the revised crack assessment methods to
Line 6B. The NTSB also found a lack of
data integration was a significant
contributor to the consequences of the
Marshall, Michigan incident.
The NTSB further concluded:
• Enbridge’s response to past IMrelated accidents focused only on the
proximate cause, without a systematic
examination of company actions,
policies and procedures.
• Enbridge’s IM program consistently
chose a less-than-conservative approach
to pipeline safety margins for crack
features.
• In preparing the risk analysis,
Enbridge failed to consider all relevant
risk factors associated with the
determination of the amount of product
that could be released from a rupture on
Line 6B.
• The results of multiple ILI
assessments on Line 6B were evaluated
independently and the information from
these assessments was not properly
integrated to assure pipeline integrity.
• Enbridge used a lower safety margin
when evaluating crack defects versus
corrosion defects. Enbridge’s criterion
for excavating and remediating a crack
defect was when the predicted failure
pressure was less than the hydrostatic
test pressure (1.25 times maximum
operating pressure). Enbridge’s criterion
for excavating and remediating a
corrosion defect was when the predicted
failure pressure was less than the
specified minimum yield strength (1.39
times maximum operating pressure).
• Enbridge used the maximum depth
reported in a 2005 UltraScan Crack
Detection (USCD) ILI tool run without
accounting for tool accuracy or
performance specifications. Further,
Enbridge did not compare the 2005
USCD-reported wall thickness to a 2004
UltraScan Wall Measurement tool run
that measured local wall thicknesses.
Enbridge used the thicker, incorrect
measurement in determining the
predicted failure pressure and crack
growth calculations.
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• Enbridge did not account for the
interaction between corrosion and
cracking. Assessments for corrosion in
2004 and for cracks in 2005 showed
areas of overlap. Using the crack depth
measurements alone likely resulted in
an underestimation of the total wall
loss.
• The ILI vendor’s junior analyst
classified certain features from the 2005
USCD ILI tool run as ‘‘crack-field’’
features, but the ILI vendor supervisor
re-classified them as ‘‘crack-like’’
features in the report to Enbridge.
Enbridge policies allowed longer
‘‘crack-like’’ features to persist without
further evaluation than ‘‘crack-field’’
features. The post-accident investigation
determined that the features were in fact
‘‘crack-field’’ features. Although the
excavation threshold for ‘‘crack-field’’
features was 2.5 inches, the
misclassified features measured 3.5
inches and were not examined further.
• The Enbridge crack management
group used a fatigue-crack growth
model to predict the remaining life of
the pipeline. In 2011, an independent
consultant determined that the
‘‘environmentally assisted cracking
mechanism that is most prevalent along
Enbridge’s liquid pipeline system is
either near-neutral pH SCC (stress
corrosion cracking) or corrosion
fatigue.’’ The growth rates of
environmentally assisted cracks can be
exponentially greater than nominal
fatigue-crack growth rates.
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PHMSA Control Center Operations and
Training Regulations
Sections 192.631 and 195.446 contain
the requirements for gas transmission
and hazardous liquid control room
management, respectively, which
establish roles and responsibilities, tools
and procedures that allow operators to
perform their duties, alarm management
and training. The requirements address
many of the deficiencies NTSB noted
that led to the prolonged release of
crude oil in Marshall, Michigan (see
also: Guidance in Advisory Bulletins
ADB–2005–06; ‘‘Countermeasures to
Prevent Human Fatigue in the Control
Room;’’ 70 FR 46917; August 11, 2005,
and ADB–2010–01; ‘‘Leak Detection on
Hazardous Liquid Pipelines;’’ 75 FR
4134; January 26, 2010).
Deficiencies Found in Enbridge’s
Control Center Operations and Training
With respect to Enbridge’s control
center operations and training, the
NTSB concluded:
• Due to the rapid growth of
Enbridge’s pipeline system, Enbridge
hired additional control center staff
without objectively assessing whether
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that growth in personnel would affect
safe operations.
• The leak detection process was
prone to misinterpretation, and control
center analysts and operators were not
adequately trained in how to recognize
or address leaks, especially during
startup and shutdown. Therefore, lowpressure alarms, material balance
system alarms and sudden and complete
loss of pump station discharge pressure
were mistakenly attributed to column
separation rather than a pipeline
rupture. Furthermore, the control center
ignored warnings from field and
operations personnel that there was a
possible leak. In post-accident
interviews, control center personnel
attributed its disinclination to believe a
rupture had occurred to the absence of
external leak detection notifications,
despite known limitations of the leak
detection system.
• Control room personnel did not
follow the established procedure to shut
the pipeline down if column separation
couldn’t be resolved within 10 minutes.
• Enbridge failed to train the control
center staff in team performance, which
resulted in poor communication and
lack of leadership.
PHMSA’s Public Awareness/Public
Education Regulations
Sections 192.616 and 195.440 contain
the requirements for gas transmission
and hazardous liquid operators’ public
awareness programs (PAP), respectively.
These regulations incorporate the
American Petroleum Institute’s (API)
Recommended Practice (RP) 1162,
‘‘Public Awareness Programs for
Pipeline Operators,’’ and require that
operators notify affected municipalities,
school districts, businesses and
residents of the location of pipelines
and pipeline facilities (see also:
guidance in ADB–2010–08; ‘‘Emergency
Preparedness Communications;’’ 75 FR
67807; November 3, 2010, and ADB–
2012–09; ‘‘Communication During
Emergency Situations;’’ 77 FR 61826;
October 11, 2012). Section 8 of API RP
1162 contains guidance for
communicating with emergency
responders, periodic evaluation of an
operator’s PAP, and measuring the
effectiveness of an operator’s PAP (see
also: guidance in ADB–2003–04;
‘‘Pipeline Industry Implementation of
Effective Public Awareness Programs;’’
68 FR 52816; September 5, 2003, and
ADB–2003–08; ‘‘Self-Assessment of
Pipeline Operator Public Education
Programs;’’ 68 FR 66155; November 25,
2003).
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Deficiencies Found in Enbridge’s Public
Awareness/Public Education Program
The NTSB identified several
deficiencies in Enbridge’s PAP,
including:
• Enbridge’s PAP failed to effectively
inform the affected public, including
citizens and emergency response
agencies about the location of the
pipeline, how to identify a pipeline
release and how to report suspected
product releases.
• Enbridge’s review of its public
awareness program was ineffective in
identifying and correcting deficiencies.
• An effective public awareness
program would have better prepared
local emergency response agencies to
identify and respond to early
indications of a rupture, which, once
communicated to Enbridge, would have
prevented the restart of the line.
II. Advisory Bulletin (ADB–2014–02)
To: Owners and Operators of Natural
Gas and Hazardous Liquid Pipeline
Systems.
Subject: Integrity Management
Lessons Learned from the Marshall,
Michigan, Release.
Advisory: To strengthen the
Department’s safety efforts, PHMSA is
issuing this advisory bulletin to notify
pipeline owners and operators they
should evaluate their safety programs
and implement any changes to eliminate
deficiencies similar to the ones the
National Transportation Safety Board
(NTSB) found when it investigated
Enbridge’s July 25, 2010, crude oil
release in Marshall, Michigan.
Specifically, the NTSB investigation
into the circumstances leading up to
and following the release identified
specific deficiencies in three Enbridge
programs: integrity management (IM),
control center operations and public
awareness. Had existing regulations,
guidance, advisories and
recommendations regarding these
programs been properly acted upon, the
consequences of that incident could
have been prevented, or at the very
least, mitigated.
Integrity Management
A fundamental tenet of the IM
program is that pipeline operators must
be aware of the physical attributes of
their pipelines, the threats and risks
posed by and to their pipelines, and the
environments which their pipelines
transverse. Operator IM programs
should reflect the recognition that each
pipeline is unique and has its own
specific risk profile that is dependent
upon the pipeline’s attributes,
geographical location, design, operating
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environment, and commodity it
transports, among other factors. It is
vital for operators to compile and
integrate this information into their IM
programs to effectively identify and
evaluate risk. If this information is
unknown, unknowable or uncertain,
operators need to take a more
conservative approach to operations.
As part of a robust IM program, an
operator will match and use the right
tools for the threats being investigated,
set the proper schedule for pipeline
segment integrity assessments and
identify the need for additional
preventative and mitigative measures
that protect pipeline integrity, including
lower operating pressures, automatic
shutoff or remotely controlled valves
and additional right-of-way markers.
However, an operator’s IM program
must go beyond simply assessing
pipeline segments and repairing
defects—in fact, American Petroleum
Institute (API) Standard 1160,
‘‘Managing System Integrity for
Hazardous Liquid Pipelines,’’ defines
pipeline risk assessment as a continuous
process and defines risk analysis as a
continuous reassessment process.
Continual improvement of IM programs
(including improvements in the
analytical processes involved in
analyzing assessment results,
identifying threats, responding to risks,
the application and implementation of
assessments and the development of
preventative and mitigative measures) is
a key aspect and critical objective of an
effective IM program.
Occasionally, accident investigations
or other events cause changes in how
operators analyze assessment data,
including analytical procedures,
algorithms, software, acceptance criteria
or how anomalies are classified. For
instance, a change in how an anomaly
is classified could impact remediation
time frames, assessment intervals,
decisions regarding preventative and
mitigative measures and the overall
perception of the integrity of the
pipeline. The NTSB noted that Enbridge
accounted for changed tool tolerances
when re-analyzing its Line 3 data after
an incident, but this change in tool
tolerances was not applied to the
assessments performed on Line 6B.
Operators should evaluate any changes
in how assessment data is analyzed to
determine if those changes will alter the
results of any previously performed
integrity assessments. If so, operators
should apply those changes to any
previously performed integrity
assessments as appropriate.
To assist in evaluating possible
assessment data analysis changes,
operators should ensure that in-line
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inspection (ILI) vendors communicate
any changes in their analytical
processes that might require previous
assessments to be re-analyzed.
Improvements to vendor analytical
processes may change anomaly
classifications in previous assessments,
and while vendors typically apply these
changes to future assessments, it is rare
for vendors to re-analyze previously
performed assessments. Re-analyzing
integrity assessments when analytical
changes occur is critical for ensuring
safety based on the best available data
and expertise.
The ability to analyze and integrate
threat- and integrity-related data from
many sources is essential for operators
to continually improve and sustain
safety performance and proactive IM
programs. However, some operators are
not sufficiently aware of their pipeline
attributes, are not adequately or
consistently assessing threats and risks
and are not effectively integrating data
as a part of their IM programs. A lack
of data integration was a significant
contributor to the incident at Marshall,
MI.
When performing self-assessments of
IM programs, operators should compare
their performance measures and
program evaluations against the
guidance of ADB–2012–10, ‘‘Using
Meaningful Metrics in Conducting
Integrity Management Program
Evaluations’’ (77 FR 72435, December 5,
2012).
Control Center Operations
Sections 192.631 and 195.446 contain
the requirements for gas transmission
and hazardous liquid control room
management, respectively. These
requirements address many of the
deficiencies the NTSB noted during
their investigation of the incident at
Marshall, MI.
PHMSA advises operators to regularly
train their control room teams and
consider establishing a program to train
control center staff as teams in the
recognition of and response to
emergency and unexpected conditions
that include supervisory control and
data acquisition indications and leak
detection software. Operators should
perform periodic evaluations of their
leak detection capabilities to ensure that
adequate leak detection coverage is
maintained during transient operations,
including pipeline shutdown, pipeline
startup and column separation. PHMSA
previously issued ADB 10–01, ‘‘Leak
Detection on Hazardous Liquid
Pipelines,’’ (75 FR 4134; January 26,
2010) to provide guidance on this issue.
If an operator suffers an unexplained
loss of product, the operator should shut
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25993
down the affected pipeline until the
problem is resolved. Operators should
additionally assess the performance of
their leak detection system following a
product release and identify and
implement improvements as
appropriate.
Pipeline owners and operators are
also reminded to evaluate their control
room personnel scheduling policies and
practices against the guidance of ADB
05–06, ‘‘Countermeasures to Prevent
Human Fatigue in the Control Room’’
(70 FR 46917; August 11, 2005).
Public Awareness Programs
PHMSA advises operators to analyze
and evaluate the effectiveness of their
public awareness programs and whether
local emergency response agencies are
prepared to identify and respond to
early indications of a rupture. Strong
public awareness and education
programs can help shorten incident
response times and improve overall
incident response.
Pipeline owners and operators should
perform periodic self-assessments of
their public awareness programs against
their written public awareness program
plans and API Recommended Practice
1162. PHMSA previously issued
guidance for these self-assessments
under ADB 03–04, ‘‘Pipeline Industry
Implementation of Effective Public
Awareness Programs’’ (68 FR 52816;
September 5, 2003) and ADB 03–08,
‘‘Self-Assessment of Pipeline Operator
Public Education Programs’’ (68 FR
66155; November 25, 2003). Further,
operators are encouraged to review their
procedures for communicating during
emergency situations to ensure
compliance with the guidance
previously issued in ADB 10–08,
‘‘Emergency Preparedness
Communications’’ (75 FR 67807;
November 3, 2010) and ADB 12–09,
‘‘Communication During Emergency
Situations’’ (77 FR 61826; October 11,
2012).
Proactive Self-Assessment
PHMSA strongly encourages operators
to review past and future NTSB
recommendations that the NTSB
provides to pipeline operators following
incident investigations. Operators
should proactively implement
improvements to their pipeline safety
programs based on these observations
and recommendations so that the entire
industry can benefit from the mistakes
of one operator.
Authority: 49 U.S.C. chapter 601: 49 CFR
1.53.
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Federal Register / Vol. 79, No. 87 / Tuesday, May 6, 2014 / Notices
Issued in Washington, DC on April 30,
2014.
Jeffrey D. Wiese,
Associate Administrator for Pipeline Safety.
Materials Safety Administration
(PHMSA), DOT.
ACTION: Notice of actions on Special
Permit Applications.
[FR Doc. 2014–10248 Filed 5–5–14; 8:45 am]
DEPARTMENT OF TRANSPORTATION
Pipeline and Hazardous Materials
Safety Administration
Special Permit Applications
Office of Hazardous Materials
Safety, Pipeline and Hazardous
AGENCY:
S.P. No.
In accordance with the
procedures governing the application
for, and the processing of, special
permits from the Department of
Transportation’s Hazardous Material
Regulations (49 CFR part 107, Subpart
B), notice is hereby given of the actions
on special permits applications in
(March to March 2014). The mode of
transportation involved are identified by
a number in the ‘‘Nature of
SUMMARY:
BILLING CODE 4910–60–P
Applicant
Regulation(s)
Application’’ portion of the table below
as follows: 1—Motor vehicle, 2—Rail
freight, 3—Cargo vessel, 4—Cargo
aircraft only, 5—Passenger-carrying
aircraft. Application numbers prefixed
by the letters EE represent applications
for Emergency Special Permits. It
should be noted that some of the
sections cited were those in effect at the
time certain special permits were
issued.
Issued in Washington, DC, on April 23,
2014.
Donald Burger,
Chief, Special Permits and Approvals Branch.
Nature of special permit thereof
MODIFICATION SPECIAL PERMIT GRANTED
11993–M ......
10427–M ......
Key Safety Systems, Lakeland, FL.
Astrotech Space Operations,
Inc., Titusville, FL.
10232–M ......
ITW Sexton, Decatur, AL ........
10832–M ......
Autoliv ASP, Inc., Ogden, UT
15865–M ......
HeliStream Inc., Costa Mesa,
CA.
14392–M ......
U.S. Department of Defense,
Scott AFB, IL.
49 CFR 173.301(a)(1), and
173.302a.
49 CFR 173.61(a), 173.301(g),
173.302(a), 173.336, and
177.848(d).
49 CFR 173.304(d) and
173.306(a)(3).
49 CFR 173.56(b), and
173.61(a).
49 CFR 172.101 Column(9B),
172.301(c), 175.30, 175.33,
Part 178, and 175.75.
49 CFR 172.101 Column
(10B), 176.83(a),(b) and (g),
176.84(c)(2), 176.136,
176.144(a), 172.203(a), and
172.302(c).
To modify the special permit to add a Division 2.2 material.
To modify the special permit to authorize additional launch
vehicles and increase the amount of Anhydrous ammonia
to 120 pounds.
To modify the special permit to authorize a Division 2.1 material.
To modify the special permit to remove the inner packaging
requirements, remove the requirement for trays in outer
packaging, and update locations where the permit may be
used.
To modify the special permit to authorize Class 1, 2, 4, 8, 9,
and additional Class 3 materials.
To modify the special permit to authorize all Government
owned Maritime Prepostioning Ships to use alternative
stowage.
NEW SPECIAL PERMIT GRANTED
Praxair, Inc., Danbury, CT ......
49 CFR 176.83 ........................
15954–N .......
Rooney Oilfield Services,
Odessa, TX.
49 CFR 173.202, 173.203,
173.241, 173.242 and
173.243.
15972–N .......
Heil Trailer International, Co.,
Athens, TN.
49 CFR 178.345–2, 178.346–
2, 178.347–2, 178.348–2
and 178.345–3.
15980–N .......
Windward Aviation, Inc.,
Peunene, HI.
iSi Automotive Austria GmbH,
Vienna.
49 CFR 175.9(a) .....................
16016–N .......
sroberts on DSK5SPTVN1PROD with NOTICES
15853–N .......
16031–N .......
Air Rescue Systems , Ashland, OR.
49 CFR § 172.101 Column
(9B), § 172.204(c)(3),
§ 173.27(b)(2),
§ 175.30(a)(1),§§ 172.200
and 172.301(c), Part 178
and § 175.75.
VerDate Mar<15>2010
17:34 May 05, 2014
Jkt 232001
49 CFR 173.301, 173.302a
and 173.305.
PO 00000
Frm 00181
Fmt 4703
Sfmt 4703
To authorize the transportation in commerce of certain DOT
Specification or UN certified packaging containing Division
2.1, 2.2, 2.3, 4.3, 5.1, 6.1, and Class 3 and Class 8 materials in a single Container Transport Unit (CTU) consisting
of multiple compartments in lieu of segregation when transported by cargo vessel. (mode 3)
To authorize the manufacture, mark, and and sale of non-UN
standard containers that are manifolded together within a
frame and securely mounted on a truck chassis for transportation by motor vehicle. (mode 1)
To authorize the manufacture, marking, sale and use of and
non-DOT specification cargo tanks meeting all requirements for DOT 400 series cargo tanks except for the use
of UNS S32101 (LDX 2101) as a material of construction
and the head and shell thicknesses are less than required.
(mode 1)
To authorize the transportation in commerce of aviation turbine engine fuel by external load. (mode 4)
To authorize the manufacture, marking, sale and use of nonDOT specification cylinders for use in automobile safety
systems. (modes 1, 2, 3, 4, 5)
To authorize the transportation in commerce of certain hazardous materials by cargo aircraft including by external
load in remote areas of the US without being subject to
hazard communication requirements and quantity limitations where no other means of transportation is available.
(mode 4)
E:\FR\FM\06MYN1.SGM
06MYN1
Agencies
[Federal Register Volume 79, Number 87 (Tuesday, May 6, 2014)]
[Notices]
[Pages 25990-25994]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-10248]
-----------------------------------------------------------------------
DEPARTMENT OF TRANSPORTATION
Pipeline and Hazardous Materials Safety Administration
[Docket No. PHMSA-2014-0020]
Pipeline Safety: Lessons Learned From the Release at Marshall,
Michigan
AGENCY: Pipeline and Hazardous Materials Safety Administration (PHMSA);
DOT.
ACTION: Notice; issuance of advisory bulletin.
-----------------------------------------------------------------------
SUMMARY: PHMSA is issuing an advisory bulletin to inform all pipeline
owners and operators of the deficiencies identified in Enbridge's
integrity management (IM) program that contributed to the release of
hazardous liquid near Marshall, Michigan, on July 25, 2010. Pipeline
owners and operators are encouraged to review their own IM programs for
similar deficiencies and to take corrective action. Operators should
also consider training their control room staff as teams to recognize
and respond to emergencies or unexpected conditions. Further, the
advisory encourages operators to evaluate their leak detection
capabilities to ensure adequate leak detection coverage during
transient operations and assess the performance of their leak detection
systems following a product release to identify and implement
improvements as appropriate. Additionally, operators are encouraged to
review the effectiveness of their public awareness programs and whether
local emergency response teams are adequately prepared to identify and
respond to early indications of ruptures. Finally, this advisory
reminds all pipeline owners and operators to review National
Transportation Safety Board recommendations following accident
investigations. Owners and operators should evaluate and implement
recommendations that are applicable to their programs.
FOR FURTHER INFORMATION CONTACT: Linda Daugherty by phone at 816-329-
3821 or by email at linda.daugherty@dot.gov. Information about PHMSA
may be found at https://phmsa.dot.gov.
SUPPLEMENTARY INFORMATION:
I. Background
On July 25, 2010, at 5:58 p.m. eastern daylight time, a segment of
a 30-inch-
[[Page 25991]]
diameter pipeline (Line 6B), owned and operated by Enbridge
Incorporated (Enbridge), ruptured in a wetland near Marshall, Michigan.
The rupture was not discovered or addressed for over 17 hours. During
that time period, Enbridge twice pumped additional oil (81 percent of
the total release) into Line 6B during two startups. The total release
was estimated to be 843,444 gallons of crude oil. The oil saturated the
surrounding wetlands and flowed into Talmadge Creek and the Kalamazoo
River. Local residents self-evacuated from their homes, and serious
environmental damage required long-term remediation. About 320 people
reported symptoms consistent with crude oil exposure. No fatalities
were reported. Cleanup and remediation continues, and costs have
exceeded $1 billion.
The National Transportation Safety Board (NTSB) determined that the
probable cause of the pipeline rupture was stress corrosion cracking
that grew and coalesced from crack and corrosion defects under
disbonded polyethylene tape coating. The NTSB also determined the
rupture and prolonged release were caused by pervasive organizational
failures at Enbridge that included: (1) Deficient integrity management
(IM) procedures, which allowed well-documented crack defects in
corroded areas to propagate until the pipeline failed; (2) inadequate
training of control center personnel, which resulted in Enbridge's
failure to recognize the rupture for 17 hours and through two re-starts
of the pipeline; and (3) insufficient public awareness and education,
which allowed the release to continue for nearly 14 hours after the
first notification of an odor to local emergency response agencies.
PHMSA IM Regulations
Subpart O of 49 CFR part 192 and Sec. 195.452, also known as the
IM regulations, require operators of gas transmission and hazardous
liquid pipelines to institute a continual process for evaluation of
pipeline integrity (see also: Guidance in Advisory Bulletin ADB-2012-
10, ``Using Meaningful Metrics in Conducting Integrity Management
Program Evaluations,'' 77 FR 72435, December 5, 2012). Specifically,
Sec. Sec. 192.937 and 195.453(j) require that an operator have a
continual process for the evaluation of pipeline integrity. The
evaluation must consider the results of integrity assessments, data
collection and integration, remediation, and preventative and
mitigative actions in evaluating pipeline integrity. The operator must
use the results from this evaluation to identify the threats specific
to each pipeline segment that could impact a High Consequence Area
(HCA) and the risk represented by those threats. The operator must
perform assessments that are specific to those threats and then
identify and implement appropriate remedial, preventative and
mitigative measures. Sections 192.945 and 195.452(k) require that an
operator have methods to measure the effectiveness of their integrity
management programs.
An operator's IM program must include the results of past and
present integrity assessments, risk assessment information and data
integrated from throughout the pipeline system. This information and
its analysis must be taken into account when making decisions about
remediation, preventive and mitigative actions.
The ability to integrate and analyze threat and integrity related
data from many sources is essential for sustaining and continually
improving safety performance and a proactive IM program. Operators must
use the results from this integrated evaluation to identify the threats
specific to each pipeline segment that could impact a HCA. The operator
must then perform assessments that are specific to the identified
threats and implement remedial, preventive and mitigative measures, as
appropriate.
The IM regulations supplement PHMSA's prescriptive safety
regulations with requirements that are more performance-based and
process-oriented. One of the fundamental tenets of the IM program is
that each individual pipeline has a unique risk profile that is
dependent on factors including the pipeline's physical attributes, its
geographical location, its design, its operating environment and the
commodity it transports. Pipeline operators use this risk profile to
identify appropriate assessment tools, set the schedule for performing
integrity assessments and identify the need for additional preventive
and mitigative measures such as lowering operating pressures,
installing automatic or remote control shut-off valves and installing
additional right-of-way markers, among other safety measures. If this
risk profile information is unknown, unknowable, or uncertain, the
pipeline should be operated more conservatively.
Deficiencies Found in Enbridge's IM Program
The following facts illustrate the ways in which Enbridge failed to
institute and maintain an adequate IM program:
In 2007, Enbridge experienced a release on its Line 3 in Glenavon,
Saskatchewan. Following the Transportation Safety Board of Canada's
investigation and issuance of a report, Enbridge changed its assessment
process to account for tool tolerances when performing engineering
assessments. However, Enbridge did not retroactively apply these
changes to the 2005 in-line inspection (ILI) data assessments performed
on the line that ruptured near Marshall, Michigan. In its investigation
of this incident, the NTSB found that Enbridge's IM program did not
incorporate a process of continuous reassessment to all pipeline
engineering assessments, and it neglected to apply the revised crack
assessment methods to Line 6B. The NTSB also found a lack of data
integration was a significant contributor to the consequences of the
Marshall, Michigan incident.
The NTSB further concluded:
Enbridge's response to past IM-related accidents focused
only on the proximate cause, without a systematic examination of
company actions, policies and procedures.
Enbridge's IM program consistently chose a less-than-
conservative approach to pipeline safety margins for crack features.
In preparing the risk analysis, Enbridge failed to
consider all relevant risk factors associated with the determination of
the amount of product that could be released from a rupture on Line 6B.
The results of multiple ILI assessments on Line 6B were
evaluated independently and the information from these assessments was
not properly integrated to assure pipeline integrity.
Enbridge used a lower safety margin when evaluating crack
defects versus corrosion defects. Enbridge's criterion for excavating
and remediating a crack defect was when the predicted failure pressure
was less than the hydrostatic test pressure (1.25 times maximum
operating pressure). Enbridge's criterion for excavating and
remediating a corrosion defect was when the predicted failure pressure
was less than the specified minimum yield strength (1.39 times maximum
operating pressure).
Enbridge used the maximum depth reported in a 2005
UltraScan Crack Detection (USCD) ILI tool run without accounting for
tool accuracy or performance specifications. Further, Enbridge did not
compare the 2005 USCD-reported wall thickness to a 2004 UltraScan Wall
Measurement tool run that measured local wall thicknesses. Enbridge
used the thicker, incorrect measurement in determining the predicted
failure pressure and crack growth calculations.
[[Page 25992]]
Enbridge did not account for the interaction between
corrosion and cracking. Assessments for corrosion in 2004 and for
cracks in 2005 showed areas of overlap. Using the crack depth
measurements alone likely resulted in an underestimation of the total
wall loss.
The ILI vendor's junior analyst classified certain
features from the 2005 USCD ILI tool run as ``crack-field'' features,
but the ILI vendor supervisor re-classified them as ``crack-like''
features in the report to Enbridge. Enbridge policies allowed longer
``crack-like'' features to persist without further evaluation than
``crack-field'' features. The post-accident investigation determined
that the features were in fact ``crack-field'' features. Although the
excavation threshold for ``crack-field'' features was 2.5 inches, the
misclassified features measured 3.5 inches and were not examined
further.
The Enbridge crack management group used a fatigue-crack
growth model to predict the remaining life of the pipeline. In 2011, an
independent consultant determined that the ``environmentally assisted
cracking mechanism that is most prevalent along Enbridge's liquid
pipeline system is either near-neutral pH SCC (stress corrosion
cracking) or corrosion fatigue.'' The growth rates of environmentally
assisted cracks can be exponentially greater than nominal fatigue-crack
growth rates.
PHMSA Control Center Operations and Training Regulations
Sections 192.631 and 195.446 contain the requirements for gas
transmission and hazardous liquid control room management,
respectively, which establish roles and responsibilities, tools and
procedures that allow operators to perform their duties, alarm
management and training. The requirements address many of the
deficiencies NTSB noted that led to the prolonged release of crude oil
in Marshall, Michigan (see also: Guidance in Advisory Bulletins ADB-
2005-06; ``Countermeasures to Prevent Human Fatigue in the Control
Room;'' 70 FR 46917; August 11, 2005, and ADB-2010-01; ``Leak Detection
on Hazardous Liquid Pipelines;'' 75 FR 4134; January 26, 2010).
Deficiencies Found in Enbridge's Control Center Operations and Training
With respect to Enbridge's control center operations and training,
the NTSB concluded:
Due to the rapid growth of Enbridge's pipeline system,
Enbridge hired additional control center staff without objectively
assessing whether that growth in personnel would affect safe
operations.
The leak detection process was prone to misinterpretation,
and control center analysts and operators were not adequately trained
in how to recognize or address leaks, especially during startup and
shutdown. Therefore, low-pressure alarms, material balance system
alarms and sudden and complete loss of pump station discharge pressure
were mistakenly attributed to column separation rather than a pipeline
rupture. Furthermore, the control center ignored warnings from field
and operations personnel that there was a possible leak. In post-
accident interviews, control center personnel attributed its
disinclination to believe a rupture had occurred to the absence of
external leak detection notifications, despite known limitations of the
leak detection system.
Control room personnel did not follow the established
procedure to shut the pipeline down if column separation couldn't be
resolved within 10 minutes.
Enbridge failed to train the control center staff in team
performance, which resulted in poor communication and lack of
leadership.
PHMSA's Public Awareness/Public Education Regulations
Sections 192.616 and 195.440 contain the requirements for gas
transmission and hazardous liquid operators' public awareness programs
(PAP), respectively. These regulations incorporate the American
Petroleum Institute's (API) Recommended Practice (RP) 1162, ``Public
Awareness Programs for Pipeline Operators,'' and require that operators
notify affected municipalities, school districts, businesses and
residents of the location of pipelines and pipeline facilities (see
also: guidance in ADB-2010-08; ``Emergency Preparedness
Communications;'' 75 FR 67807; November 3, 2010, and ADB-2012-09;
``Communication During Emergency Situations;'' 77 FR 61826; October 11,
2012). Section 8 of API RP 1162 contains guidance for communicating
with emergency responders, periodic evaluation of an operator's PAP,
and measuring the effectiveness of an operator's PAP (see also:
guidance in ADB-2003-04; ``Pipeline Industry Implementation of
Effective Public Awareness Programs;'' 68 FR 52816; September 5, 2003,
and ADB-2003-08; ``Self-Assessment of Pipeline Operator Public
Education Programs;'' 68 FR 66155; November 25, 2003).
Deficiencies Found in Enbridge's Public Awareness/Public Education
Program
The NTSB identified several deficiencies in Enbridge's PAP,
including:
Enbridge's PAP failed to effectively inform the affected
public, including citizens and emergency response agencies about the
location of the pipeline, how to identify a pipeline release and how to
report suspected product releases.
Enbridge's review of its public awareness program was
ineffective in identifying and correcting deficiencies.
An effective public awareness program would have better
prepared local emergency response agencies to identify and respond to
early indications of a rupture, which, once communicated to Enbridge,
would have prevented the restart of the line.
II. Advisory Bulletin (ADB-2014-02)
To: Owners and Operators of Natural Gas and Hazardous Liquid
Pipeline Systems.
Subject: Integrity Management Lessons Learned from the Marshall,
Michigan, Release.
Advisory: To strengthen the Department's safety efforts, PHMSA is
issuing this advisory bulletin to notify pipeline owners and operators
they should evaluate their safety programs and implement any changes to
eliminate deficiencies similar to the ones the National Transportation
Safety Board (NTSB) found when it investigated Enbridge's July 25,
2010, crude oil release in Marshall, Michigan. Specifically, the NTSB
investigation into the circumstances leading up to and following the
release identified specific deficiencies in three Enbridge programs:
integrity management (IM), control center operations and public
awareness. Had existing regulations, guidance, advisories and
recommendations regarding these programs been properly acted upon, the
consequences of that incident could have been prevented, or at the very
least, mitigated.
Integrity Management
A fundamental tenet of the IM program is that pipeline operators
must be aware of the physical attributes of their pipelines, the
threats and risks posed by and to their pipelines, and the environments
which their pipelines transverse. Operator IM programs should reflect
the recognition that each pipeline is unique and has its own specific
risk profile that is dependent upon the pipeline's attributes,
geographical location, design, operating
[[Page 25993]]
environment, and commodity it transports, among other factors. It is
vital for operators to compile and integrate this information into
their IM programs to effectively identify and evaluate risk. If this
information is unknown, unknowable or uncertain, operators need to take
a more conservative approach to operations.
As part of a robust IM program, an operator will match and use the
right tools for the threats being investigated, set the proper schedule
for pipeline segment integrity assessments and identify the need for
additional preventative and mitigative measures that protect pipeline
integrity, including lower operating pressures, automatic shutoff or
remotely controlled valves and additional right-of-way markers.
However, an operator's IM program must go beyond simply assessing
pipeline segments and repairing defects--in fact, American Petroleum
Institute (API) Standard 1160, ``Managing System Integrity for
Hazardous Liquid Pipelines,'' defines pipeline risk assessment as a
continuous process and defines risk analysis as a continuous
reassessment process. Continual improvement of IM programs (including
improvements in the analytical processes involved in analyzing
assessment results, identifying threats, responding to risks, the
application and implementation of assessments and the development of
preventative and mitigative measures) is a key aspect and critical
objective of an effective IM program.
Occasionally, accident investigations or other events cause changes
in how operators analyze assessment data, including analytical
procedures, algorithms, software, acceptance criteria or how anomalies
are classified. For instance, a change in how an anomaly is classified
could impact remediation time frames, assessment intervals, decisions
regarding preventative and mitigative measures and the overall
perception of the integrity of the pipeline. The NTSB noted that
Enbridge accounted for changed tool tolerances when re-analyzing its
Line 3 data after an incident, but this change in tool tolerances was
not applied to the assessments performed on Line 6B. Operators should
evaluate any changes in how assessment data is analyzed to determine if
those changes will alter the results of any previously performed
integrity assessments. If so, operators should apply those changes to
any previously performed integrity assessments as appropriate.
To assist in evaluating possible assessment data analysis changes,
operators should ensure that in-line inspection (ILI) vendors
communicate any changes in their analytical processes that might
require previous assessments to be re-analyzed. Improvements to vendor
analytical processes may change anomaly classifications in previous
assessments, and while vendors typically apply these changes to future
assessments, it is rare for vendors to re-analyze previously performed
assessments. Re-analyzing integrity assessments when analytical changes
occur is critical for ensuring safety based on the best available data
and expertise.
The ability to analyze and integrate threat- and integrity-related
data from many sources is essential for operators to continually
improve and sustain safety performance and proactive IM programs.
However, some operators are not sufficiently aware of their pipeline
attributes, are not adequately or consistently assessing threats and
risks and are not effectively integrating data as a part of their IM
programs. A lack of data integration was a significant contributor to
the incident at Marshall, MI.
When performing self-assessments of IM programs, operators should
compare their performance measures and program evaluations against the
guidance of ADB-2012-10, ``Using Meaningful Metrics in Conducting
Integrity Management Program Evaluations'' (77 FR 72435, December 5,
2012).
Control Center Operations
Sections 192.631 and 195.446 contain the requirements for gas
transmission and hazardous liquid control room management,
respectively. These requirements address many of the deficiencies the
NTSB noted during their investigation of the incident at Marshall, MI.
PHMSA advises operators to regularly train their control room teams
and consider establishing a program to train control center staff as
teams in the recognition of and response to emergency and unexpected
conditions that include supervisory control and data acquisition
indications and leak detection software. Operators should perform
periodic evaluations of their leak detection capabilities to ensure
that adequate leak detection coverage is maintained during transient
operations, including pipeline shutdown, pipeline startup and column
separation. PHMSA previously issued ADB 10-01, ``Leak Detection on
Hazardous Liquid Pipelines,'' (75 FR 4134; January 26, 2010) to provide
guidance on this issue. If an operator suffers an unexplained loss of
product, the operator should shut down the affected pipeline until the
problem is resolved. Operators should additionally assess the
performance of their leak detection system following a product release
and identify and implement improvements as appropriate.
Pipeline owners and operators are also reminded to evaluate their
control room personnel scheduling policies and practices against the
guidance of ADB 05-06, ``Countermeasures to Prevent Human Fatigue in
the Control Room'' (70 FR 46917; August 11, 2005).
Public Awareness Programs
PHMSA advises operators to analyze and evaluate the effectiveness
of their public awareness programs and whether local emergency response
agencies are prepared to identify and respond to early indications of a
rupture. Strong public awareness and education programs can help
shorten incident response times and improve overall incident response.
Pipeline owners and operators should perform periodic self-
assessments of their public awareness programs against their written
public awareness program plans and API Recommended Practice 1162. PHMSA
previously issued guidance for these self-assessments under ADB 03-04,
``Pipeline Industry Implementation of Effective Public Awareness
Programs'' (68 FR 52816; September 5, 2003) and ADB 03-08, ``Self-
Assessment of Pipeline Operator Public Education Programs'' (68 FR
66155; November 25, 2003). Further, operators are encouraged to review
their procedures for communicating during emergency situations to
ensure compliance with the guidance previously issued in ADB 10-08,
``Emergency Preparedness Communications'' (75 FR 67807; November 3,
2010) and ADB 12-09, ``Communication During Emergency Situations'' (77
FR 61826; October 11, 2012).
Proactive Self-Assessment
PHMSA strongly encourages operators to review past and future NTSB
recommendations that the NTSB provides to pipeline operators following
incident investigations. Operators should proactively implement
improvements to their pipeline safety programs based on these
observations and recommendations so that the entire industry can
benefit from the mistakes of one operator.
Authority: 49 U.S.C. chapter 601: 49 CFR 1.53.
[[Page 25994]]
Issued in Washington, DC on April 30, 2014.
Jeffrey D. Wiese,
Associate Administrator for Pipeline Safety.
[FR Doc. 2014-10248 Filed 5-5-14; 8:45 am]
BILLING CODE 4910-60-P