NTSB Safety Recommendation P-12-005

NTSB safety recommendation P-12-005.

TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Conduct a comprehensive inspection of Enbridge Incorporated’s integrity management program after it is revised in accordance with Safety Recommendation P-12-11.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 2012-07-25

Adopted Date: 2012-07-10

Overall Date Closed: 2015-04-08

Synopsis: On Sunday, July 25, 2010, about 5:58 p.m., eastern daylight time, a segment of a 30-inch-diameter pipeline (Line 6B), owned and operated by Enbridge Incorporated (Enbridge) ruptured in a wetland in Marshall, Michigan. The rupture occurred during the last stages of a planned shutdown and was not discovered or addressed for 17 hours. During the time lapse, 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 the Talmadge Creek and the Kalamazoo River. Local residents self-evacuated from their houses, and the environment was negatively affected. Cleanup efforts continue as of the adoption date of this report, with continuing costs exceeding $767 million. About 320 people reported symptoms consistent with benzene exposure. No fatalities were reported.

Probable Cause: The National Transportation Safety Board (NTSB) determines that the probable cause of the pipeline rupture was corrosion fatigue cracks that grew and coalesced from crack and corrosion defects under disbonded polyethylene tape coating, producing a substantial crude oil release that went undetected by the control center for over 17 hours. The rupture and prolonged release were made possible by pervasive organizational failures at Enbridge Incorporated (Enbridge) that included the following: Deficient integrity management procedures, which allowed well-documented crack defects in corroded areas to propagate until the pipeline failed. Inadequate training of control center personnel, which allowed the rupture to remain undetected for 17 hours and through two startups of the pipeline. 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. Contributing to the accident was the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) weak regulation for assessing and repairing crack indications, as well as PHMSA’s ineffective oversight of pipeline integrity management programs, control center procedures, and public awareness. Contributing to the severity of the environmental consequences were (1) Enbridge’s failure to identify and ensure the availability of well-trained emergency responders with sufficient response resources, (2) PHMSA’s lack of regulatory guidance for pipeline facility response planning, and (3) PHMSA’s limited oversight of pipeline emergency preparedness that led to the approval of a deficient facility response plan.

Ntsbnumber: DCA10MP007

Report Number: PAR-12-01

Addressee Name: PHMSA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2015-04-08

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2014-01-03

Communication Type: Official Correspondence

Communication Contents: We are aware of PHMSA’s civil action against Enbridge relating to the company’s failures that resulted in the Marshall, Michigan, oil spill, and we note that, after the July 2012 failure of Enbridge’s pipeline in Grand Marsh, Wisconsin, PHMSA issued a corrective action order to the company. We are encouraged (1) that PHMSA reviewed Enbridge’s compliance with the new regulations on control room management and public awareness effectiveness and (2) that the agency will continue monitoring Enbridge’s progress and compliance. Pending completion of these efforts, Safety Recommendation P-12-5 remains classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2015-04-08

Communication Type: Official Correspondence

Communication Contents: We are aware that you completed the requested inspection of Enbridge Incorporated’s IM program. Accordingly, Safety Recommendation P-12-5 is classified CLOSED—ACCEPTABLE ACTION. For your information, the companion recommendation to Enbridge Incorporated, Safety Recommendation P-12-11, was classified “Closed—Acceptable Action” on November 20, 2014.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2013-01-11

Communication Type: Official Correspondence

Communication Contents: The NTSB notes that PHMSA plans to conduct a comprehensive inspection of Enbridge’s integrity management program, once the company completes revisions to its integrity management program as delineated in Safety Recommendation P-12-11. We also note that, on August 6, 2012, PHMSA executed a Consent Agreement and Order incorporating a comprehensive safety plan for oversight of Enbridge’s Lakehead system consistent with Safety Recommendation P-12-11, which includes additional elements to improve the safety record of Enbridge’s Lakehead pipeline system. Pending completion of the recommended action, Safety Recommendation P-12-5 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2013-08-29

Communication Type: Official Correspondence

Communication Contents: -From Cynthia L. Quarterman, Administrator: PHMSA has issued a record setting $3.7 million civil penalty against Enbridge for findings relating to Enbridge’s existing integrity management program, which failed to prevent the significant oil spill at Marshall, Michigan. PHMSA also developed a comprehensive approach to reviewing Enbridge’s actions. Following another Enbridge pipeline failure on July 27, 2012, on Enbridge’s Line 14 in Grand Marsh, Wisconsin, PHMSA issued a Corrective Action Order (CAO) covering far more than typical requirements normally contained in CAOs. The order required the development and implementation of a comprehensive plan to improve the safety record on Enbridge’s entire Lakehead system. The Lakehead Plan addressed multiple integrity management elements, including improvements to risk modeling, pipeline integrity verification, in-line inspection, pipe replacement programs, valve placement, leak detection systems, and other safety improvements. Det Norske Veritas (DNV), retained under our CAO as an independent third party verification agent, completed its review of the Lakehead Plan and submitted a final report to PHMSA on June 30, 2013. DNV considers the Plan adequate, and when it is implemented effectively, anticipates an improvement in safety performance. DNV will monitor the implementation of the Lakehead Plan to evaluate its effectiveness in improving safety performance and integrity management. In addition to the PHMSA oversight described above, PHMSA has also conducted a review of Enbridge’s compliance with the new regulations on Control Room Management and public awareness effectiveness. PHMSA will continue to closely monitor Enbridge’s progress toward implementing the Lakehead plan, requirements contained in PHMSA enforcement actions, and regulatory requirements. PHMSA will also continue to review and improve its regulations.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2015-01-22

Communication Type: Official Correspondence

Communication Contents: -From Timothy P. Butters, Acting Administrator: PHMSA proposes closure of this recommendation. PHMSA has developed a comprehensive approach to improving Enbridge's safety record, including reviewing its IM program for the entire Lakehead system. The Lakehead Plan addressed multiple IM elements, including improvements to risk modeling, pipeline integrity verification, in-line inspection, pipe replacement programs, valve placement, leak detection systems, and other safety improvements. Det Norske Veritas Germanischer Lloyd (DNV GL), retained under our Corrective Action Order as an independent third-party verification agent, completed its review of the Lakehead Plan and considers the Plan adequate and anticipates an improvement in safety performance when the plan is fully implemented. At this stage, DNV GL is currently monitoring the implementation of the Lakehead Plan to evaluate its effectiveness. Through our inspection and enforcement program, PHMSA will continue to review and closely monitor the ongoing efforts of both DNV GLand Enbridge to ensure implementation of the Lakehead Plan and requirements contained in PHMSA enforcement actions and regulations. Our goal is to ensure improvements occur not only to Enbridge's integrity management program, but to its overall safety performance. PHMSA will also continue to review and improve its regulations. PHMSA has drafted an NPRM titled "Pipeline Safety: Safety of On-Shore Hazardous Liquid Pipelines," which proposes changes to integrity management requirements. The NPRM is currently under review with the Office of Management and Budget, and our anticipated publication date is May 2015.

Addressee Acronym: PHMSA

Addressee Organization Type: G-Federal Government

Communication Date: 2012-11-01

Communication Type: Official Correspondence

Communication Contents: -From Cynthia Quarterman, Administrator: PHMSA will conduct a comprehensive inspection of Enbridge’s integrity management program as recommended by NTSB. The timing of the inspection will be contingent on Enbridge’s completion of its revisions to the integrity management program as delineated in Safety Recommendation P-12-11. Additionally, on August 6, 2012, PHMSA executed a Consent Agreement and Order incorporating a comprehensive safety plan for oversight of Enbridge’s Lakehead system.