NTSB Safety Recommendation Letter P-90-034 through P-90-036

Page 1Official PDFNational Transportation Safety Board Washington, D.C. 20594 Safety Recornmenda tion ~ _ _ ~ Date: October 1 , 1990 I n reply r e f e r t o : P-90-34 through -36 Mr . Barry Wi 11 i amson Director Minerals Management Service Room 4210 Department of t h e I n t e r i o r 1849 C S t r e e t , N . W . Washington, DC 20240 On October 3, 1989, t h e United S t a t e s f i s h i n g vessel NORTHUMBERLAND s t r u c k and ruptured a 16-inch-diameter natural gas transmission pipe1 ine about 1/2 nautical mile offshore in t h e Gulf of Mexico, and about 5 1/3 nautical miles west of t h e j e t t i e s a t the entrance t o Sabine Pass, Texas. Natural gas under a pressure of 835 psig was released. An undetermined source on board t h e vessel ignited t h e gas, and w i t h i n seconds, t h e e n t i r e vessel was engulfed in flames. The f i r e on t h e vessel burned i t s e l f out on October 4. Leaking gas from the pipeline a l s o continued t o burn u n t i l October 4. O f t h e 14 crewmembers, 11 died as a r e s u l t of t h e accident.l When t h e accident occurred, the NORTHUMBERLAND was i n shallow waters and c l o s e t o shore, which was normal and usual f o r i t s t r a d e . The major c o n s t r a i n t t o t h e v e s s e l ' s operation in the area was i t s d r a f t . The water depth and t h e estimated d r a f t o f the vessel a t t h e time of t h e accident were both about 10 f e e t . Consequently, t h e bottom of t h e vessel was c l o s e t o the sea bottom o r s l i g h t l y penetrating the bottom when i t struck t h e pipeline. The pipeline was not f u l l y buried when i t was s t r u c k by t h e NORTHUMBERLAND. Diving surveys conducted a f t e r t h e accident established t h a t the unburied segments of t h e pipeline were not confined t o a l i m i t e d length, b u t extended f o r as much as 400 f e e t in t h e immediate accident area. The quantity and type of marine growth found on t h e p i p e l i n e indicated t h a t t h e pipeline had been unburied f o r a prolonged period. Damage t o t h e concrete coating a l s o indicated t h a t the pipeline had been previously s t r u c k by o t h e r vessels o r equipment towed by vessels. Additional information is given in the accident report. (National Transportation Safety Board. 1 9 9 0 . Fire on board the F / V NORTHUMBERLAND and rupture of a natural g a s transmission pipeline in the Gulf of Mexico near Sabine Pass, T e x a s , October 3, 1989. Pipetine Accident Report NTSB/PAR- 9 0 / 0 2 . Washington, DC.) 5208B#

Page 22 The U.S. Army Corps of Engineers ( t h e Corps) i s s u e s permits t o operators placing man-made o b j e c t s i n navigable waters t o prevent t h e obstruction of such wat.erways. Therefore, i n issuing i t s permit t o t h e owner and operator of t h e pipeline, t h e Corps required t h e pipeline t o be buried and maintained t o t h e burial depths shown on approved plans (about 9 f e e t be’low t h e seabed i n t h e case o f this p i p e l i n e ) . The NORTHUMBERLAND s t r u c k and ruptured the pipeline because t h e pipeline was not buried and maintained a t t h e burial depth required by t h e Corps’ permit. An offshore p,ipeline can be and often i s subject t o t h e j u r i s d i c t i o n of several Federal and S t a t e regulatory agencies. To i l l u s t r a t e , t h e p i p e l i n e involved i n t h i s accident was subject t o t h e j u r i s d i c t i o n of t h e Research and Special Programs Administration’s ( R S P A ) Office of Pipeline Safety (OPS) within t h e U.S. Department of Transportation (DOT), t h e Minerals Management Service (MMS) within t h e U.S. Department of t h e I n t e r i o r (DOI), t h e Corps, and t h e General Land Office o f Texas. The investigation of the N O R T H U M B E R L A N D accident revealed many d e f i c i e n c i e s in t h e Federal regulations f o r submerged pipelines. The regulations o r standards of t h e OPS, t,he MMS, and the Corps d i f f e r i n t h e i r a p p l i c a b i l i t y a n d scope. Pipelfnes a r e exempted from regulation by one agency b u t not another because of seemingly a r b i t r a r y f a c t o r s such a s minimum s t r e s s l e v e l , diameter, o r location o f a pipeline. For example, the OPS does not regulate hazardous l i q u i d pipelines t h a t operate a t a s t r e s s level of 20 percent or l e s s , while t.he MMS and t h e Corps do not have a s i m i l a r exclusion. The MMS requires the burial of pipelines g r e a t e r than 8 5/8 inches i n diameter, whereas t h e OPS requires t h e burial of hazardous l i q u i d and natural gas transmission pipelines w i t h o u t consideration of diameter. Further, DOT regulations, enforced by OPS, a l s o have grandfathering provisions that. exempt e x i s t i n g pipelines from may standards. As a r e s u l t of t h e inconsistent standards, exemptions, and grandfathering provisions among t h e d i f f e r e n t regulatory agencies, submerged pipelines may not be required t o be buried, protected, o r even regulated. To ensure t h a t a l l pipelines w i t h comparable hazards will be c o n s i s t e n t l y protected, RSPA (through OPS), t h e MMS, and t h e Corps c o l l e c t i v e l y need t o evaluate t h e a p p l i c a b i l i t y of their respective regulations and t o amend t h e i r regulations a s necessary t o provide uniform regulation o f submerged p i p e l i n e s . However, t h e Safety Board i s a l s o concerned about t h e possible number of submerged p i p e l i n e s t h a t have never been regulated, were never required t o buried and protected, and have never been regularly inspected. Although t h e number of reported incidents o f submerged p i p e l i n e s damaged by surface vessels i s small according t o t h e OPS ( 2 1 incidents s i n c e 1985), the l a r g e number of claims f i l e d under Louisiana‘s Fisherman’s Gear Compensation Fund (about 364 a year) suggest.s t h a t t.he danger from underwater obstructions, including p i p e l i n e s , i s g r e a t e r t h a n t h e OPS records suggest.. Because a l l submerged p i p e l i n e s a r e not subject t o the OPS o r o t h e r reporting requirements, and because t h e number, location, and owners of a l l submerged pipelines i n t h e Gulf o f Mexico are not known, t h e actual danger cannot be ascertained from t h e OPS incident reports alone. Consequently, t h e i#

Page 33 magnitude of the problem and the potential danger of submerged pipelines to surface vessels are unknown. Therefore, in Safety Recommendations P-90-4 to the DOT and P-90-1 to the DOI, issued on February 22, 1990, the Safety Board recommended that the Departments identify, with appropriate Gulf Coast States, the number, location, and owner of all offshore pipelines in the Gulf of Mexico. In a response dated May 30, 1990, the DOT cited a recently completed study conducted as part of the MMS' ongoing environmental studies program. The study includes the information specified in the recommendation for those pipelines previously documented by the MMS. The DOT also cited the records maintained under the Corps' permit program. The DOT further stated it is considering proposals to require pipel ine operators to maintain current maps and other information about t.heir pipelines that can be used to identify and locate .pipeline facilities. The DO1 responded that it was cooperating with the DOT through a DOT-sponsored task force that was organized as a result of the NORTHUMBERLAND accident. (The task force is discussed later in this letter.) The responses o f the DO1 and the DOT, however, did not completely meet the intent of the recommendations. The study and records cited in the DOT'S response identify known pipelines that were issued right-of-way permits. The Safety Board's primary concern, however, is for those pipel ines that were-- for whatever reason--never issued right-of-way permits or otherwise regulated. Until their number, location, and ownership are established, the potential danger to surface vessels remains unknown. The Safety Board urges both the DO1 and the DOT to renew their efforts to collect these data, and to utilize the resources of the States in the gulf region. However, because of the positive efforts taken, Safety Recommendations P-90-1 to the DO1 and - 4 t o the DOT are classified as "Open--Acceptable Response." The OPS, the MMS, and the C,orps have acknowledged the need to bury submerged pipelines to protect them from vessel operations. Yet, the MMS and the Corps were unable to cite the basis of their respective standards, whereas an OPS representative indicated that OPS standards were based on industry practices. The Safety Board believes that the appropriate burial depth to protect a submerged pipeline from damage depends on several factors, including the design of the pipel ine, the product transported, the operating pressures of the pipeline, characteristics of the sea bottom, subsidence and sedimentation rates, the depth of water, and the type and extent of vessel activity in the area. Without proper consideration of these factors, burial depths become arbitrary and ma,y not necessarily be effective in protecting the pipelines from damage. Because the OPS, the MMS, and the Corps cannot justify the basis for their standards, the Safety Board is concerned that each agency has adopted its standards without proper consideration of these factors.#

Page 44 Also, the burial standards of the OPS, the MMS, and the Corps establish the "natural bottom" or the "sea bottom" as the reference datum for burial depths. However, in areas of soft mud and silt, such as those found in much of the Gulf of Mexico, there may be several feet of mud and silt suspended in the water. Because the suspension of mud and silt does not provide effective support or cover for a pipeline, the reference datum must be located where the bottom sediment has sufficient consistency and compaction to support and cover a pipeline. The Safety Board believes that prescribed burial depths would provide a more consistent level of protection if the reference datum was based on a specified compaction of the bottom sediments. Both the OPS and the MMS have designated the requirements to bury and protect submerged pipelines as construction or installation standards that do not apply throughout the service life of the pipeline. The need to protect a pipeline from damage, however, does not diminish after the pipeline has been constructed. Consequently, the level of protection required throughout the service life of a pipeline should riot be less than that required at the time of construction. Because o f these deficiencies, DOT and DO1 regulations and the standards of the Corps do not provide a sufficient level o f safety. Consequently, the RSPA (through the OPS), the MMS, and the Corps should, collectively and under the leadership of the RSPA, develop and implement new standards for the burial and continued protection of submerged pipelines based on the potential risks to and from the pipeline. Requirements to bury and protect submerged pipelines from surface vessels will have little effect without proper inspection and surveillance programs. Over time, environmental effects and the activities of surface vessels in the near-shore or along embankment areas can lead to the loss of overburden over a submerged The pipeline that is offshore or under a river. pipeline therefore becomes more vulnerable to external damage and poses a greater danger to vessels that operate in the area. Because the OPS, the MMS, and the Corps do not explicitly require operators to conduct regular inspections of submerged pipelines, operators have not given adequate attention to potential dangers from unburied pipelines. Information revealed during the investigation suggests that some operators of submerged pipe1 ines have adopted a reactive posture from which they take action after an accident occurs rather than a proactive posture from which they would continuously search for and identify hazardous conditions. As a result of its concerns about deficiencies in the regulations and practices to protect and inspect submerged pipelines, the Safety Board, on February 22, 1990, issued Safety Recommendations P-90-5 to the DOT and P-90-2 to the DO1 recommending that the Departments determine effective methods of inspection, maintenance, and protection for offshore pipelines in shallow waters of the Gulf of Mexico. The DOT responded that a Federal task force, under the sponsorship of OPS, had been established in February 1990 to develop solutions to the hazards that may exist between offshore pipelines and fishing vessels in the Gulf of Mexico. Other participating agencies#

Page 55 included the MMS, the U.S. Coast Guard, the Corps, the National Oceanic and Atmospheric Administration, and the States of Texas and Louisiana. The OPS has indicated that by October 1, 1990, the task force will have completed a report on the long-term regu1ator.y and administrative projects to be initiated by each agency. The DO1 responded that it is cooperating with the DOT through the Federal task force. Since these two recommendations were issued, however, the Safety Board has become concerned that the safet,y problems with submerged pipel ines are not confined to the offshore areas of the Gulf of Mexico. A submerged pipeline under a river, shipping channel, or other body of water is also susceptible to being unburied and damaged or ruptured by a vessel. For example, on January 2, 1990, a submerged 12-inch pipeline transporting heating oil was ruptured in the Art,hur Kill channel between Staten Island, New York, and Linden, New Jersey. Evidence indicates that the pipeline was struck possibly by a passing ship or dredge. Although the Federal task force is addressing safety issues involving commercial fishing vessels and offshore pipelines in the Gulf of Mexico, the Safety Board now believes that the scope of the initial recommendations needs to be expanded to evaluate the level of safet,y that exists for all submerged pipelines located under navigable waterways. The evaluation should address the issues and problems noted concerning the practices of the both the fishing and pipeline industries, the jurisdiction over submerged pipelines, the deficiencies in regulatory standards for submerged pipelines, the inadequacy of enforcement and oversight., and the need for improved communication and coordination. Because the RSPA, through the OPS, is the primary Federal agency for pipeline safety, the Safety Board believes that the RSPA, with the assistance of the MMS, the Coast Guard, and the Corps, should build on the work of the current Federal task force and develop and implement effective methods and requirements to bury, protect, inspect the burial depth of, and maintain all submerged pipelines in areas subject t o damage by surface vessels and their operations. The Safety Board has therefore classified Safety Recommendations P-90-5 to the DOT and - 2 t o the DO1 as "Closed--Superseded" by Recommendations P-90-29 to the RSPA and -34 to the MMS. While the standards are being developed for the protection of submerged pipelines, measures are also needed to increase communication and coordination between and among government and industry groups. The Safety Board therefore believes that the MMS, the Coast Guard, and the Corps, should assist RSPA with the implementation of permanent measures to increase the coordination and communication between and among Federal and State regulatory agencies, and the pipeline, fishing, and marine industries. The pipel ine that was struck by the NORTHUMBERLAND transported natural gas from four offshore production pl atforms operated by four different owners. Natural Gas Pipeline Company of America (NGPL), owner of the pipeline, had to rely on the proper operation of the automatic shutdown systems on the four platforms to isolate the pipeline from offshore; therefore, it was imperative for the NGPL district superintendent to be able to contact each producer for confirmation that each platform had shut-in.#

Page 66 The district emergency plan, however, did not include a telephone number for the owner of one of the platforms, and company personnel did not attempt to find an emergency telephone number or to contact the owner of the platform. Because NGPL could not make contact and because of communications problems with another platform, the superintendent dispatched two employees by helicopter to confirm that all four platforms had shut-in. The failure of the district superintendent to have an emergency telephone number can be attributed to an absence of emergency planning and coordination between the pipel ine operators and the offshore producers. Because the operations of an offshore pipeline and platform are directly integrated, an emergency condition on one will necessarily affect the operation of the other. The failure to have a telephone contact and the communications problems may have been mitigated if the NGPL and the producers had previously planned and coordinated for emergency situations. Effective coordination requires that the pipel ine operator and the producer have current emergency contacts and agreement on their respective procedures in the event of an offshore emergency. The Safety Board is also concerned about the effectiveness of the emergency planning and coordination between pipel ine operators and offshore producers on an industry-wide basis. Because such emergency planning is not required under DOT or DO1 regulations, the Safety Board believes that the MMS should assist the RSPA in evaluating the need for greater emergency planning between offshore pipeline operators and producers, and then should implement, if necessary, appropriate safety regulations. Therefore, as a result of this accident, the National Transportation Safety Board recommends that the Minerals Management Service: Assist the Research and Special Programs Administration with the development and implementation of effective methods and requirements to bury, protect, inspect the burial depth of, and maintain all submerged pipelines in areas subject to damage by surface vessels and their operations. (Class 11, Priority Action) (P-90-34) Assist the Research and Special Programs Administration with the implementation of permanent measures to increase the coordination and communicat ion between and among Federal and State regulatory agencies, and the pipeline, fishing, and marine industries. (Class 11, Priority Action) (P-90-35) Assist the Research and Special Programs Administration with the evaluation of the need for emergency planning and coordination between offshore pipel ine operators and producers, and the implementation of appropriate safety regulations. (Class 111, Longer Term Action) (P-90-36)#

Page 77 Also as a result of its investigation, the Safety Board issued recommendations to the Zapata Haynie Corporation, Natural Gas Pipeline Company of America, U.S. Department of Transportation, Research and Special Programs Administration, U.S. Coast Guard, U.S. Department of the Interior, U.S. Army Corps of Engineers, National Oceanic and Atmospheric Administration, Interstate Natural Gas Association of America, American Gas Association, America Public Gas Association, American Petroleum Institute, National Fish Meal and Oil Association, Louisiana Shrimp Association, and National Council of Fishing Vessel Safety and Insurance. The National Transportation Safety Board i s an independent Federal agency with the statutory responsibility ' I . . .to promote transportation safety by conducting independent accident investigations and by formulating safety improvement recommendations" (Public Law 93-633). The Safety Board is vitally interested in any actions taken as a result of its safety recommendations and would appreciate a response from you regarding action taken or contemplated with respect to the recommendations in this letter. Please refer to Safety Recommendations P-90-34 through -36 in your reply. KOLSTAD, Chairman, COUGHLIN, Vice Chairman, LAUBER, BURNETT, and HART, Members, concurred in these recommendations. & Chairman Kol stad#