NTSB Safety Recommendation P-98-039

NTSB safety recommendation P-98-039.

THE NTSB RECOMMENDS THAT THE KOCH PIPELINE COMPANY, LP: ESTABLISH A PROCEDURE TO PROMPTLY EVALUATE ALL DATA RELATED TO PIPELINE CORROSION, SUCH AS ANNUAL CATHODIC PROTECTION SURVEYS, FIELD REPORTS, INTERNAL INSPECTION RESULTS, & COATING CONDITION DATA, TO DETERMINE WHETEHR THE PIPELINE'S CORROSION PROTECTION IS ADEQUATE, & TAKE NECESSARY CORRCTIVE ACTION.

Priority: CLASS II

Overall Status: Closed - Acceptable Action

Issued Date: 1998-11-18

Adopted Date: 1998-11-06

Overall Date Closed: 2000-04-06

Synopsis: ON SATURDAY, 8/24/96, ABOUT 3:26 P.M., AN 8-INCH-DIAMETER STEEL LPG (LIQUEFIED PETROLEUM GAS) PIPELINE TRANSPORTING LIQUID BUTANE, OPERATED BY KOCH PIPELINE COMPANY, LP (KOCH), RUPTURED NEAR LIVELY, TEXAS, SENDING A BUTANE VAPOR CLOUD INTO A SURROUNDING RESIDENTIAL AREA. THE BUTANE VAPOR IGNITED AS TWO AREA RESIDENTS IN A PICKUP TRUCK DROVE INTO THE VAPOR CLOUD. THE PEOPLE DIED AT THE ACCIDENT SITE FROM THERMAL INJURIES. ABOUT 25 FAMILIES WERE EVACUATED FROM THE AFFECTED AREA. KOCH ESTIMATED ITS DIRECT PIPELINE LOSSES, INCLUDING THE LOSS OF PRODUCT FROM THE LINE, TO BE ABOUT $217.000. OTHER PROPERTY LOSSES INCLUDED DAMAGE TO THE ROADWAY UNDER WHICH THE RUPTURE OCCURRED & DAMAGE TO A PICKUP TRUCK, A MOBILE HOME, SEVERAL OUTBUILDINGS, & ADJACENT WOODLANDS.

Probable Cause: The failure of Koch to adequately protect its pipeline from corrosion.

Ntsbnumber: DCA96FP007

Report Number: PAB-98-01

Addressee Name: Koch Pipeline Company, LP

Addressee Status: Closed - Acceptable Action

Addressee Date Closed: 2000-04-06

Addressee Acronym: KPL

Addressee Organization Type: P-Private Industry

Communication Date: 1999-06-29

Communication Type: Official Correspondence

Communication Contents: THE SAFETY BOARD IS PLEASED THAT KOCH HAS EVALUATED ALL PIPELINE DATA RELATED TO CORROSION ON THE STERLING I PIPELINE AND TAKEN CORRECTIVE ACTION. THE APRIL 9 LETTER REFERENCES KOCH OPERATIONS GROUP (KOG) STANDARD 1301.076 (THE STANDARD), SECTION 7.0, AS THE ITEM IN WHICH SUCH DATA MUST BE ADDRESSED BY A PLAN TO BE DEVELOPED WITHIN 30 DAYS. KOCH'S CORROSION ENGINEER IS APPARENTLY THE QUALIFIED PERSON RESPONSIBLE FOR ASSESSING THE LEVEL OF CATHODIC PROTECTION NEEDED TO MITIGATE PIPELINE CORROSION THAT IS AFFECTED BY ENVIRONMENTAL CONDITIONS. THOSE CONDITIONS, ACCORDING TO YOUR LETTER, WOULD INCLUDE MICROBIAL-INFLUENCED CORROSION (MIC) ON THE UNDERGROUND PIPELINE SYSTEM. HOWEVER, NEITHER THE KOCH HYDROCARBON DIVISION'S PROCEDURES NOR THE KOG STANDARD SPECIFICALLY STATE THAT THE CONDITIONS INCLUDE MIC, AND THE BOARD BELIEVES THAT THIS ISSUE, WHICH IS CRITICAL TO PUBLIC SAFETY, NEEDS TO BE DIRECTLY ADDRESSED. IN ADDITION, SECTION 2.1 OF THE STANDARD DOES NOT MANDATE A REVIEW OF ALL AVAILABLE CORROSION-RELATED DATA TO EVALUATE ADEQUATE CORROSION PROTECTION ON THE PIPELINE. YET, THIS SECTION OF THE STANDARD IS THE ONLY ONE THAT REFERENCES INTERNAL INSPECTION RESULTS. SECTION 2.1 STATES THAT THE IN-LINE INSPECTION TOOL CAN INDICATE EVIDENCE OF CORROSION, BUT IT DOES NOT REQUIRE THAT THE CORROSION ENGINEER ASSESS THE INSPECTION DATA TO EVALUATE THE STATUS OF CORROSION PROTECTION. FURTHER, THE HYDROCARBON DIVISION'S PROCEDURES DO NOT REQUIRE THE CORROSION ENGINEER TO EVALUATE THE DATA FROM FIELD REPORTS, INTERNAL INSPECTIONS, AND COATING CONDITION REPORTS, IN ADDITION TO THE CATHODIC PROTECTION SURVEYS, TO DETERMINE WHETHER THE ENTIRE PIPELINE'S CORROSION PROTECTION IS ADEQUATE. MOREOVER, THE SAFETY BOARD IS CONCERNED THAT SECTION 6.0 OF THE STANDARD REQUIRES THAT THE EXCAVATION INFORMATION BE DOCUMENTED AND RETAINED RATHER THAN FORWARDED TO THE CORROSION ENGINEER FOR REVIEW. ALSO, SECTION 6.2 DOES NOT REQUIRE A REVIEW OF THE COATING CONDITION REPORTS TO EVALUATE WHETHER THERE IS A PATTERN OF FAILURES AFFECTING CORROSION PROTECTION OF THE PIPELINE SYSTEM. THE BOARD BELIEVES THAT THE ABOVE ISSUES SHOULD BE ADDRESSED IN THE PROCEDURES AND STANDARDS THAT ARE AVAILABLE TO PIPELINE PERSONNEL THROUGHOUT THE COMPANY. THE BOARD RECOGNIZES THAT KOCH HAS MADE PROGRESS IN UPDATING ITS PROCEDURES AND STANDARDS TO PROVIDE ADEQUATE PROTECTION ON ITS PIPELINE SYSTEMS. WE ENCOURAGE KOCH TO COMPLETE ACTION IN THE AREAS DISCUSSED ABOVE. PENDING FURTHER RESPONSE FROM KOCH, P-98-39 IS CLASSIFIED "OPEN--ACCEPTABLE RESPONSE."

Addressee Acronym: KPL

Addressee Organization Type: P-Private Industry

Communication Date: 2000-04-06

Communication Type: Official Correspondence

Communication Contents: THE SAFETY BOARD HAS REVIEWED THE KOCH PIPELINE COMPANY LP (KOCH) STANDARD OPERATION OF CATHODIC PROTECTION ON COMPLETED PIPELINES AND IN COMPLETED FACILITIES AND FOUND THAT THE CONCERNS RAISED IN THE BOARD'S 6/29/99, LETTER HAVE BEEN ADDRESSED. ACCORDINGLY, BECAUSE KOCH HAS AMENDED THEIR PROCEDURES AS REQUESTED, P-98-39 HAS BEEN CLASSIFIED "CLOSED--ACCEPTABLE ACTION."

Addressee Acronym: KPL

Addressee Organization Type: P-Private Industry

Communication Date: 1999-04-09

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 4/12/99 4:56:04 PM MC# 990390 AS THE RESULT OF ITS OWN INTERNAL INVESTIGATION AND IN REPLY TO THIS RECOMMENDATION, KPLLP HAS ADOPTED THE FOLLOWING INTERNAL PROCEDURE: ATTACHMENT "A" IS GENERAL STANDARD 1301.076, OPERATION OF CATHODIC PROTECTION ON COMPLETED PIPELINES AND IN COMPLETED FACILITIES. AS A RESULT OF KNOWLEDGE GAINED BY THIS ACCIDENT, STANDARD 1301.076 HAS BEEN MODIFIED TO REFLECT, IN SECTION 7, A REQUIREMENT THAT DATA REFLECTING POSSIBLE INDADEQUATE CORROSION PROTECTION BE MADE IN A TIMEFRAME THAT ALLOWS A PLAN TO BE DEVISED BY THE APPROPRIATE PEOPLE WITHIN THIRTY (30) DAYS. KPLLP HAS ADOPTED THIS STANDARD FOR ALL HVL PIPELINES. INDIVIDUAL DIVISIONS ARE FREE TO ADOPT MORE STRINGENT STANDARDS IN THEIR PROCEDURE MANUAL BASED ON THEIR KNOWLEDGE OF CONDITIONS SURROUNDING INDIVIDUAL PIPELINES. AS A RESULT OF THIS ACCIDENT, THE HYDROCARBON DIVISION OF KPLLP, THE DIVISION THAT CONTROLS THE STERLING I PIPELINE, HAS BEEN UTILIZING A PROCESS THAT REQUIRES A MORE PROMPT REVIEW OF DATA RELATED TO PIPELINE CORROSION THAN IS REQUIRED BY GENERAL STANDARD 1301.076. THIS IS BECAUSE OF THE KNOWLEDGE THE COMPANY NOW POSSESSES RELATING TO THE RAPID RATE OF BACTERIAL CORROSION THAT LIKELY OCCURRED ON THE PIPELINE. THIS PROCESS IS NOW DOCUMENTED IN THE DIVISION'S PROCEDURE MANUAL. THE REVISED, EXCERPTED PORTION TO THIS MANUAL IS ATTACHED AS ATTACHMENT "B". IN ADDITION TO THESE PROCEDURE REVISIONS, KPLLP HAS, OF COURSE, ALSO PERFORMED A PHYSICAL EVALUATION OF THIS PIPELINE AND CONDUCTED SUBSEQUENT MAINTENANCE ON THE PIPELINE SINCE THE ACCIDENT. THIS WORK HAS BEEN IN COOPERATION WITH THE DEPT. OF TRANSPORTATION. THIS PROCESS IS OUTLINED IN CORRESPONDENCE OVER THE PAST TWO YEARS WITH DOT. KPLLP HOPES THE LESSONS LEARNED FROM THIS INCIDENT CAN BE SHARED WITH THE INDUSTRY IN GENERAL SO THAT NO SIMILAR INCIDENTS OCCUR ON OTHER PIPELINES OWNED AND OPERATED BY OPERATORS WHO ARE NOT FAMILIAR WITH THE EXTREMELY AGGRESSIVE CORROSION RATES ASSOCIATED WITH MIC.

Addressee Acronym: KPL

Addressee Organization Type: P-Private Industry

Communication Date: 2000-03-03

Communication Type: Official Correspondence

Communication Contents: Letter Mail Controlled 03/09/2000 3:38:22 PM MC# 2000373 RESPONDING TO YOUR LETTER OF 6/29/99, KOCH PIPELINE COMPANY, L.P. (KOCH PIPELINE) SUBMITS WITH THIS CORRESPONDENCE, ITS REVISED STANDARD 1301.076 ENTITLED "OPERATION OF CATHODIC PROTECTION ON COMPLETED PIPELINES AND IN COMPLETED FACILITIES." THIS STANDARD ESTABLISHES MINIMUM EXPECTATIONS REGARDING CATHODIC PROTECTION. ADDITIONAL REQUIREMENTS MAY BE DEFINED AS APPLICABLE IN THE OPERATIONS AND MAINTENANCE MANUAL, SPECIFIC TO THAT PIPELINE SYSTEM, BASED ON THE KNOWLEDGE OF CONDITIONS THAT SURROUND THE SPECIFIC PIPELINE. IN YOUR 6/29/99 CORRESPONDENCE, YOU RAISED SEVERAL ISSUES REGARDING THE ADEQUACY OF STANDARD 1301.076. WE BELIEVE THE MODIFICATIONS REFLECTED IN THIS VERSION OF THE STANDARD COVER YOUR AREAS OF CONCERN. I WILL HIGHLIGHT THE CHANGES BELOW. YOU RAISED A CONCERN THAT MICROBIOLOGICALLY INFLUENCED CORROSION (MIC) AND ITS RAMIFICATIONS WERE NOT ADDRESSED IN THE STANDARD. IN RESPONSE, WE MODIFIED SECTION 6.1 OF THE STANDARD TO REQUIRE, IF MIC IS SUSPECTED, APPROPRIATE TESTING CONDUCTED BY OR UNDER THE DIRECTION OF A "QUALIFIED PERSON" (AS THAT TERM IS DEFINED IN SECTION 1.2). YOU ALSO RAISED A CONCERN THAT SECTION 2.1 OF THE STANDARD DID NOT MANDATE A REVIEW OF ALL AVAILABLE CORROSION DATA TO EVALUATE ADEQUATE CORROSION PROTECTION ON THE PIPELINES. IN RESPONSE, WE MODIFIED SECTION 1.0 TO STATE, "IN ORDER TO EVALUATE THE ADEQUACY OF CATHODIC PROTECTION, A QUALIFIED PERSON SHALL REVIEW OR DIRECT THE REVIEW OF APPROPRIATE CATHODIC PROTECTION RELATED DATA." YOU NOTED A CONCERN THAT SECTION 6.0 OF THE STANDARD DID NOT REQUIRE FORWARDING OF EXCAVATION INFORMATION TO A "CORROSION ENGINEER FOR REVIEW." TO ADDRESS THIS CONCERN, WE HAVE MODIFIED THE STANDARD'S SECTION 6.0 TO REQUIRE THAT "APPROPRIATE DATA AND/OR DOCUMENTS WHICH INDICATE EVIDENCE OF CORROSION, COATING DEFECTS, OR LEVELS OF CATHODIC PROTECTION NOT MEETING THE ESTABLISHED CRITERIA, SHALL BE REVIEWED UNDER THE DIRECTION OF A 'QUALIFIED PERSON'." FINALLY, YOU RAISED A CONCERN THAT SECTION 6.2 OF THE STANDARD DID NOT REQUIRE A REVIEW OF THE COATING CONDITION REPORTS TO EVALUATE WHETHER THERE IS A PATTERN OF FAILURES AFFECTING CORROSION PROTECTION OF THE PIPELINE SYSTEM. WHILE WE DID NOT MODIFY SECTION 6.2 SPECIFICALLY, WE BELIEVE THE MODIFICATION WE MADE TO 6.0, WHICH REQUIRES A 'QUALIFIED PERSON' TO REVIEW EVIDENCE OF COATING DEFECTS, WILL ADDRESS THIS FINAL CONCERN. PLEASE BE ASSURED THAT KOCH PIPELINE IS COMMITTED TO PIPELINE SAFETY AND IS ALSO COMMITTED TO WORKING WITH THE SAFETY BOARD TO BE A LEADER IN THE INDUSTRY REGARDING PIPELINE OPERATIONS AND PIPELINE SAFETY. IF YOU HAVE ADDITIONAL QUESTIONS OR CONCERNS, PLEASE DO NOT HESITATE TO CONTACT ME. OTHERWISE, IF THE SAFETY BOARD HAS NO FURTHER CONCERNS REGARDING KOCH PIPELINE'S STANDARD 1301.076, I WOULD APPRECIATE A SHORT CORRESPONDENCE NOTING THAT FOR MY FILE.