On Sunday, July 25, 2010, at 5:58 p.m., eastern daylight time, a segment of a 30-inch-diameter pipeline (Line 6B), owned and operated by Enbridge Incorporated (Enbridge) ruptured in a wetland in Marshall, Michigan. The rupture occurred during the last stages of a planned shutdown and was not discovered or addressed for over 17 hours. During the time lapse, Enbridge twice pumped additional oil (81 percent of the total release) into Line 6B during two startups; the total release was estimated to be 843,444 gallons of crude oil. The oil saturated the surrounding wetlands and flowed into the Talmadge Creek and the Kalamazoo River. Local residents self-evacuated from their houses, and the environment was negatively affected. Cleanup efforts continue as of the adoption date of this report, with continuing costs exceeding $767 million. About 320 people reported symptoms consistent with crude oil exposure. No fatalities were reported.
The National Transportation Safety Board (NTSB) determines that the probable cause of the pipeline rupture was corrosion fatigue cracks that grew and coalesced from crack and corrosion defects under disbonded polyethylene tape coating, producing a substantial crude oil release that went undetected by the control center for over 17 hours. The rupture and prolonged release were made possible by pervasive organizational failures at Enbridge Incorporated (Enbridge) that included the following:
- Deficient integrity management procedures, which allowed well-documented crack defects in corroded areas to propagate until the pipeline failed.
- Inadequate training of control center personnel, which allowed the rupture to remain undetected for 17 hours and through two startups of the pipeline.
- Insufficient public awareness and education, which allowed the release to continue for nearly 14 hours after the first notification of an odor to local emergency response agencies.
Contributing to the accident was the Pipeline and Hazardous Materials Safety Administration's (PHMSA) weak regulation for assessing and repairing crack indications, as well as PHMSA's ineffective oversight of pipeline integrity management programs, control center procedures, and public awareness.
Contributing to the severity of the environmental consequences were (1) Enbridge's failure to identify and ensure the availability of well-trained emergency responders with sufficient response resources, (2) PHMSA's lack of regulatory guidance for pipeline facility response planning, and (3) PHMSA's limited oversight of pipeline emergency preparedness that led to the approval of a deficient facility response plan.
Safety issues identified during this accident investigation include the following:
- The inadequacy of Enbridge's integrity management program to accurately assess and remediate crack defects. Enbridge's crack management program relied on a single in-line inspection technology to identify and estimate crack sizes. Enbridge used the resulting inspection reports to perform engineering assessments without accounting for uncertainties associated with the data, tool, or interactions between cracks and corrosion. A 2005 Enbridge engineering assessment and the company's criteria for excavation and repair showed that six crack-like defects ranging in length from 9.3 to 51.6 inches were left in the pipeline, unrepaired, until the July 2010 rupture.
- The failure of Enbridge's control center staff to recognize abnormal conditions related to ruptures. Enbridge's leak detection and supervisory control and data acquisition systems generated alarms consistent with a ruptured pipeline on July 25 and July 26, 2010; however, the control center staff failed to recognize that the pipeline had ruptured until notified by an outside caller more than 17 hours later. During the July 25 shutdown, the control center staff attributed the alarms to the shutdown and interpreted them as indications of an incompletely filled pipeline (known as column separation). On July 26, the control center staff pumped additional oil into the rupture pipeline for about 1.5 hours during two startups. The control center staff received many more leak detection alarms and noted large differences between the amount of oil being pumped into the pipeline and the amount being delivered, but the staff continued to attribute these conditions to column separation. An Enbridge supervisor had granted the control center staff permission to start up the pipeline for a third time just before they were notified about the release.
- The inadequacy of Enbridge's facility response plan to ensure adequate training of the first responders and sufficient emergency response resources allocated to respond to a worst-case release. The first responders to the oil spill were four Enbridge employees from a local pipeline maintenance shop in Marshall, Michigan. Their efforts were focused downstream along the Talmadge Creek rather than near the immediate area of the rupture. The first responders neglected to use the culverts along the Talmadge Creek as underflow dams to minimize the spread of oil, and they deployed booms unsuitable for the fast-flowing waters. Further, the oil spill response contractors, identified in Enbridge's facility response plan, were unable to immediately deploy to the rupture site and were over 10 hours away.
- Inadequate regulatory requirements and oversight of crack defects in pipelines. Title 49 Code of Federal Regulations (CFR) 195.452(h) fails to provide clear requirements for performing an engineering assessment and remediation of crack-like defects on a pipeline. In the absence of prescriptive regulatory requirements, Enbridge applied its own methodology and margins of safety. Enbridge chose to use a lower margin of safety for cracks than for corrosion when assessing crack defects. PHMSA expects pipeline operators to excavate all crack features; however, PHMSA did not issue any findings about the methods used by Enbridge in previous inspections.
- Inadequate regulatory requirements for facility response plans under 49 CFR 194.115, which do not mandate the amount of resources or recovery capacity required for a worst-case discharge. In the absence of such requirements, Enbridge interpreted the level of oil response resources required under PHMSA's three-tier response time frame, resulting in a lack of adequate oil spill recovery equipment and resources in the early hours of the first response. By contrast, the U.S. Coast Guard (Coast Guard) and the U.S. Environmental Protection Agency (EPA) regulations specify effective daily response capability for each of the three tiers for oil spill response planning.
- PHMSA's inadequate review and approval of Enbridge's facility response plan that failed to verify that the plan content was accurate and timely for an estimated worst-case discharge of 1,111,152 gallons. PHMSA's facility response program oversaw 450 facility response plans with 1.5 full-time employees, which is a lower staffing commitment than comparable response plan review programs carried out by the EPA and the Coast Guard. PHMSA and other Federal agencies receive funding from the Oil Spill Liability Trust Fund to cover operational, personnel, enforcement, and other related program costs.