NTSB Safety Recommendation P-02-003

NTSB safety recommendation P-02-003.

The National Transportation Safety Board makes the following safety recommendation to the Environmental Protection Agency: Require all your regions to integrate the principles contained in the National Response Team’s Technical Assistance Document Incident Command System/Unified Command-Managing Responses to Oil Discharges and Hazardous Substance Releases under the National Contingency Plan in their area contingency plans and require the regions to train all personnel who are assigned responsibility to implement the plans according to those principles.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2002-08-02

Adopted Date: 2002-07-23

Overall Date Closed: 2006-08-11

Synopsis: This recommendation addresses the effectiveness of incident command. The recommendation is derived from the Safety Board's investigation of the rupture of the Piney Point Oil Pipeline and release of fuel oil near Chalk Point, Maryland, on April 7, 2000, and is consistent with the evidence we found and the analysis we performed. As a result of this investigation, the Safety Board has issued three safety recommendations, one of which is addressed to the Environmental Protection Agency (EPA). Information supporting this recommendation is discussed below. The Safety Board would appreciate a response from you within 90 days addressing the actions you have taken or intend to take to implement our recommendation.

Probable Cause: The National Transportation Safety Board determines that the probable cause of the April 7, 2000, Piney Point Oil Pipeline accident at the Potomac Electric Power Company?s Chalk Point, Maryland, generating station was a fracture in a buckle in the pipe that was undiscovered because the data from an in-line inspection tool were interpreted inaccurately as representing a T-piece. Contributing to the magnitude of the fuel oil release were inadequate operating procedures and practices for monitoring the flow of fuel oil through the pipeline to ensure timely leak detection.

Ntsbnumber: DCA00MP006

Report Number: PAR-02-01

Addressee Name: United States Environmental Protection Agency

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2006-08-11

Addressee Acronym: EPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-12-17

Communication Type: Official Correspondence

Communication Contents: Ms. Horinko advised the Safety Board that the EPA has several efforts underway to address this matter. Specifically, the EPA is currently working to integrate Incident Command System/Unified Command (ICS/UC) principles into regional and area contingency plans, and hopes to have these plans updated no later than December 2004. Regarding training, the EPA has developed and offered a course on the fundamental principles of ICS/UC to its regional On-Scene Coordinators (OSCs), who are responsible for managing incidents similar to the Piney Point Oil Pipeline rupture. The EPA will also provide this training at the upcoming 2002 OSC Readiness Training Program. Ms. Horinko further advises that the EPA is exploring ways to present this course on-line so that it is continually available to all interested EPA staff. The EPA is also developing advanced-level training on ISC/UC, which it plans to make available to OSCs early next year. Most importantly, the EPA is requiring that all OSCs participate in training on ICS/UC by December 2003. Accordingly, because the EPA is aggressively taking action as requested, Safety Recommendation P-02-3 is classified "Open--Acceptable Response," pending completion of these efforts. The Safety Board would appreciate periodic updates on actions to implement this recommendation, particularly your efforts to update the regional and area contingency plans.

Addressee Acronym: EPA

Addressee Organization Type: G-Federal Government

Communication Date: 2006-03-02

Communication Type: Official Correspondence

Communication Contents: The EPA's October 31, 2002, letter to the Safety Board (enclosed) detailed efforts then-underway to address the recommendation, and Safety Recommendation P 02-3 was classified "Open-Acceptable Response," pending completion of these efforts, on December 17, 2002. Since that time, Safety Board staff has exchanged several e-mails with EPA staff, but has been unable to confirm that action has been completed on this issue. The Safety Board would appreciate receiving a formal update on the action that the EPA has taken to implement Safety Recommendation P-02-3. Copies of the letter issuing the recommendation and our December 17, 2002, response to EPA's October 31, 2002, letter, are enclosed for your review.

Addressee Acronym: EPA

Addressee Organization Type: G-Federal Government

Communication Date: 2004-04-28

Communication Type: Official Correspondence

Communication Contents: Per our telephone conversation this morning, attached is the background information for Safety Recommendation P-02-3 which the Board issued to the EPA as a result of our investigation of the 2000 pipeline rupture and spill at the Piney Point Oil Pipeline in Chalk Point, MD. The attachments are the original recommendation letter (adobe), MC2020935 scanned is the EPA letter of 10-31-02, and the MC2020935 is the Board's letter back to EPA which classified the recommendation "Open--Acceptable Response," pending completion of the ongoing efforts to implement the recommendation. I'm hoping that this action is complete so that we can close out the recommendation. An email response from you or someone on staff with the particulars of the EPA action would suffice. I will then draft a formal letter back to EPA classifying the recommendation. I can be reached at 202-314-6174 (6178 - fax) or by email: brownm@ntsb.gov. Appreciate your help. Call me if you need further information. Mike Brown

Addressee Acronym: EPA

Addressee Organization Type: G-Federal Government

Communication Date: 2006-08-11

Communication Type: Official Correspondence

Communication Contents: The Safety Board notes that in 2002, the EPA began an aggressive Incident Command System (ICS) training program, and as of April 2006, over 2,449 EPA field personnel had received ICS training. EPA states that the ICS training is specific to the employee's job description and meets the training standards established in 2004 by the Department of Homeland Security, National Incident Management System (NIMS) Integration Center. Further, on-scene coordinators (OSCs) who are responsible for the implementation of area contingency plans are required to take ICS 100 through 400 as a baseline training requirement, and unified command principles are presented as part of the courses in ICS 300 and 400. The Safety Board further understands that the EPA developed ICS position-specific training for regional Incident Management Teams. These teams include 11 key positions, one of which is Incident Commander; the training for this position focuses heavily on a unified command response. The Safety Board notes that this training was put to the test when OSCs from the EPA responded to Hurricane Katrina. Currently, the EPA is continuing with its 2006 course schedule, which includes ICS 300 through 400, position-specific training, and a new course, "ICS for Executives." In addition, the EPA's Office of Emergency Management drafted training, certification and qualification guidance, developed a national qualifications database, and has also established a national NIMS coordinator position to assist in implementation of NIMS-based ICS throughout each of the 10 EPA regions. These actions constitute a satisfactory response to Safety Recommendation P- 02- 3; accordingly the recommendation is classified "Closed-Acceptable Action.

Addressee Acronym: EPA

Addressee Organization Type: G-Federal Government

Communication Date: 2002-10-31

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 11/08/2002 12:25:56 PM MC# 2020935 In your letter, you asked EPA to tell you what actions we have taken or intend to take to implement this recommendation. I am pleased to report we have a number of efforts underway to address this matter. EPA is currently working to integrate ICSAJC principles into Regional Contingency Plans and Area Contingency Plans. We hope to have these plans updated no later than December 2004. In the area of training, EPA has developed and offered a course on the fundamental principles of ICS'UC to our regional On-Scene Coordinators (OSCs) who are responsible for managing incidents similar to the Piney Point Oil Pipeline rupture. We are providing this training again at the upcoming 2002 OSC Readiness Training Program. We are also exploring ways to present this course on-line so that it is continually available to all interested EPA staff. Additionally, EPA is developing advanced level training on ICSKJC which we plan to have available to OSCs early next year. Most importantly, we are requiring that all OSCs participate in training on ICS/UC by December 2003. Again, thank you for your recommendation. We believe these efforts demonstrate our commitment to utilizing ICS/UC where appropriate. If you have any questions or concerns, please feel free to call Michael B. Cook, Director, Office of Emergency and Remedial Response. Mr. Cook can be reached at (703) 603-8960.

Addressee Acronym: EPA

Addressee Organization Type: G-Federal Government

Communication Date: 2006-04-20

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 4/20/2006 11:01:44 AM MC# 2060210 4-12-06: This letter provides a response to the National Transportation Safety Board, Safety Recommendation P 02-3, regarding rupture of the Piney Point Oil Pipeline and releases of fuel oil near Chalk Point, Maryland on April 7,2000. The recommendation that all personnel with the responsibility of implementing regional contingency plans receive training in the Incident Command System (ICS) and have a working knowledge of Unified Command has been put into practice within the Environmental Protection Agency (EPA). Please be advised that in 2002 EPA began an aggressive Incident Command System (ICS) training program. As of this date, over 2,449 EPA field personnel have received ICS training. EPA has spent over $800,000 ensuring the training was of the highest quality, applicable to the employee's job description, and meets the training standards established in 2004 by the Department of Homeland Security, National Incident Management System (NIMS) Integration Center. On Scene Coordinators (OSCs) who are responsible for the implementation of Area Contingency Plans are required to take ICS 100 through 400 as a base line training requirement. Unified Command principles are presented as part of the course in ICS 300 and 400. Additionally, EPA has developed ICS position specific training for regional Incident Management Teams which have 11 key positions, one of which is the Incident Commander (IC). The training developed for the IC position focuses heavily on a Unified Command response. The training program was interrupted in August of 2005 as the majority of EPA OSCs responded to Hurricane Katrina. Without hesitation and before they even had a Mission Assignment from the Federal Emergency Management Agency, EPA OSCs established Unified Command with the State of Louisiana in Baton Rouge and with the United States Coast Guard and the State of Mississippi in Mobile. By the end of the first week, Incident Action Plans were being published daily, with signatures from our response-partners in Unified Command. In spite of the fact that many of our employees are still involved in hurricane response work, EPA is continuing scheduled 2006 ICS training. The 2006 training includes ICS 300 through 400, positions specific training, team building training and a new course - , "ICS for Executives". Additionally, EPA's Office of Emergency Management (OEM) has drafted a Training, Certification and Qualification Guidance document and developed a National Qualification database. EPA has also established a National NIMS Coordination position, within OEM, to assist in implementation of NIMS based ICS through out each of the 10 EPA regions. We consider that the actions taken over the past 4 years have more than addressed the Safety Recommendation issued by NTSB on August 2,2002. We are looking forward to a continued close working relationship with the NTSB and appreciate the recommendations developed to assist us in our operating procedures. Should you have any questions regarding this correspondence, please contact Mark Mjoness, Director, Office of Emergency Management, National Planning and Preparedness Division at (202) 564-1916. Sincerely, Deborah Y. Dietrici, Director, Office of Emergency Management