NTSB Safety Recommendation P-12-017

NTSB safety recommendation P-12-017.

TO THE AMERICAN PETROLEUM INSTITUTE: Facilitate the development of a safety management system standard specific to the pipeline industry that is similar in scope to your Recommended Practice 750, Management of Process Hazards. The development should follow established American National Standards Institute requirements for standard development.

Priority: CLASS II

Overall Status: Closed - Exceeds Recommended Action

Issued Date: 2012-07-25

Adopted Date: 2012-07-10

Overall Date Closed: 2015-10-22

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: American Petroleum Institute

Addressee Status: Closed - Exceeds Recommended Action

Addressee Date Closed: 2015-10-22

Addressee Acronym: API

Addressee Organization Type: A-Associations

Communication Date: 2012-09-24

Communication Type: Official Correspondence

Communication Contents: -From Jack M. Gerard, President and Chief Executive Officer: API is pleased to respond to the U.S. National Transportation Safety Board (NTSB) recommendation P-12-17 as follows: The NTSB had recommended that API "Facilitate the development of a safety management system standard specific to the pipeline industry that is similar in scope to your Recommended Practice 750, Management of Process Hazards. The development should follow established American National Standards Institute requirements for standard development." The joint API/ AOPL Pipeline Performance Excellence Team (PET) has begun its review of the recommendation, utilizing existing standards documents including API Recommended Practice 750 and existing member company management systems as bases for consideration. Members of the PET also met with NTSB staff on August 30, 2012, in order to more fully understand recommendation P-12-17 and to discuss the standards development process. API will now form a standards work group in accordance with API's Procedures for Standards Development, which are accredited by the American National Standards Institute. As the standards development process progresses API will periodically provide updates to NTSB staff to ensure coordination on this important safety standard.

Addressee Acronym: API

Addressee Organization Type: A-Associations

Communication Date: 2014-06-24

Communication Type: Official Correspondence

Communication Contents: -From Peter T. Lidiak, Director, Pipeline: This is to update the National Transportation Safety Board on the progress being made to develop a consensus standard for Pipeline Safety Management Systems, per the above referenced safety recommendation from the Marshall Michigan Incident Investigation Report, July 2012. API formed a multi-stakeholder work group to develop the document in December 2012. Members include oil and gas pipeline operator personnel and trade association staff, federal and state agency personnel, including senior staff from PHMSA, NTSB and members of NAPSR, and safety experts representing the public. The work group has met face-to-face monthly since then and on June 20, 2014, submitted a draft of the API Recommended Practice 1173, 1st edition for balloting. PHMSA hosted a public workshop in mid-February to receive an overview of the draft document, gather input for the work group to consider and discuss important elements of safety management systems. The draft document was made available for public review and comment from February 28 through April 11, 2014. The work group then addressed comments from the public review process leading to the current balloted draft. Balloting will be conducted by the API Pipeline Operations & Technical Group (OTG), the standing body for balloting of API pipeline consensus standards in accordance with API’s American National Standards Institute (ANSI) approved “Procedures for Standards Development”. Once approved, the standard will be submitted to the ANSI Board of Standards Review for review and final approval as an American National Standard with the designation ANSI/API 1173. The OTG will complete its review on August 1st and API will accept public comment per the ANSI process through August 4th. We anticipate receiving comments on the document that will require resolution by the work group, potential reballot of any significant revisions and final publication sometime before the end of this year. Please let us know if you have any questions about the development process. For your information, Robert Beaton is representing NTSB on the work group in a non-voting capacity.

Addressee Acronym: API

Addressee Organization Type: A-Associations

Communication Date: 2015-08-05

Communication Type: Official Correspondence

Communication Contents: -From Jack N. Gerard, President and CEO: After review and consultation with NTSB staff API formed a standards work group to develop the standard. The work group was formed in accordance with API's Procedures for Standards Development, which are accredited by the American National Standards Institute, and represented a balanced group of stakeholders. API Recommended Practice 1173, Pipeline Safety Management Systems, provides an important framework for the pipeline industry's continuous improvement efforts. API would like to thank both NTSB and PHMSA staff for their active participation in the standards development process. A copy of the standard is attached for your review.

Addressee Acronym: API

Addressee Organization Type: A-Associations

Communication Date: 2014-08-13

Communication Type: Official Correspondence

Communication Contents: We understand that you formed a multi-stakeholder work group in December 2012 to develop the requested document you plan to issue as American National Standard ANSI/API 1173 before the end of 2014. Pending publication of the final document, Safety Recommendation P 12-17 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: API

Addressee Organization Type: A-Associations

Communication Date: 2012-11-13

Communication Type: Official Correspondence

Communication Contents: The NTSB understands that the Pipeline Performance Team of the American Petroleum Institute/Association of Oil Pipe Lines has initiated work to develop the recommended standard. Accordingly, pending completion of this project, Safety Recommendation P-12-17 is classified OPEN—ACCEPTABLE RESPONSE.

Addressee Acronym: API

Addressee Organization Type: A-Associations

Communication Date: 2015-10-22

Communication Type: Official Correspondence

Communication Contents: We are pleased that you issued API RP 1173, Pipeline Safety Management Systems (PSMS), on July 8, 2015, to assist pipeline operators in reviewing an existing PSMS or developing and implementing a new PSMS. We appreciate your consulting NTSB and Pipeline Safety and Hazardous Materials Safety Administration staffs and forming a standards work group to develop this standard in accordance with your Procedures for Standards Development, accredited by ANSI. We believe that RP 1173 provides an important framework for the pipeline industry’s continuous improvement efforts and are pleased that it exceeds API 750 by addressing safety culture and other important safety issues. We also commend you for your swift action in forming the work group, developing the standard, and issuing it in under 3 years. In addition, we are very pleased with the commitment and efforts of the Interstate Natural Gas Association of America, the Association of Oil Pipelines, and the American Gas Association (AGA) to promote and faciliate the adoption of RP 1173 by pipeline companies. We understand that nine AGA member companies have already committed to pilot implementation of the recommended practice. The content of API Recommended Practice 1173 exceeds our original intent in issuing Safety Recommendation P 12-17; accordingly, the recommendation is classified CLOSED—EXCEEDS RECOMMENDED ACTION.