NTSB Safety Recommendation P-80-003

NTSB safety recommendation P-80-003.

THE NTSB RECOMMENDS THAT THE CITIES SERVICE PIPE LINE COMPANY: DETERMINE THE DEPTH OF PIPE AT ALL CROSSINGS WHERE DITCH-CLEANING AND ROAD-GRADING ACTIVITIES MAY RESULT IN DAMAGE TO THE PIPELINES, AND TAKE NECESSARY ACTION TO PREVENT SUCH DAMAGE.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1980-02-26

Adopted Date: 1980-02-15

Overall Date Closed: 2001-11-26

Synopsis: ON AUGUST 20, 1979, A BULLDOZER OPERATED BY THE ORANGE COUNTY DRAINAGE DISTRICT, ORANGE, TEXAS, BEGAN TO CLEAN A FARM DRAINAGE DITCH WITH A GENERALLY NORTH-SOUTH ALIGNMENT. AFTER MAKING SEVERAL PASSES ACROSS THE DITCH, THE OPERATOR HEADED THE BULLDOZER SOUTH ALONG THE LENGTH OF THE DITCH. AT 2:15 P.M. THE CORNER OF THE BLADE CUT INTO A PROPANE LINE, OWNED BY THE CITIES SERVICE PIPE LINE COMPANY, WHICH CROSSED BENEATH THE DITCH IN AN EAST-WEST DIRECTION. PROPANE AT 350 PSIG ESCAPED AND WAS IGNITED WITHIN SECONDS. THE RESULTING FIRE KILLED ONE PERSON AND INJURED ANOTHER, AND CAUSED CONSIDERABLE PROPERTY DAMAGE.

Ntsbnumber: FTW79FP014

Report Number: None

Addressee Name: Cities Service Pipeline Company

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2001-11-26

Addressee Organization Type: P-Private Industry

Communication Date: 2000-09-26

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 10/06/2000 1:34:52 PM MC# 2001496 In 1983, Cities Service Company sold its refining, marketing and transportation operations, then known as Citgo Petroleum Corporation (Citgo), to The Southland Corporation (Southland). In 1983, the Cities Service Company contracted with Citgo Pipe Line Company (formerly Cities Service Pipe Line Company) to operate the 12" pipeline when that Citgo entity was sold to Southland as a part of the above referenced sale of Cities Service's refining, marketing and transportation operations. Subsequently, the NGL Pipeline Entity underwent several name changes as well as ownership changes, is now Dynegy NGL, Inc., but it has continued since 1991 to be the sole owner of the NGL Pipeline Entity. Based on the above, I have attempted to locate records dealing with the 12" pipe line after the 1979 pipe line break, no information has been located relating to P-80-3 and P-80-4 other than the information contained in the November 23, 1982 letter from H. R. Slack of Cities Service Pipe Line Company attached to your July 14, 2000 letter. This record search has been conducted of the Cities Service Company records, the Citgo Petroleum Corporation records, and the Trident/Dynegy records. As such, I cannot provide you with any information on behalf of Occidental Petroleum Corporation and, therefore, I have no information relating to any further response to Safety Recommendation P-80-3 or P-80-4.

Addressee Organization Type: P-Private Industry

Communication Date: 2001-03-19

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 03/26/2001 6:21:40 PM MC# 2010247: This will acknowledge receipt of your January 30,200l letter directed to Mr. Ray Irani of Occidental Petroleum Corporation which was in response to my September 26,200O letter directed to Mr. Barry M. Sweedler in connection with the above-referenced Safety Recommendation, I attempted to contact you by phone on March 16,200l and was advised that you would be unavailable, and it was suggested that I contact Mr. Bob Chipkevich of the Pipeline and Hazardous Safety Office. I was unable to reach Mr. Chipkevich and left a voice-mail message for him to contact me at the number listed below. I assume you will coordinate my efforts with Mr. Chipkevich and either you or Mr. Chipkevich will contact me or will make arrangements for someone on the National Transportation Safety Board to contact me at the below address and telephone number.

Addressee Organization Type: P-Private Industry

Communication Date: 2001-08-27

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 09/05/2001 7:30:07 PM MC# 2010713 P-80-3 pertains to a twelve inch (12") natural gas liquids pipeline currently owned by Dynegy NGL Pipeline Company, L.L.C. which is utilized to transport natural gas liquids between Mont Belvieu, Texas and Lake Charles, Louisiana (the "Pipeline"). Cities Service Pipe Line Company ("Cities Service") operated this 12 inch Pipeline at the time the explosion and fire referenced in the Safety Recommendation occurred (August 20, 1979). Through a series of divestitures and mergers, Dynegy Midstream Services, Limited Partnership now operates the subject Pipeline for the current owner, Dynegy NGL Pipeline Company, L.L.C. While we are not aware of the actions taken by Cities Service subsequent to the issuance of the Safety Recommendation, we are aware that (i) since 1991 over seven million dollars ($7,000,000) has been spent on improvements to the subject pipeline and (ii) improvements to this Pipeline are continuing to be made, as warranted. A list of these improvements and certain facts and actions that have been undertaken are listed below: ·The Lake Charles to Sour Lake portion of the pipeline was hydrostatic tested in 1994 to ensure integrity of the pipeline and to establish the current Maximum Operating Pressure of 730 psig. The length of pipeline that was tested includes the location of the 1979 incident. The new pipeline integrity rule will require re-testing or smart-pigging this pipeline every five years. We intend to fully comply with this requirement and take whatever actions are necessary to ensure the integrity of the pipeline. ·Portions of the pipeline were lowered during the period 1989 through 2000, with the majority of this work being done between 1992 and 1999. The lowering of the pipeline included the location of the 1979 incident. Most of these lowerings were done to provide a minimum coverage of three feet, if not in a residential area, and deeper where possible if in a residential area. With respect to any areas that may be tilled, the minimum coverage was below tillage depth. ·All overhead canal crossings except for three were removed due to their deteriorated conditions and replaced with bored canal crossings. The three remaining overhead canal crossings are in good condition. We continue to monitor the three remaining overhead canal crossings annually, every fall when the ROW is mowed, to ensure their continued integrity. ·In September 1994, a section of the pipeline located immediately east of the Sabine River was replaced/lowered to avoid the pipeline from being struck by small boat traffic. ·All navigable river crossings are surveyed for adequate depth of cover according to the frequency required by Department of Transportation (DOT) regulations. ·The number of isolating block valves has been increased from five to fifteen. The block valves have been installed and are in the process of being automated for remote operations. ·Two instrumented internal inspections (smart-pig runs) were made in 1988 and 1999. Both internal and external corrosion was found. There was internal corrosion on small portions of the pipeline situated in low areas. Only one internal corrosion location required replacement. An additional area was found to have external corrosion due to a shorted road crossing casing. As a result, the area with external corrosion exceeding calculated limits were excavated and were either repaired with full encirclement steel sleeves welded to the pipeline or replaced with new steel pipe. ·Dynegy participates in and strongly supports both the Louisiana "One-call" system, covering that portion of the Pipeline situated in Louisiana and two one-call organizations currently operating in Texas. ·Dynegy has an active damage prevention program which complies with the requirements of DOT Regulation 195.442. ·The pipeline, including operations, are periodically inspected by the Office of Pipeline Safety of DOT/RSPA. These improvements, taken as a whole, indicate that all of the NTSB recommendations have been followed and, in fact, additional actions have been taken to ensure the continued integrity of this Pipeline. Furthermore, both physical and operational improvements illustrate Dynegy's dedication and commitment to pipeline safety.

Addressee Organization Type: P-Private Industry

Communication Date: 1982-11-23

Communication Type: Official Correspondence

Communication Contents: CITIES SERVICE PIPE LINE (CSPL) COMPANY LTR: NTSB RECOMMENDED IN P-80-3 THAT CSPL DETERMINE THE DEPTH OF PIPE AT ALL CROSSINGS WHERE DITCH-CLEANING AND ROAD-GRADING MAY RESULT IN DAMAGE TO THE LINES AND TAKE NECESSARY ACTION TO PREVENT SUCH DAMAGE. WE ARE STILL IN THE PROCESS OF IDENTIFYING THE EXTENT OF THE PROBLEM, AND AFTER THE RESULTS ARE IN AND HAVE BEEN EVALUATED, CSPL WILL TAKE WHATEVER CORRECTIVE ACTION IS DEEMED APPROPRIATE.

Addressee Organization Type: P-Private Industry

Communication Date: 1983-01-27

Communication Type: Official Correspondence

Communication Contents: Your acceptance of our recommendation and your commitment to identify the extent of the problem is gratifying to the Board. We would appreciate being advised of the final results of your review and of any corrective actions which are related to our Safety Recommendation. We will hold the file for Safety Recommendation P-80-3 in an "Open--Acceptable Action" status pending such notification.

Addressee Organization Type: P-Private Industry

Communication Date: 2000-07-14

Communication Type: Official Correspondence

Communication Contents: ON 1/27/83, BASED ON INFORMATION IN THE CITIES SERVICE LETTER OF 11/23/82, P-80-3 WAS CLASSIFIED "OPEN--ACCEPTABLE RESPONSE." TO DATE THERE HAS BEEN NO FURTHER RESPONSE TO P-80-3. THE SAFETY BOARD UNDERSTANDS THAT IN DECEMBER 1982, CITIES SERVICE MERGED INTO OCCIDENTAL PETROLEUM CORPORATION (OCCIDENTAL). THE SAFETY BOARD WOULD APPRECIATE LEARNING WHAT ACTION OCCIDENTAL OR ITS PREDECESSOR, CITIES SERVICE, HAS TAKEN TO IMPLEMENT THIS RECOMMENDATION.

Addressee Organization Type: P-Private Industry

Communication Date: 2001-01-30

Communication Type: Official Correspondence

Communication Contents: The Safety Board understands that through a series of corporate mergers and sales, in 1982, the former Cities Service Pipe Line Company became a part of OXY Services, Inc., and now operates under the name of Dynegy NGL, Inc. In addition, Mr. Purser reported that he made a comprehensive search of all company archived records, noting that in 1991, extensive work was done by OXY USA and later by trident NGL, Inc., but he was unable to positively determine exactly what work had been completed. While the Safety Board appreciates Mr. Purser's efforts, we are still concerned about this issue. The Board maintains that the owner is responsible for taking action to determine the depth of pipe where ditch-cleaning and road-grading activities may result in damage to pipeline as well as taking necessary action to prevent such damage. Accordingly, in consideration of the over 20 years since the recommendation was issued and pending further response from Occidental Petroleum Corporation ensuring the recommended action has been completed, Safety Recommendation P-80-3 is classified "Open-Unacceptable Response."

Addressee Organization Type: P-Private Industry

Communication Date: 2001-04-25

Communication Type: Official Correspondence

Communication Contents: FROM STAFF DISCUSSIONS, THE SAFETY BOARD UNDERSTANDS THAT A CONSIDERABLE AMOUNT OF WORK WAS COMPLETED ON THE PIPELINE DURING THE PERIOD 1991-92. THE SAFETY BOARD WOULD APPRECIATE LEARNING WHETHER THIS WORK INCLUDED THE RECOMMENDED ACTION AND, IF NOT, WHAT OTHER ACTION DYNERGY OR ITS PREDECESSORS, CITIES SERVICE OR OCCIDENTAL, HAVE TAKEN TO IMPLEMENT THIS RECOMMENDATION.

Addressee Organization Type: P-Private Industry

Communication Date: 2001-11-26

Communication Type: Official Correspondence

Communication Contents: The Safety Board is aware that since the accident occurred, Cities Service Pipe Line Company (Cities Service) sold the pipeline and, through a series of divestitures and mergers, Dynergy Midstream Services, LP, now operates the pipeline for the current owner, Dynergy NGL Pipeline Company, L.L.C. (Dynergy). Further, while the actions taken by Cities Service subsequent to the accident may be unknown, the Board is pleased to note that Dynergy has invested over $7 million on improvements to the pipeline and that improvements continue to be made, as warranted. The Safety Board understands that the following is a summary of the improvements and other actions that have been undertaken by Dynergy: ·The Lake Charles to Sour Lake portion of the pipeline was hydrostatic tested in 1994 to ensure integrity of the pipeline and to establish the current maximum operating pressure of 730 psig. The length of pipeline that was tested includes the location of the 1979 incident. The new pipeline integrity rule will require re-testing or smart-pigging this pipeline every 5 years, which Dynergy intends to conduct. The company further intends to undertake whatever actions are necessary to ensure the integrity of the pipeline. ·Portions of the pipeline were lowered during the period 1989 through 2000, with the majority of this work being done between 1992 and 1999. The lowering of the pipeline included the location of the 1979 incident. Most of these lowerings were done to provide a minimum coverage of 3 feet, if not in a residential area, and deeper where possible if in a residential area. With respect to any areas that may be tilled, the minimum coverage was below tillage depth. ·All overhead canal crossings except for three were removed due to their deteriorated conditions and were replaced with bored canal crossings. The three remaining overhead canal crossings are in good condition. Dynergy continues to monitor the three remaining overhead canal crossings annually, every fall when the right-of-way is mowed, to ensure their continued integrity. ·In September 1994, a section of the pipeline located immediately east of the Sabine River was replaced and lowered to avoid the pipeline from being struck by small boat traffic. ·All navigable river crossings are surveyed for adequate depth of cover according to the frequency required by U.S. Department of Transportation (DOT) regulations. ·The number of isolating block valves has been increased from five to fifteen. The block valves have been installed and are in the process of being automated for remote operations. ·Two instrumented internal inspections (smart pig runs) were made in 1988 and 1999. Both internal and external corrosion was found. There was internal corrosion on small portions of the pipeline situated in low areas. Only one internal corrosion location required replacement. An additional area was found to have external corrosion due to a shorted road crossing casing. As a result, the area with external corrosion exceeding calculated limits were excavated and were either repaired with full encirclement steel sleeves welded to the pipeline or replaced with new steel pipe. ·Dynergy participates in and strongly supports both the Louisiana one-call system, covering that portion of the pipeline situated in Louisiana and two one-call organizations currently operating in Texas. ·Dynergy has an active damage prevention program that complies with the requirements of Title 49 Code of Federal Regulations 195.442. ·The pipeline, including operations, are periodically inspected by the DOT's Office of Pipeline Safety. The Safety Board agrees that these improvements, taken as a whole, indicate that actions have been taken on the subject pipeline that are responsive to the recommended action; consequently, Safety Recommendation P-80-3 is classified "Closed--Acceptable Action." The Safety Board appreciates Dynergy's commitment to pipeline safety.

Addressee Organization Type: P-Private Industry

Communication Date: 1982-10-08

Communication Type: Official Correspondence