NTSB Safety Recommendation P-21-021

NTSB safety recommendation P-21-021.

TO ENTERPRISE PRODUCTS: Revise your damage prevention program guidelines to include a larger tolerance zone for dredging operations.

Priority: CLASS II

Overall Status: Open - Acceptable Response

Issued Date: 2021-12-21

Adopted Date: 2021-12-07

Synopsis: On Friday, August 21, 2020, about 0802 central daylight time, the US-flagged, non-propelled, 152-foot-long cutter-head suction dredge Waymon Boyd struck a submerged 16-inch liquid propane pipeline during dredging operations adjacent to the EPIC Marine Terminal, located on the Corpus Christi Ship Channel in Corpus Christi, Texas. A geyser of propane gas and water erupted adjacent to the vessel. Shortly thereafter, gas engulfed the vessel and an explosion occurred. Fire consumed the vessel and surrounding shoreline. A total of 18 personnel employed by Orion Marine Group were working or resting on the dredge and assist boats (tender boats, anchor barges, booster barges, and a supply barge) on the day of the accident. Three crewmembers aboard the Waymon Boyd and one on an adjacent anchor barge died in the explosion and fire. Six crewmembers aboard the dredge were injured. First responders located the injured and transported them to local hospitals. They were eventually transferred to burn units in San Antonio, Texas, where one of the crewmembers later died from his injuries. The Waymon Boyd, valued at $9.48 million, was a total loss. The cost of pipeline damage was $2.09 million. The cost of physical damage to the EPIC facility was $120,000.

Probable Cause: The National Transportation Safety Board determines that the probable cause of the hazardous liquid pipeline breach, propane release, and subsequent explosion and fire aboard the dredging vessel Waymon Boyd was Orion Marine Group’s inadequate planning and risk management processes, which failed to identify the proximity of their dredging operation to Enterprise Products’ pipeline TX219 and resulted in the absence of effective controls to prevent the dredge’s cutterhead from striking the pipeline. Contributing to the accident were deficient dredging plans provided by Schneider Engineering and Consulting, which resulted in incomplete and inaccurate information communicated to Enterprise Products by Orion Marine Group during the one-call process, which resulted in insufficient measures to protect the pipeline from excavation damage.

Ntsbnumber: DCA20FM026

Report Number: MAR-21-05

Addressee Name: Enterprise Products Partners L.P.

Addressee Status: Open - Acceptable Response

Addressee Organization Type: P-Private Industry

Communication Date: 2021-12-21

Communication Type: Transmittal Letter

Communication Contents: The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to provide assistance to victims and their family members affected by major transportation disasters. The attached letter from the NTSB Chair provides information about the NTSB’s December 7, 2021, report Hazardous Liquid Pipeline Strike and Subsequent Explosion and Fire aboard Dredging Vessel Waymon Boyd, EPIC Marine Terminal, Corpus Christi Ship Channel, Corpus Christi, Texas, August 21, 2020, NTSB/MAR-21/05. The details of this accident investigation and the resulting safety recommendation may be found in the attached report, which can also be accessed at http://www.ntsb.gov. For more information about NTSB and our recommendation process, please see the attached one-page summary. The NTSB is vitally interested in these recommendations because they are designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement these recommendations. When replying, please refer to the safety recommendation by number (for example, P-21-021. We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply exceeds 20 megabytes, including attachments, please e mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response. All communications regarding safety recommendations will be stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov. The National Transportation Safety Board (NTSB) is an independent federal agency charged by Congress with investigating every civil aviation accident in the United States and significant accidents in other modes of transportation—railroad, highway, marine, and pipeline. We determine the probable cause of the accidents and issue safety recommendations aimed at preventing future accidents. In addition, we carry out special studies concerning transportation safety and coordinate the resources of the federal government and other organizations to assist victims and their family members affected by major transportation disasters. We are providing the following information to urge Enterprise Products to act on the safety recommendation in this letter because we believe your organization can help reduce the risk of future accidents. For more information about the NTSB and our recommendation process, please see the attached one-page summary. This letter also includes information about our December 7, 2021, report Hazardous Liquid Pipeline Strike and Subsequent Explosion and Fire aboard Dredging Vessel Waymon Boyd, EPIC Marine Terminal, Corpus Christi Ship Channel, Corpus Christi, Texas, August 21, 2020, NTSB/MAR-21/05. The details of this accident investigation and the resulting safety recommendations may be found in the attached report, which can also be accessed at http://www.ntsb.gov. As a result of this investigation, we identified the following safety issues: • Inadequate project planning and risk assessment. • Ineffective pipeline damage prevention. • Lack of pipeline hazard training. Accordingly, the NTSB makes the following safety recommendation to Enterprise Products. Additional information regarding this recommendation can be found in the noted section of the report. • Revise your damage prevention program guidelines to include a larger tolerance zone for dredging operations. (P-21-021) (See section 2.4.3) The NTSB is vitally interested in this recommendation because it is designed to prevent accidents and save lives. We would appreciate a response within 90 days of the date of this letter, detailing the actions you have taken or intend to take to implement this recommendation. When replying, please refer to the safety recommendation by number (Safety Recommendation P-21-021). We encourage you to submit your response to ExecutiveSecretariat@ntsb.gov. If your reply, including attachments, exceeds 20 megabytes, please e mail us at the same address for instructions on how to send larger documents. Please do not submit both an electronic copy and a hard copy of the same response. All communications regarding safety recommendations are stored by the NTSB and viewable by the public. Please do not send privileged or confidential communications in response to this recommendation. Responses marked as confidential or privileged (or similar designations) will be considered nonresponsive. In the likely event that your company uses auto generated and/or preformatted confidentiality statements on letterhead or outgoing e-mails, please include a statement in your letter indicating that the information can be publicly released. If you have concerns about this protocol, please contact us at ExecutiveSecretariat@ntsb.gov.

Addressee Organization Type: P-Private Industry

Communication Date: 2022-03-21

Communication Type: Official Correspondence

Communication Contents: -From Jeff Morton, Senior Director, Transportation Compliance: On behalf of Enterprise Products Operating LLC (“Enterprise” or “Company”), we are writing to respond to your letter dated December 21, 2021. As an initial matter, please know that Enterprise appreciated the opportunity to work with the National Transportation Safety Board (“NTSB”) and the other Parties in connection with the NTSB’s investigation into the Orion Marine Group (“Orion”) pipeline strike of Line TX219 in Corpus Christi, Texas, that occurred on August 21, 2020. We also wanted to acknowledge receipt of NTSB Safety Recommendation P-21-021 which the NTSB directed to Enterprise. Specifically, the recommendation states the following: Revise your damage prevention program guidelines to include a larger tolerance zone for dredging operations. (P-21-021) (See section 2.4.3 [of the final report]) Enterprise is implementing the NTSB’s recommendation. As NTSB knows from its investigation, the relevant document is Enterprise Operations and Maintenance Procedure (No. 3000), Damage Prevention Program. This Damage Prevention Program implements various measures to prevent damage to Enterprise assets and underground pipelines from excavation activities. This document provides the framework that allows the Company to effectively carryout its Damage Prevention Program. Enterprise is in the process of revising this document. The revised document will contain a specific section on damage prevention in the context of marine dredging, including the establishment of a larger tolerance zone during dredging operations. We anticipate completing the revision of this document by June 30, 2022. If you have any questions, please do not hesitate to contact me.

Addressee Organization Type: P-Private Industry

Communication Date: 2022-04-25

Communication Type: Official Correspondence

Communication Contents: We note that you are implementing our recommendation by revising your Operations and Maintenance Procedure (No. 3000) within your Damage Prevention Program to contain a specific section on damage prevention for marine dredging, including guidance to establish a larger tolerance zone during dredging operations. We further note that you anticipate completing your work soon. Accordingly, Safety Recommendation P-21-21 is classified OPEN-- ACCEPTABLE RESPONSE.