NTSB Safety Recommendation P-96-021

NTSB safety recommendation P-96-021.

THE NTSB RECOMMENDS THAT THE RSPA: REQUIRE OPERATOR OF LIQUID PIPELINES TO ADDRESS, IN THEIR OIL PULLUTION ACT OF 1990 SPILL RESPONSE PLANS, IDENTIFYING & RESPONDING TO EVENTS THAT CAN POSE A SUBSTANTIAL THREAT OF A WORST-CASE PRODUCT RELEALSE.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1996-09-11

Adopted Date: 1996-09-06

Overall Date Closed: 1997-08-01

Synopsis: IN MID-OCTOBER 1994, SERIOUS FLOODING OCCURRED IN THE SAN JACINTO RIVER FLOOD PLAIN NEAR HOUSTON, TEXAS, FORCING OVER 14,000 PEOPLE TO EVACUATE & RESULTING IN 20 DEATHS. DUE EO THE FLOODING, EIGHT PIPELINES RUPTURED & MANY OTHERS WERE UNDERMINED. MORE THAN 35,000 BARRELS OF PETROLEUM & PETROLEUM PRODUCTS WERE RELEASED INTO THE RIVER. IGNITION OF THE RELEASED PRODUCTS RESULTED IN 547 PEOPLE RECEIVING (MOSTLY MINOR) BURN & INHALATION INJURIES. SPILL RESPONSE COSTS EXCEED $7 MILLION, & ESTIMATED PROPERTY DAMAGE LOSSES WERE ABOUT $16 MILLION.

Probable Cause: None

Ntsbnumber: DCA95MP002

Report Number: SIR-96-04

Addressee Name: RSPA

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 1997-08-01

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1997-08-01

Communication Type: Official Correspondence

Communication Contents: THE BOARD DETERMINED THAT PIPELINE OPERATORS WOULD MORE LIKELY HAVE IMPLEMENTED EARLY SHUTDOWN ON PURGING OF PRODUCTS FROM PIPE SEGMENTS CROSSING THE SAN JACINTO FLOOD PLAIN HAD RSPA REQUIRED THEM TO DEVELOP PLANS FOR RESPONDING TO SUBSTANTIAL THREATS OF A PIPELINE FAILURE & PRODUCT DISCHARGE. EXMAMINATION OF THOSE OPERATORS WHOSE PIPELINES FAILED DURING THE 1994 SAN JACINTO FLOOD REVEALED THAT ALL BUT ONE HAD CONDITIONED THE IMPLEMENTATION OF RESPONSE ACTIONS OR BEING MADE AWARE OF AN ACTUAL RELEASE OF PRODUCT FROM ITS PIPELINE. THE BOARD NOTED IN IT SPECIAL INVESTIGATION THAT SPILL PREVENTION REQUIREMENTS WERE NOT ADDRESSED IN APPENDIX A TO 49 CFR PART 194, "GUIDELINES FOR THE PREPARATION OF RESPONSE PLANS." YET RSPA USED THIS APPENDIX AS THE BASIS FOR REVIEWING MOST OF THE RESPONSE PLANS FOR ONSHORE OIL PIPELINES. CONSEQUENTLY, RSPA DID NOT RECOGNIZE THAT ONSHORE PIPELINE OPERATOR PLANS OMITTED PROVISIONS ON RESPONDING TO SUBSTANTIAL THREATS OF DISCHARGE THAT ARE REQUIRED UNDER THE OIL POLLUTION ACT OF 1990 (OPA 90). RSPA STAFF HAVE ACKNOWLEDGED THIS OVERSIGHT & INDICATED THAT RSPA WILL HENCFORTH REQUIRE THAT OPERATORS REVISE THEIR OPA 90 RESPONSE PLANS TO ENSURE THAT PROPER PRECAUTIONS ARE TAKEN IN RESPONSE TO "SUBSTANTIAL THREATS" BEFORE A SPILL OCCURS. THE BOARD RECOGNIZES THAT ON 1/24/97, RSPA ISSUED A PIPELINE SAFETY ALERT NOTICE, ALN-97-01, TO ALL PLAN HOLDERS, REMINDING THEM OF THE IMPORTANCE OF BEING PREPARED TO RESPOND TO A SUBSTANTIAL THREAT OF WORST-CASE DISCHARGE, EVEN IN THE ABSENCE OF AN ACTUAL RELEASE. ON 1/29/97, RSPA INCLUDED ALN-97-01 ON ITS PUBLIC HEARING AGENDA IN NEW ORLEANS, LOUISIANA, TO SOLICIT INDUSTRY COMMENTS. THE BOARD ALSO NOTES THAT THE LATEST REVISION TO THE NATIONAL RESPONSE TEAM'S INTEGRATED CONTINGENCY PLAN (ICP) GUIDANCE, WHICH RSPA HELPED PREPARE, CONTAIN SPILL PREVENTION GUIDANCE THAT CORRESPONDS MORE CLOSELY TO STANDARD OPERATING PRACTICES & INDUSTRY EXPERIENCE. THE BOARD UNDERSTANDS THAT THESE GUIDELINES MAY BE ADOPTED BY OPERATORS WHO FAVOR HAVING JUST ONE CONTINGENCY PLAN FOR ALL THEIR FACILITES, INCLUDING TRANSPORTATION PIPELINES, MARINE TERMINALS, & TANK FARMS. IF WIDELY ADOPTED, THE ICP CONCEPT WOULD GREATLY FACILITATE RSPA'S PLAN REVIEW & MODIFICATION EFFORTS IN 1998. THE BOARD WELCOMES RSPA'S ASSURANCE THAT FUTURE GUIDANCE UNDER APPENDIX A WILL MEET OPA 90 REQUIREMENTS & RECOGNIZES RSPA'S COMMITMENT TO REQUIRE REVISIONS TO EXISTING PLANS & PLAN COMPLIANCE IN THE FUTURE. BASED ON THIS INFO P-96-21 IS CLASSIFIED "CLOSED--ACCEPTABALE ACTION." TO HELP THE BOARD KEEP CURRENT CONCERNING DEVELOPMENTS AFFECTING THIS IMPORTANT SAFETY ISSUE, WE WOULD APPRECIATE RECEIVING AS SOON AS POSSIBLE, ANY GUIDANCE OR CHECKLIST RSPA PLANS TO USE IN CONDUCTING ITS 1998 REVIEW OF PIPELINE OPERATOR PLANS.

Addressee Acronym: RSPA

Addressee Organization Type: G-Federal Government

Communication Date: 1997-03-17

Communication Type: Official Correspondence

Communication Contents: DR. SCHARMA ADVISED THAT RSPA HAS ISSUED ON 1/24/97 A PIPELINE SAFETY ALERT NOTICE, ALN-97-01. THE NOTICE REQUIRES ONSHORE OIL OPERATORS TO REEVALUATE THEIR OPA 90 SPILL RESPONSE PLANS WITH RESPECT TO THE 49 CFR 195 & 194 REQUIREMENTS. IN ADDITION TO THE ALERT NOTICE, RSPA HAS TAKEN SEVERAL NON-REGULATORY INITIATIVES. THESE INITIATIVES INCLUDE: 1) HOLDING A PUBLIC MEETING ON OPS OPA 90 PROGRAM; 2) IMPLEMENTING LESSONS LEARNED FROM A JOINT RSPA-USCG INCIDENT REPORT; 3) COMPLETING TWO TECHNICAL STUDIES THAT ADDRESS PIPELINE RISK FACTORS FROM NATURAL DISASTERS; & 4) DEVELOPING NATIONAL PIPELINE MAPPING SYSTEM.