{"operation":"document","citation":"CPF 520031003H","title":"WILLIAMS GAS CO — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2003-05-02","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520031003h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520031003h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520031003h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520031003H","body":"Corrective Action Order involving WILLIAMS GAS CO. The dataset does not identify a cited regulation for this case. The case was opened on 2003-05-02 and is reported as closed as of 2010-03-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520031003H.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520031003H/520031003H.pdf\n\n520031003HA.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520031003H/520031003HA.pdf\n\n520031003H_Amendment to CAO_12182003.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520031003H/520031003H_Amendment%20to%20CAO_12182003.pdf\n\n520031003h_amendment to cao_12182003_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520031003H/520031003h_amendment%20to%20cao_12182003_text.pdf\n\n520031003H_CAO_05022003.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520031003H/520031003H_CAO_05022003.pdf\n\n520031003h_cao_05022003_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520031003H/520031003h_cao_05022003_text.pdf\n\n520031003H_post-hearing decision on CAO amendment_04092004.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520031003H/520031003H_post-hearing%20decision%20on%20CAO%20amendment_04092004.pdf\n\n520031003H_post-hearing decision on CAO amendment_04092004.pdf\n\n?}\nU.SDeoortment\nof Tronsoortolion\nReseorch ond\nSpe€iol Prognoms Admanistrolion\n40o Seventh St S.W\nWashrngton. O C 20590\nAi,1\n,\" '.^,.\\ A\n.. .' ],+\nMr. Randy Bamard\nVice President of Operations\nWilliams Gas Pipeline - Northwest\n2800 Post Oak Boulevard\nMD-21\nHouston, TX 77056\nRe: CPFNo. 5-2003-1003-H\nDear Mr. Bamard:\nEnclosed is the Post Hearing Decision to the Amendment to the Corrective Action Order in\nthis case. The Post Hearing Decision includes a Second Amendment to the Corrective Action Order\nand proposes an additional amendment, The Second Amendment clarifies and modifies some of the\nprovisionsoftheDecemberl8,2003AmendmenttotheCorrectiveActionOrder. ThisPostHearing\nDecision also notifies you of a proposed amendment that would require you to take additional\ncorrective action involving your communication and liaison procedures with public officials and\nprovide progress reports on the work done under the order.\nService is being made by certified mail and facsimile. Your receipt constitutes service under\n49 C.F.R. $ 190.5. The terms and conditions of this Second Amendment to the Corrective Action\nOrder are effective upon receipt. You have the right to a hearing with respect to the proposed\nadditional amendment.\nSincerely,\nnf\\ v \\ 4(A^S^\n/\\a u\nH\", Revnolds\n6tl Pipeline iompliance Registry\n\\ Office of Pipeline Safety\nEnclosure\nVIA CERTIF'IED MAIL RETURN RECEIPT REOIJ]ESTED) AND TELECOPY\n\n\n\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nWASHINGTON. DC 20590\nIn the Matter of\nWilliams Gas Pipeline. Northwest,\nRespondent.\nCPF No.5-2003-1003-H\nPOST.HEARING DECISION --\nSECOND AMENDMENT TO TI{E CORRECTIVE ACTION ORDER\nAND PROPOSED FURTHER AMENDMENT\nPurpose and Background\nOn May 2, 2003, the Associate Administrator for Pipeline Safety issued a Corrective Action Order\n(May 2 Order) in this case, under authority of 49 U.S.C. $ 60112, finding that continued operation\nby Williams Gas Pipeline - Northwest (Respondent) of its 26-inch natural gas pipeline in westem\nWashington State would be hazardous to the public, property, and the environment without\ncorrective measures. The May 2 Order was issued as a result of the May |,2OO3 rupture of the line\nat mile post 1352.7 near Lake Tapps in Pierce County, Washington.\nOn December 13,2003, the line ruptured again. This time the failure occurred near Toledo, kwis\nCounty, Washington. On December 18, 2003, the Associate Administrator issued an Amendment\nto the Corrective Action Order (Amendment) to require additional corrective measures. By letter\nofDecember29,2003,Respondentrequesteda\"hearingandclarification\"andenumeratedsix items\nof the Amendment it intended to address.\nA hearing was conducted on lanuary 26, 2004 in the OPS offices in Lakewood, Colorado.\nRepresentatives of the Washington Utilities and Transportation Commission (WUTC), which\nparticipated in the investigation ofthe accidents as an interstate agent, participated in the hearing.\nIn addition to the six items enumerated in the response, Respondent raised issues and sought\nclarification with respect to other items of the Amendment. On February 9, Respondent filed its\npost-hearing submission.\nDiscussion of Items Raised by Respondent\nPressure restriction on Sumas to Mt Venton segrnent. Respondent noted that it had been unable to\ncomply with Item 1 of the Amendment on the Sumas to Snohomish portion of the line. Item 1\nrequired reduction of the line pressure to 100 psi by mid-January. By letter of January 12,2004,\nRespondent had requested additional time to achieve that pressure. Respondent contends that\n\n\n\nachieving the reduced pressure can only be done by venting a considerable amount of gas to the\natmosphere in the more populated area of the line. Respondent has been unable to reduce the\npressure on this segment below 100 psi and still operate the line. Respondent confirmed that this\npressure is less than 207o of the specified minimum yield strength of the pipe, a pressure at which\nit is highly unlikely to rupture. The line was subsequently depressurized for integrity testing.\nHowever, if retum to full service is delayed, there is a need to prescribe an acceptable interim\npressure. The Regional Director concurs that operation of this segment at pressures up to 200 psi\nwould not likely result in failure. Accordingly, paragraph a. below modifies Item 1 to grant relief.\nMetallurgical Analysis. Item 2 of the Amendment required Respondent to submit the original of the\nmetallurgical report to the Regional Director within one week of receipt. The Regional Director\nnoted that the goal was to ensure that OPS saw the original version of the metallurgical analysis and\nthat having thd laboratory mail the copy simultaneously with forwarding the report to Respondent\nwould achieve this. Respondent has now submitted a copy of the original report to the Regional\nDirector.\nIntegriQ management program. Respondent requested clarification with respect to Item 3 of the\nAmendment:\n3. Integrity management. Finalize an integrity management program that conforms to the\nrequirements for integrity management programs published on December 15, 2003 (new\nsubpart O to 49 C.F.R. Part 192) on an expedited basis. The program must address the\nfactors involved in the failures on the line that have occurred since 1990, including stress\ncorrosion cracking and land movement, as risks. Submit this program within 90 days of\nissuance of this Amendment for approval by the Director, Westem Region.\nSpecifically, Respondent noted the difficulty of developing a plan that will satisfy all of the detailed\nrequirements of the December 15 final rule prior to the development of the protocols and guidance\nthat OPS has indicated will be forthcoming. The Regional Director agreed that some of the details\nmay need to be filled in later, but noted that, based on a December 10,2003 meeting, Respondent\nhad already done a considerable amount of work in analyzing the risks on the lines subject to this\norder. It is not unreasonable to require Respondent to produce a first version of an integrity\nmanagement plan for the lines covered by this order on an expedited basis. At the hearing, the\nRegional Director agreed to review an eady draft and provide feedback on the adequacy of the plan\nto meet the requirements of the Amendment and the areas which Respondent may need to address\nin the future as it implements the integrity management program for its entire system. Respondent\ninformally submitted its draft on February 2,2004 andhas engaged in discussions with regional staff\nabout the scope. To allow these discussions to continue, the Regional Director extended time for\nsubmitting the program until April 18, 2004. Accordingly, paragraph b. below modifies item 3 of\nthe Amendment to again allow for a slight extension of time and to allow for future development\nof a complete integrity management program.\n\n\n\nPipe replacement. Item 4 of the Amendment requires Respondent to develop a prioritized plan to\nremove pipe that is subject to stress corrosion cracking from the 26-inch line if it intends to request\nremoval of the current pressure restrictions. The plan may allow for implementation to extend over\naten-year period. Although the term \"replacement\" is used, nothing in the Amendment requires\nRespondent to continue operating or to replace the line pipe with pipe of equivalent size.\nRespondent would satisfy the replacement requirement by constructing a new pipeline that meets\nfuture capacity needs and abandoning (in accordance with 49 C.F.R. $ 192.605) all or sections of the\ncuffent 26-inch line requiring replacement.\nAs an initial argument, Respondent challenges the need to replace pipe in the 26-inch line.\nRespondent argues that OPS lacks authority to order replacement with the information available to\nit. Respondent urges OPS to consider an approach that allows the line to continue in service\nindefinitely so long as it is managed through an integrity management program. Section 60112 of\nTitle 49, United States Code, expressly allows OPS to order \"suspended or restricted use of the\nfacility, . . ., replacement, or other appropriate action\" ifthe agency determines that the pipeline\nfacility at issue is or would be hazardous but for the corrective actions. As already noted,\nreplacement in this context does not require Respondent to replace with equivalent pipe, but does\nrequire that the hazardous pipe be removed from service. In this case, OPS has presented evidence\nof numerous SCC failures that have occurred on the line. There is evidence that the pipe is subject\nto several of the factors in SCC - nature of the coating, environmental conditions, and metallurgical\ntoughness of the pipe. The same toughness factors make the pipe prone to failure during land\nmovement, which is also a well-recognized risk in the area. Respondent has not challenged this\nevidence or the conclusion of OPS that corrective action is needed. The question comes down to the\nreasonableness of a requirement to remove pipe rather than to manage the risk of SCC and earth\nmovement through some other means,\nEvidence of pipeline failure due to land movement was detailed in the May 2 Order in this case. The\nfollowine indicates that SCC is a serious and pervasive problem on this line:\nThe metallurgical report on the 1992 SCC failure south of Snohomish indicated that there\nwas a family of deep cracks on the pipe examined. The report recommended periodic\nhydrostatic testing to identify and remove the SCC in the line.\nHydrostatic testing of a 4.8 mile segment of a l6-inch lateral in 1994 resulted in 22 SCC\nfailures.\nThe report on the 1999 Mt. Pleasant failure noted 21 othercracks in addition to the crackthat\ncaused the failure.\nThe report on the May L, 2003 SCC failure noted numerous other cracks due to SCC in the\npipe examined.\nThe report on the December 73,2003 SCC failure that underlies the Amendment also\nindicates that there are several other cracks due to SCC that had not failed in the pipe tested.\n\n\n\nThe Ulffascan crack detection done in 2003 revealed 38 SCC colonies in the three miles from\nSumner to White River. There have been 8 digs in this three-mile segment in which over a\nhundred anomalies have been noted. At least one of these was a crack with 100Vo\npenetration of the pipe and at least 10 had a depth of more than25Eo.\nAt the hearing, Respondent claimed that the transverse field inspection tool (TFI) can accurately\ndetect, and thus be used to manage, SCC in the26-inch line. Noel Duckworth, an expert in internal\ninspection technology, discussed the limitations of the TFI in locating SCC. In his opinion, the tool\ndoes not at this time reliably detect SCC sufficiently in advance of failure for it to be used for long-\nterm management. The limitations stem from the manner in which the tool measures anomalies,\nrather than from the quality of the analysis done of the inspection data. Although Respondent\npointed out that Mr. Duckworth's assessment was opinion, not fact, Respondent did not present\nevidence that supported a contrary view. OPS is left with the information before it. There is a\nhistory of SCC with two failures in the past year, the existence of several known parameters for\nSCC, an expert opinion that TFI will not detect SCC in time to prevent failure, and no countervailing\nevidence,\nRespondent indicates that a complete understanding of the SCC parameters at issue could allow an\nintegrity management program to eliminate the threat of SCC failures and that it should not be\nordered to replace the line until it can gain that complete understanding. It is not clear, however,\nwhen Respondent will have enough information to present such a case or whether technology will\nindeed provide sufficient certainty to manage the SCC on this line for an indefinite time.\nRespondent indicates that hydrotesting being done may provide data that would be helpful and that\nI-Jltrascan crack detection has been accurate. However, discussions at the hearing indicate that\nUltrascan cannot be used on the entire system because of the hilly terrain. In the meantime, OPS is\nfaced with the real risk of a future failure.\nThe Amendment does not require Respondent to replace line pipe if replacement is not necessary\nfor safety and is otherwise reasonable with respect to the replacement program. The terms of the\nAmendment expressly provide Respondent with the opportunity to present the case that a particular\nsegment is not subject to SCC and that replacement is not necessary (Items 4.v. and 6). As\nexamples, this showing could be evidence that, because of different construction, manufacturing\ntechniques, or pipe materials, a particular segment is not subject to SCC.\nTo the extent that extenuating circumstances mean that, despite all efforts, Respondent cannot make\na decision about replacement of the capacity within the 120 days cunently required for a replacement\nplan, the order allows for extensions of time for good cause. In addition, if the hydrotesting and\ntrials of the Ultrascan crack detection provide new unexpected and convincing data indicating that\nSCC can be managed on this line, Respondent may request OPS to amend the order with respect to\nthe replacement program. Accordingly, this Second Amendment does not change the requirements\nof Item 4 of the Amendment which addresses the current risks accordins to the current realitv.\n\n\n\nto seek removal from pressure restrictions for pipe in the replacement program. The basis is an\noManaging SCC until replacement. Item 5 of the Amendment provides a provision for Respondent\nadequate demonstration that SCC can be managed as a temporary measure through periodic\nhydrostatic testing or intemal inspection. Respondent has requested some modification of these\nprocedures.\nFirst, Respondent has asked that it be allowed to retum a segment to service after successful\ncompletion of a hydrostatic test but prior to the establishment of the interval for retesting.\nRespondent asks that it be allowed 90-120 days to establish this interval. This additional time will\nallow for better analysis of the test data, including analysis of any failures that occur. There is\nliterature available that provides guidance on appropriate retest intervals and it is appropriate that\nRespondent use this guidance to establish an interim interval prior to requesting permission to return\nto service. If this is done, allowing Respondent to adjust the retest interval within 90 days after\ncomplete analysis is reasonable. This provides assurance that there will always be an interval in\nplace for retesting. Paragraph c. below provides for this modification.\nSecond, Respondent has asked that the \"spike test\" be conducted for no more than 30 minutes rather\nthan for the t hour provided in Item 5. iii. and thatthe pressure of ll0%o of the specified minimum\nyield strength (SMYS) not be required for the entire segment. The Regional Director has agreed that\nthis is acceptable provided the entire segment be tested to a minimum of lOUVo SMYS with the\nweakest pipe, typically 0.28l-inch pipe, testing to LLOVo SMYS at some point in the test section.\nRespondent's post-hearingcomments assert that the Regional Directorhas indicated that only0.281-\ninch pipe need be tested. That assertion is incorrect and all pre-1970 pipe must be tested. Paragraph\nc. below provides for modification with respect to the terms of the \"spike test\".\nThird, Respondent has asked that, if intemal inspection using a combination of TFI and magnetic\nflux tools is used, it be allowed up to one year to address the anomalies after a retum to service.\nSome anomalies may require expedited repair, but a repair schedule that addresses the most critical\nfirst (prior to return to service) and allows additional time for noncritical repairs is acceptable.\nParagraph d. below provides for this modification.\nFinally, discussion at the hearing indicated public concern about safety when work is done on a\npipeline and Respondent's willingness to include provisions for a public safety procedure in the\nprotocol for hydrostatic testing. Based on continuing concern from local officials, OPS proposes,\nbelow, to further amend this corrective action order to provide for a public safety procedure for all\nactivities conducted under the order that could create the need for public safety decision-making by\nfederal, state, or local officials.\nEvaluation of other lines. Item 8 requires Respondent to evaluate certain other lines for\nsusceptibility to SCC and to report the findings and response to the Regional Director. Respondent\nhas sought clarification as to the requirement. Item 8 does not require Respondent to evaluate the\nother lines using hydrostatic testing or internal inspection, or indeed to select either in selecting the\no\n\n\n\nresponse to the evaluation. If, at some time in the future, OPS determines that either is needed, it\nmay further amend the order. No change to the Amendment is needed.\nModifications of the Required Corrective Action of the Amendment\nPursuant to 49 U.S.C. $ 60112, I hereby amend the corrective action of the December 18, 2003\nAmendment to the Corrective Action Order (Amendment) as follows:\nItem I of the Amendment (addressing pressure restrictions on the 26-inch line) is amended by\nadding the following language:\nff a reduced pressure of 100 psi cannot be maintained on the Sumas to Snohomish segment,\nRespondent may reduce the pressure and operate the line at a maximum pressure of 200 psi\nas needed to maintain a minimal line pack on the segment.\nb. Item 3 of the Amendment is modified to read as follows:\n3. Integrity management. Develop an integrity management program covering the lines\nsubject to this orderthat substantiallyconforms to the requirements forintegritymanagement\nprograms published on December 15,2003 (new subpart O to 49 C.F.R. Pafi 192) on an\nexpedited basis. The program must address the factors involved in the failures on the line\nthat have occurred since 1990, including stress corrosion cracking and land movement, as\nrisks. The program must include at least the following elements of an integrity management\nprogram: 49 C.F.R. $$ 192.911(a), (b), (c), (e), (f), (h), (i), 0), (l) and (m). Submit this\nprogram to the Director, Western Region by April 30,2004 for his approval.\nc. Item 5 iii. of the Amendment is modified to read:\niii. Successful completion of hydrostatic testing must include a \"spike test\"; that is, a test\nwith someportionofthesegmentexperiencingll0percentofthespecifiedminimumleld\nstrength of the weakest pipe in the test section for a period of 30 minutes and no segment\nexperiencing less than 100 percent, The spike test must be followed by a test at a minimum\nof 90 percent of the specified minimum yield strength for eight hours. Each failure must\nbe metallurgically tested to identify cause and failed pipe must be replaced with pretested\npipe.\nIn supporting the request for removal of the pressure restriction, Respondent may submit for\napproval an interim interval for reassessment of a pipe section based upon general guidance.\nRespondent must then provide a final interval for reassessment based upon additional analysis\nwithin 90 days of removal of the pressure restriction.\n\n\n\nd. The last bullet of Item 5. iv. of the Amendment is modified to read as follows:\n. Following written procedures approved by the Director, Western Region, that include\nfitness for service criteria for identifying, pri oitizing, and correcting defects within one year\nafter removal of the pressure restriction.\nThe terms and conditions of this Amendment are effective upon receipt. Failure to comply with this\nOrder may result in the administrative assessment of civil penalties of not more than $i00,000 per\nday and in referral to the Attomey General for appropriate relief in United States District Court.\nPronosed Further Amendment - Public Safety Procedures: Progress Reports\nSince I issued the Amendment to the Corrective Action Order, public safety officials have expressed\nconcern that an ineffective and uncoordinated flow of information from the Respondent about the\npipelines is hindering their ability to execute their public safety responsibilities and to protect\npersons in the vicinity of the pipeline. This proposed additional amendment proposes additional\ncorrective measures based on the following:\n. In meetings with the Associate Administrator for Pipeline Safety, public officials from Skagit,\nPuyallup and Bellevue, WA, and representatives of the WUTC expressed concern that more\ninformation from Respondent about the condition and ongoing operations ofthe subject pipeline\nwas necessary to avoid confusion, enhance coordination and better protect the citizens for whom\nthe officials are resoonsible.\nIn a meeting with the Associate Administrator for Pipeline Safety, the Fire Chief of Puyallup,\nWA expressed concern that more information from Respondent concerning its planned\noperating activities was necessary for the Fire Chief to effectively carry out his responsibilities.\nIn addition, corrective action orders with extensive measures require significant monitoring effort\non the part of OPS. Based on the experience thus far, OPS believes that periodic progress reports\nare necessary for effective monitoring.\nAccordingly, I propose to further amend this coffective action order by adding the following items:\n10. Identify actions or series of actions taken under this order that may require rapid decision-\nmaking by responsible authorities at the community level to protect the public safety such as\nthrough evacuations, road closings, or notifications of police, fire, or other emergency\nresponders (such actions would include, but are not limited to, line restarts, pressure testing,\npurging, and other significant excavation activities). Develop procedures for communicating\ntimely notice of such actions to federal, state, and local officials and for maintaining liaison to\ncoordinate pre-planned and actual response activities with the appropriate officials that provide\nfor appropriate notice to the public officials. Provide a copy of these procedures to the Director,\nWestem Region, within 30 days (of issuance of an amendment including this term).\n\n\n\n1L Provide Progress Reports on actions taken under this order on a monthly basis to the Director,\nWestern Region, that include at least the following information:\nNumber of miles of pipe hydrostatically tested, number of failures, and suspected causes\nwith updates based on results of the metallurgical testing.\nll.\n(For each type of nondestructive test performed) The number of miles tested, the number\nand nature of anomalies found, and the number and nature of repairs made.\nWithin 10 days of receipt of this proposed amendment, Respondent may request a hearing, to be held\nas soon as practicable, by notitlng the Associate Administrator for Pipeline Safety in writing,\ndelivered personally, by mail or by telecopy at (202) 366-4566. The hearing will be held in\nLakewood, Colorado or Washington, DC on a date that is mutually convenient to OPS and\nRespondent. Failwe to respond authorizes the Associate Administrator to issue an amendment\nconsistent with this notice.\nAPR - g 2m4\nDate Issued\nfor Pioeline Safetv\n\n520031003h_amendment to cao_12182003_text.pdf\n\nU5 Department\nor Tronsporiarion\ntaeaearch and\nSpeckN Aogrwna\nAglmlirlattcNon\nc0o ~enih si s w\nwaahegl0n D C 20590\nDEC 18 21lc3\nMr Randy Barnard\nVice President of Operations\nWilliams Gas Pipeline - Northwest\n2800 Post Oak Boulevard\nMD-21\nHouston, TX 77056\nRe CPF No. 5-2003-1003-H\nDear Mr. Barnard\nEnclosed is an Amendment to the Corrective Action Order issued by the Associate\nAdmmistrator for Pipeline Safety m the above-referenced case. It requires you to take additional\ncorrective actions with respect to your 26-inch line in Western Washington and to evaluate your 30-\ninch parallel line, the 26-inch line from the Washougal Compressor Station east to the Goldendale\nCompressor station, and all transmission lines from the Washougal Compressor Station south to\nGrants Pass, Oregon, for similar safety concerns. Service is being made by certified mail and\nfacsimile. Your receipt of this Amendment constitutes service of that document under 49 C F R\ng 190 5. The terms and conditions of this Amendment to the Corrective Action Order are effective\nupon receipt\nSmcerely,\nJames Reynolds\nPipehne Compliance Registry\nOnce of Pipeline Safety\nEnclosure\nVl. a C ED MAIL RETURN El RE STE ND ECOPY,\n\n\n\nDEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nWASHINGTON, DC 20590\nIn the Matter of\nWilliams Gas Pipeline - Northwest, Respondent.\n)\nCPF No. 5-2003-1003-H\nA ENDM TT CO ACTION ORDER\nPur ose and Back round\nOn May 2, 2003, the Associate Administrator for Pipeline Safety issued a Corrective Action Order\n(May 2 Order) in this case, under authority of 49 U S. C g 60112, finding that continued operation\nby Williams Gas Pipeline - Northwest (Respondent) of its 26-inch natural gas pipeline in v estern\nWashington State would be hazardous to the public, property, and the environment v ithout\ncorrective measures\nThe May 2 Order was issued as a result of the May 1, 2003 rupture of the linc at mile post 1352. 7\nnear Lake Tapps in Pierce County, Washington. The May 2 Order restricted operating pressure on\nthe linc and required Respondent to conduct a metallurgical analysis of the May 1, 2003 failure, to\nre-evaluate in-lme inspection surveys, to do a geotechnical evaluation of the area, and to take\nappropriate remedial action\nOn December 13, 2003, the hne ruptured again This time the failure occurred near Toledo, Lee is\nCounty, Washington\nPursuant to 49 U. S. C. ) 60117, thc Western Region, Office of Pipeline Safety (OPS) initiated an\ninvestigation of the incident, The Washington Utilities and Transportation Commission (WUTC),\nwhich, as an interstate agent, inspects the line for compliance with pipeline safety regulations, is\nparticipating in the investigation.\nAdditi nal Prelimina 'nd s\n~ On the morning of December 13, 2003, a rupture occurred on Respondent's 26-inch gas\ntransmission pipeline at Mile Post 128LS, approximately 7 miles south of the Chchalis\ncompressor station in Lewis County, Washington. AAer confirming that the pressure drop that\nhad been detected was indeed a failure, Respondent reported the failure to th«National\nResponse Center at approximately 11. 15 A. M. 1, \"ST.\n\n\n\nThe failure resulted in the release of gas for at least three hours. There was no ignition and no\nfatalities or tnJunes. The residents of 4 of the 12 homes in the vicinity evacuated voluntarily\nThe linc is located in primarily rural locations. Howcvcr, thc line is in close proximity to\npopulation where the line passes through the Seattle area, Whatcom County, as well as other\ncommunities. There were houses within 250 yards of the failure site as well as a road crossing\napproximately 30 feet away.\nThe maximum allowable operating pressure (MAOP) had been reduced by 20 percent by the\nMay 2 Order.\nVisual examination of the failed section revealed a dark stain at the edge of the rupture area\nwhich is indicative of corrosion. Field examination revealed signs of moisture beta een the\n1957 vintage tar coating and the pipe wall and indications of surface corrosion and pitting\nVisual examination also revealed significant longitudinal cracking of the pipe body that appears\nto be stress corrosion cracking (SCC)\nThe May 2 Order required a metallurgical analysis of the May I, 2003 failure The analysis,\nperformed by an independent laboratory, found that the cause was stress corrosion «racking\n(SCC). The May 2 Order also required a geotechnical evaluation This evaluation, performed\nby an independent consultant, indicated that land movement. originally thought to be a factor,\nwas not the cause.\nAccording to a November 1992 metallurgical report by an independent third party, the failure\nthat occurred on the line approximately 7 miles south of Snohomish during hydrotesting was\ncausedl by stress ~convsion . :. «. . ' in,\nAn Apnl 23, 1999 metallurgical report by an independent third party consultant indicated that\nstress corrosion cracking was involved in a leak that occurred near M. P. 1255 5 in March 1999\nIn addition to the failures on the line within the State of Washington, there were 22 fail wes duc\nto SCC expenenced dunng hydrostatic testing of a 16-inch lateral between June and August\n1994 between Mile Posts 21 and 26 near Oregon City, Oregon.\nOn October I, 2003, OPS issued an advisory bulletin to owners and operators of gas and\nhazardous liquid pipelines advising them to assess their pipelines for susceptibility to SCC Th«\nbulletin contains detailed instructions on identifying and addressing the SCC threat The\n0\nplay a role in SCC include the operating pressures, imposed loads placed on pipeline due to\nstress, the acidity of the soil, and coal tarcoating. These are factors found on this 26-inch line\n\n\n\n~ Respondent operates a 30-inch pipeline parallel to the 26-inch line that is the subject of the May\n2 Order This line is of newer construction and does not have the failure history of the 26-inch\nline However, it is subject to the same land movements and soil conditions, and has coal tar\ncoating\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, aAer reasonable notice and the opportunity for a hearing, requiring corrective action, which\nmay include the suspended or restricted use of a pipeline facihty, physical inspection, testing, repair,\nreplacement, or other action as appropnate The basis for making the determmation that a pipeline\nfacility is hazardous, requinng correct& ve action, is set forth both in the above referenced statute and\n49 C. F. R. )190. 233, a copy of which is enclosed.\nSection 60112, and the regulations promulgated thereunder, provide for the issuance of a Corrective\nAction Order without prior opportunity for notice and hearing upon a finding that failure to issue the\nOrder expeditiously will result in likely senous harm to life, property or the environment. In such\ncases, an opportunity for a hearing will be provided as soon as practicable aAer the issuance of the\nOrder\nAAcr evaluating the preliminary findings of fact, I continue to find that the operation of\nRespondent's 26-inch line between the Sumas station near the Canadian border and the Washougal\nstation near the Columbia River (Sumas-Washougal 26-inch line), without corrective measures\nwould be hazardous to life, property and the environment and that additional measures arc required\nAdditionally, aAer considering the age of the pipe, the population near the pipeline in western\nWashington state, the excessive land movements in the area, the prior history of the pipeline, the\nMay 1, 2003 accident attributed to stress corrosion cracking, the possibility that the December 13,\n2003 accident was also caused by stress corrosion cracking, and the fact that a second accident\noccurred under the reduced operating pressure, I find that a failure to expeditiously issue this\nAmendment, requiring immediate corrective action, would likely result in serious harm to life,\nproperty, and the environment.\nAccordingly, this Amendment mandating needed immediate correcti ve action is issued without prior\nnotice and opportunity for a heanng. The terms and conditions of this Amendment are efYectivc\nupon receipt.\nWithin 10 days of receipt of this Amendment, Respondent may request a hearing, to be held as soon\nas practicable, by notifying the Associate Administrator for Pipeline Safety in wnting, delivcrcd\npersonally, by mail or by telecopy at (202) 366-4566. The hearing will be held in Lakcwood,\nColorado or Washington, DC on a date that is mutually convenient to OPS and Respondent\n\n\n\nAfter receiving and analyzing additional data in the course of tlus investigation, OPS may identify\nother corrective measures that need to be taken. In that event, Respondent will be notifie of any\nadditional measures required and further amendment of the May 2 Order will be considered. To the,\nextent consistent with safety, Respondent will be afforded notice and an opportunity for a hearing\nprior to the imposition of any additional corrective measures.\nR ird\nPursuant to 49 U. S. C. $ 60112, I hereby order Respondent to immedtately take thc following\nadditional corrective actions\nWith respect to the Sumas-Washougal 26-iach Iiae:\nArlrhttonal pressure restnctton, Immediately reduce operating pressure on the line and alloi~\ndepletion of the product to achieve a reduced pressure of 100 psi withia 30 days of issuance\nof this Amendment. Once the reduced pressure of 100 psi has been achieved, the line may be\noperated at a maximum pressure of 110 psi as needed to maintain a minimal line pack on thc\nsystem.\n2. Metallurgical analysts. Conduct a detailed metallurgical analysis of the pipeline that failed nn\nDecember 13, 2003 to determine the cause of failure and contributing factors Submit an\norigmal copy of the report of this analysis to the Director, Western Region, OPS, within one\nweek of your receipt of the report,\n3. Integnti management. Finalize an integrity management program that conforms to the\nrequirements for integrity management programs published on December 15, 2003 (new subpart\n0 to 49 C. F. R. Part 192) on an expedited basis The program must address the factors involved\nin the failures on the line that have occurred since 1990, including stress corrosion cracking and\nland movement, as risks. Submit this program withia 90 days of issuance of this Amendment\nfor approval by the Director, Western Region\n4. Replacement program. Withia 120 days of issuance of tlus Amendment, develop a plan for\nreplacement of pipe in those segments for which Respondent intends io seek removal of\npressure restrictions as provided for in item 5 below, The plan must provide that\nA segment in a high consequence area, as defined in the natural gas integrity management\nrule published on December 15, 2003, which is to be replaced, must be replaced on a\npriority basis within three years of issuance of this Amendment.\nA segment in a class 2 area must be replaced within five years of the issuance of this\nAmendment.\n\n\n\niii. All other segments to be replaced must be replaced within ten years of issuance of this\nAmendment.\niv. To the extent that pressure restrictions have been liAed on a segment in accordance v ith\nitem 5, retesting prescribed in item 5 must contmue until replacement.\nv, Provided that there are no mdicationsof SCC, segments that contam pipe with well-bonded\ncoating and matenal toughness that meet standards for pipelines constructed aAer 1970 need\nnot be replaced.\n5 Removal of pressure restrictions. The Director, Western Region, may authonze removal of the\npressure restnctions m this corrective action order, as amended, upon request by Respondent\nSupport a request for removal of the pressure restrictions on a segment by demonstrating the\nfol lowmg.\nThe successful completion of either hydrostatic test or fraternal inspection of the segment\nin accordance with requirements provided below and the establishment of an approved\nretest interval for the segment that does not exceed 3 years; or\nn. There is evidence that the pipe in the segment is not prone to SCC, This mcludes evidence,\nthat the pipe has been replaced smce original construction with pipe meeting standards for\ntoughness and coating acceptable for pipeline constructed since 1970 and has not shown\nindications of SCC\niii. Successful completion of hydrostatic testing must include a \"spike test\", that is, a test\nconducted at 110 percent of the specified minimum yield strength of the weakest pipe in the\ntest section fora penod of 1 hour The spike test must be followed by a test at a minimum\nof 90 percent of the specified mimmum yield strength for eight hours. Each failure must\nbe metallurgically tested to identify cause and failed pipe must be replaced wi th pretested\npipe\niv. Successful completion of internal inspection must include:\n~ Use of a tool that is at least capable of reliably detecting SCC. Tool capability must\nbe validated. Validation is done through hydrostatic testmg of one statistically\nrepresentative section without failure during the test. This hydrostatic test is done aAcr\nthe tool has been run and all identified SCC anomalies in the section have been\naddressed.\n~ Direct evaluation and repair or replacement of any identified SCC that could fail before\nthe middle of the next test cycle.\n~ Follov mg wntten procedures approved by the Director, Western Region, that include\nfitness for service critena for identifying, pnontizing, and correcting defects\n\n\n\n6. Other exceptions from replacement. At any time, Respondent may present evidence that a\nsegment of pipe that this Amendment requires to be replaced is not susceptible to SCC and\nrequest that the Deputy Associate Administrator, OPS, grant an exception to replacement For\nexample, Respondent may present evidence that a segment has been both hydrostatically tested\nwithout failure due to SCC and internally inspected without identification of SCC' The decision\nof the Deputy Associate Administrator granting or denying the request must be in writing\n7, Advance no(ifica(ion of activities. Provide the Regional Director, Western Region, at least 5\nworking days advance notice of the schedules for any testing, inspection, excavation. repair, or\nreplacement done under the corrective action order, as amended. The purpose of this is to allov,\nthe Regional Director the opportumty to arrange for a Federal or State representative to witness\nthc activity.\nWith respect to the parallel 30-inch line within the State of Washington, the 26-inch line from\nthe Washougal Compressor Station east to the Goldendale Compressor Station, and all the\ntransmission lines from the Washongal Compressor Station south to Grants Pass, Oregon:\n8 Evaluate the lines for susceptibility to SCC based on data available and risk factors. Provide\na report to the Director, Western Region, within 180 days of issuance of this Amendment on\nthe findings and any programs Respondent is undertaking to address the findings\n9, Monthly Progress Reports on the status of the evaluations required in Item 8 must be submitted\nto the Director, Western Region.\nExcept for a request for a replacement exception (Item 6), the Director, Western Region, may extend\nthe time for the conduct of any item in this order, as amended Respondent may appeal any decision\nof the Director, Western Region, OPS, or of the Deputy Associate Administrator, OPS, to the\nAssociate Admimstrator for Pipelin","truncated":true,"body_characters":40319}