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Safety Recommendation Details

Safety Recommendation P-12-003
Details
Synopsis: On Sunday, July 25, 2010, about 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 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 benzene exposure. No fatalities were reported.
Recommendation: TO THE PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION: Revise Title 49 Code of Federal Regulations 195.452 to clearly state (1) when an engineering assessment of crack defects, including environmentally assisted cracks, must be performed; (2) the acceptable methods for performing these engineering assessments, including the assessment of cracks coinciding with corrosion with a safety factor that considers the uncertainties associated with sizing of crack defects; (3) criteria for determining when a probable crack defect in a pipeline segment must be excavated and time limits for completing those excavations; (4) pressure restriction limits for crack defects that are not excavated by the required date; and (5) acceptable methods for determining crack growth for any cracks allowed to remain in the pipe, including growth caused by fatigue, corrosion fatigue, or stress corrosion cracking as applicable.
Original recommendation transmittal letter: PDF
Overall Status: Open - Unacceptable Response
Mode: Pipeline
Location: Marshall, MI, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA10MP007
Accident Reports: Enbridge Incorporated Hazardous Liquid Pipeline Rupture and Release
Report #: PAR-12-01
Accident Date: 7/25/2010
Issue Date: 7/25/2012
Date Closed:
Addressee(s) and Addressee Status: PHMSA (Open - Unacceptable Response)
Keyword(s):

Safety Recommendation History
From: PHMSA
To: NTSB
Date: 4/1/2019
Response: -From Howard R. Elliott, Administrator: PHMSA requests the NTSB change the status of this recommendation to "Open-Acceptable Response." PHMSA's current requirements and planned actions will address the safety goal of this recommendation. PHMSA incorporated the following consensus standards by reference into the "Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Changes" final rule published on January 23, 2017: • In-line Inspection Systems Qualification Standard, August 2005 (API-1163); • In-line Inspection of Pipelines (National Association of Corrosion Engineers (NACE) Standard Practice SP0102-2010); • Stress Corrosion Cracking Direct Assessment (NACE Standard Practice SP0204-2008); and • In-line Inspection Personnel Qualification and Certification (American National Standards Institute and American Society for Non-Destructive Testing ILI-PQ-2010). Furthermore, PHMSA originally proposed certain repair criteria provisions in accordance with this NTSB recommendation in the NPRM titled "Pipeline Safety: Safety of Hazardous Liquid Pipelines." 4 PHMSA is planning to address repair criteria provisions in a separate rulemaking titled "Pipeline Safety: Repair Criteria for Hazardous Liquid Pipelines." This approach will allow PHMSA to further analyze developing technologies and practices, anomaly types, repair timeframes, and engineering critical assessment methods. This rulemaking will also address the issue of crack-like defects, including the engineering analyses for dents and cracks, in accordance with this recommendation. PHMSA is developing a timeline for completing the NPRM and anticipates that the publication date for the NPRM will be included in the spring regulatory agenda; PHMSA looks forward to the NTSB's comments.

From: NTSB
To: PHMSA
Date: 2/21/2018
Response: We note that, on October 13, 2015, you issued an NPRM, “Pipeline Safety: Safety of Hazardous Liquid Pipelines,” to incorporate, by reference, consensus standards governing physical condition assessments of in-service pipelines using in-line inspection (ILI), internal corrosion direct assessment, and stress corrosion cracking direct assessment. In our December 5, 2016, letter about this recommendation, we also noted that the changes proposed to requirements for scheduling crack defect remediation only address indications of significant stress corrosion cracking (SCC). We pointed out that the recommendation refers to all forms of crack defects, not just SCC. By only addressing crack indications identified as SCC colonies, the proposed regulation does not limit or otherwise describe requirements for remediating other types of crack indications, including the indication associated with the crack that led to the rupture in Marshall. We urged you to ensure that remediation requirements for all types of crack indications were included in the final rule. Pending resolution of this issue in the final rule, Safety Recommendation P 12 3 was classified “Open—Unacceptable Response.” We note from your current letter that in the final rule that was published on January 23, 2017, “Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Changes,” you incorporated by reference a number of consensus standards that you had previously proposed in a different NPRM, “Safety of On-Shore Hazardous Liquid Pipelines.” In addition, your work to satisfy Safety Recommendation P-09-2 (classified “Closed—Acceptable Action” in this letter) included developing crack and crack field evaluation software for seam cracks that enables evidence-based repair and replacement decisions. We also note that, based on comments that you received about the October 13, 2015, NPRM and from your liquid pipeline advisory committee, you are considering using an engineering assessment for crack defects. Finally, we note that the final rule based on your October 13, 2015, NPRM has been delayed because of the executive orders placing a moratorium on new regulations and requiring all pending regulations to be reviewed. Although we are pleased that you are considering further revisions to the final rule to address the issue we discussed in our December 5, 2016, letter, it would be premature to change the classification until after we have reviewed either the final rule or a supplemental NPRM. Pending resolution in the final rule as discussed, Safety Recommendation P-12-3 remains classified OPEN--UNACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 11/13/2017
Response: -From Howard R. Elliott, Administrator: PHMSA requests a status of "Open - Acceptable Response" or "Open -Acceptable Alternate Response." PHMSA's current requirements and intended actions forward are working to address the intent of this recommendation. PHMSA incorporated by reference the following consensus standards in the "Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Changes" final rule (82 FR 7972, https://www.federalregister.gov/documents/2017/01/23/2016-31461/pipeline-safetyoperator-qualification-cost-recovery-accident-and-incident-notification-and-other), published on January 23, 2017, instead of as part of the Safety of On-Shore Hazardous Liquid Pipelines rule: • API-1163, In-Line Inspection Systems Qualification Standard, August 2005; • NACE Standard Practice SP0102-2010, Inline Inspection of Pipelines; • NACE Standard Practice SP0204-2008, Stress Corrosion Cracking Direct Assessment; and • American National Standards Institute and American Society for Non-Destructive Testing, ILI-PQ-2010, In-Line Inspection Personnel Qualification and Certification). In addition, PHMSA's work towards NTSB Recommendation P-9-02 included the development of crack and crack field evaluation software for seam cracks that enables evidence-based repair and replacement decisions and includes management tools. This software is complete and available to operators. PHMSA notes NTSB' s concerns that requirements for scheduling crack defect remediation must address all forms of crack defects, not just significant stress corrosion cracking (SCC). PHMSA's current crack anomaly definitions are broad and cover crack types beyond SCC. In HCAs, operators must currently repair dents with any indication of cracking; crack-type and other anomalies with a specific calculated burst pressure compared to MOP; potential cracks that, when excavated, are determined to be cracks; and other crack-type anomalies that could impair the integrity of the pipeline. PHMSA's October 13, 2015, "Pipeline Safety: Safety of On-Shore Hazardous Liquid Pipelines" NPRM (80 FR 61609, https://www.federalregister.gov/documents/2015/10/13/2015-253 59/pipeline-safetysafety-of-hazardous-liguid-pipelines) proposed requirements for the specific identification and repair of SCC and selective seam weld corrosion (SSWC) cracks in both HCAs and non-HCAs. In addition, PHMSA proposed applying current crack repair requirements to non-HCAs. Further, based on the comments received on the NPRM and at the LP AC meeting, PHMSA is considering the use of an engineering assessment for crack defects. All of which PHMSA believes will meet the intent of this recommendation. The final rule was withdrawn from the Federal Register on January 23, 2017. Like many other issues before us, this is part of an ongoing regulatory review pursuant to the executive order issued by the President.

From: NTSB
To: PHMSA
Date: 12/5/2016
Response: We note that you agree with incorporating recently developed consensus standards to assure the better consistency, accuracy, and quality of pipeline assessments that are conducted using these techniques, and that, on October 13, 2015, you issued an NPRM, “Pipeline Safety: Safety of Hazardous Liquid Pipelines,” to incorporate, by reference, consensus standards governing physical-condition assessments of the in-service pipelines using in-line inspection (ILI), internal corrosion direct assessment, and stress-corrosion cracking direct assessment. However, we also note that changes to requirements for scheduling crack defect remediation only address indications of significant stress corrosion cracking (SCC). We point out that recommendation P-12-3 refers to all forms of crack defects, not just SCC. The crack that led to the rupture in Marshall, Michigan, was characterized as a “crack-like” feature (individual crack) rather than a “crack field” feature (crack colony). By addressing only crack indications identified as SCC colonies, the proposed regulation does not limit or otherwise describe requirements for remediating other types of crack indications, including the indication associated with the crack that led to the rupture in Marshall. We understand that you are reviewing comments and expect that a final rule will be published by the end of 2016. We urge you to ensure that remediation requirements for all types of crack indications are included in the final rule. Pending resolution of this issue in the final rule, Safety Recommendation P-12-3 is classified OPEN—UNACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 8/17/2016
Response: -From Marie Therese Dominguez, Administrator: PHMSA believes that incorporating recently developed consensus standards will assure better consistency, accuracy, and quality of pipeline assessments that are conducted using these techniques. To this end, on October 13, 2015, PHMSA proposed its NPRM titled "Pipeline Safety: Safety of On-Shore Hazardous Liquid Pipelines" to incorporate by reference consensus standards governing conduct of assessments of the physical condition of in-service pipelines using in-line inspection, internal corrosion direct assessment, and stress-corrosion cracking (SCC) direct assessment. Comments are being analyzed and a final rule is under Agency review. We anticipate publication by the end of 2016.

From: NTSB
To: PHMSA
Date: 8/18/2015
Response: Correspondence Control 201500682: The National Transportation Safety Board (NTSB) has reviewed the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) notice of proposed rulemaking (NPRM), Pipeline Safety: Operator Qualification, Cost Recovery, Accident and Incident Notification, and Other Pipeline Safety Proposed Changes, published on July 10, 2015. In this notice, PHMSA is proposing amendments to the pipeline safety regulations to address requirements of the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011 and update and clarify certain regulatory requirements. We also note that the proposed rulemaking addresses recommendations issued by the NTSB to PHMSA. We are pleased that PHMSA continues to improve pipeline transportation safety through its proposals and amendments. We offer the following comments on sections of the proposed rulemaking listed below that respond to NTSB safety recommendations or relate to matters for which we have basis to comment. Section VII. Pipeline Assessment Tools The NTSB offers the following comments to the Pipeline Assessment Tools section of the NPRM. To preface our technical comments, we note that in the discussion on 49 CFR § 195.452 the NPRM incorrectly refers to “Supervisory Control and Data Acquisition System (SCADA).” This should be replaced with “Stress Corrosion Cracking Direct Assessment (SCCDA).” The NPRM discusses the PHMSA response to an NTSB recommendation issued to PHMSA on July 25, 2012, that addresses piping crack defects and seam corrosion utilizing crack and circumferential tools. Revise Title 49 Code of Federal Regulations 195.452 to clearly state (1) when an engineering assessment of crack defects, including environmentally assisted cracks, must be performed; (2) the acceptable methods for performing these engineering assessments, including the assessment of cracks coinciding with corrosion with a safety factor that considers the uncertainties associated with sizing of crack defects; (3) criteria for determining when a probable crack defect in a pipeline segment must be excavated and time limits for completing those excavations; (4) pressure restriction limits for crack defects that are not excavated by the required date; and (5) acceptable methods for determining crack growth for any cracks allowed to remain in the pipe, including growth caused by fatigue, corrosion fatigue, or stress corrosion cracking as applicable. (P–12–3) PHMSA has identified specific proposed requirements for performing direct assessments on pipelines to evaluate the effects of external corrosion or stress corrosion cracking. They apply, in part, to items 2 and 3 of the recommendation. PHMSA notes that it will address the other elements of the recommendation in a separate rulemaking. The proposed provisions in this rulemaking address incorporating by reference into 49 CFR Part 195 certain consensus standards published by the American Petroleum Institute and the American Society for Non-Destructive Testing for using in-line inspection and using an SCCDA pipeline assessment tool. PHMSA is also addressing a petition from the National Association of Corrosion Engineers (NACE) to incorporate two new consensus industry standards. Finally, PHMSA proposes to allow the use of remotely-controlled or tethered tools not specifically addressed in the NACE standard with certain restrictions. The proposed changes are summarized below: 1 Incorporate by reference consensus standards for the integrity management of in-service hazardous liquids pipeline segments, specifically, the American Petroleum Institute Standard API-1163, In-Line Inspection Systems Qualification Standard, August 2005; NACE Standard Practice SP0102-2010, Inline Inspection of Pipelines; and NACE Standard Practice SP0204-2008, Stress Corrosion Cracking Direct Assessment. 2 Incorporate by reference the consensus standard developed by the American National Standards Institute and American Society for Non-Destructive Testing, ILI-PQ-2010, In-Line Inspection Personnel Qualification and Certification, for managing the qualification and certification of inline inspection personnel. 3 Approve the use of remotely-controlled or tethered tools for conducting pipeline integrity management assessments not explicitly discussed in the NACE Standard Practice SP0102-2010. Operators will be required to comply with the applicable sections of the NACE standard practice. 4 Propose changes in 49 CFR § 195.588 to require a written SCCDA implementation plan that includes reference to NACE standard practice SP0204 and additional factors that must be considered by the operator when conducting SCCDA. The NTSB agrees that incorporating by reference the industry consensus standards listed in Section VII of the NPRM will improve operator pipeline assessment consistency, accuracy, and quality. The NTSB also believes that requiring a written SCCDA plan to include the pre-assessment as outlined in the NACE standard practice RP0204 would provide owner/operators with valuable information and allow them to thoroughly assess vulnerabilities to stress corrosion cracking. Furthermore, the NTSB strongly feels that the proposed requirement that the piping assessment plan contain a “data gathering and integration” element addressing the four, listed factors will further improve the SCCDA process. The NTSB agrees that the NACE standard practice for conducting SCCDA combined with the written plan requirements are more comprehensive and rigorous than the current regulatory requirements.

From: NTSB
To: PHMSA
Date: 4/8/2015
Response: We are disappointed that you still have not issued the NPRM expected in 2013, Pipeline Safety: Safety of On-Shore Hazardous Liquid Pipelines; however, we are encouraged that you plan to issue the NPRM in 2015, and that it will address both these recommendations. We encourage you to expedite this action. Pending timely publication of a final rule that satisfies these recommendations, Safety Recommendations P 12-3 and -4 are classified OPEN—ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 1/22/2015
Response: -From Timothy P. Butters, Acting Administrator: PHMSA believes that incorporating recently developed consensus standards will assure better consistency, accuracy, and quality of pipeline assessments that are conducted using these techniques. To this end, PHMSA is developing an NPRM titled "Pipeline Safety: Safety of On-Shore Hazardous Liquid Pipelines." Among other things, the NPRM proposes to incorporate by reference consensus standards governing conduct of assessments of the physical condition of in-service pipelines using in-line inspection, internal corrosion direct assessment, and stress corrosion cracking (SCC) direct assessment. The NPRM is currently under review with the Office of Management and Budget, and our anticipated publication date is May 2015.

From: NTSB
To: PHMSA
Date: 1/3/2014
Response: We are encouraged that PHMSA’s pending NPRM, Pipeline Safety: Safety of On-Shore Hazardous Liquid Pipelines, addresses the issues specified in these two recommendations. Pending the publishing of a final rule as recommended, Safety Recommendations P-12-3 and -4 remain classified OPEN—ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 8/29/2013
Response: -From Cynthia L. Quarterman, Administrator: Currently, Part 195 Appendix C provides guidance to help pipeline operators implement liquid Integrity Management Program (IMP) requirements, including detection of pipeline stress corrosion cracking (SCC) and other crack-like features such as fatigue cracks, narrow axial corrosion, toe cracks, hook cracks, etc. Appendix C states that an operator must choose a minimum of two internal inspection tools, including one to detect cracks. Periodic assessment of the condition of gas transmission pipelines is required by 49 CFR sections 192.921 and 192.937. Periodic assessment of hazardous liquid pipelines is required by section 195.452. These sections allow use of the inspection techniques addressed in these standards. The regulations provide minimal requirements for the use of these techniques. PHMSA believes that incorporating recently developed consensus standards will assure better consistency, accuracy, and quality of pipeline assessments that are conducted using these techniques. To this end, PHMSA is developing an NPRM titled “Pipeline Safety: Safety of On-Shore Hazardous Liquid Pipelines.” The NPRM proposes to incorporate by reference consensus standards governing conduct of assessments of the physical condition of in-service pipelines using in-line inspection, internal corrosion direct assessment, and SCC direct assessment. The NPRM is expected to be published by the end of CY2013.

From: NTSB
To: PHMSA
Date: 1/11/2013
Response: The NTSB notes that PHMSA plans a rulemaking, Pipeline Safety: Standards for Conducting Condition Assessments of In-Service Pipelines, that may incorporate consensus standards to ensure better consistency, accuracy, and quality of pipeline assessments conducted to detect stress corrosion cracking (SCC) and to identify the appropriate tool for detecting anomalies, including crack defects. We further note that, in July 2012, PHMSA held a research and development forum at which participants discussed the need to study the effectiveness of crack detection tools for non-SCC anomalies. Although PHMSA’s actions to date constitute progress, in order to satisfy Safety Recommendation P-12-3, the final rule will need to address all five elements of this recommendation. In the meantime, pending completion of rulemaking, Safety Recommendation P-12-3 is classified OPEN—ACCEPTABLE RESPONSE.

From: PHMSA
To: NTSB
Date: 11/1/2012
Response: -From Cynthia Quarterman, Administrator: Currently, Part 195 Appendix C provides guidance to help a pipeline operator implement liquid Integrity Management Program (IMP) requirements including detection of pipeline stress corrosion cracking (SCC) and other crack-like features, such as fatigue cracks, narrow axial corrosion, toe cracks, hook cracks, etc. Appendix C states that an operator must choose a minimum of two internal inspection tools including one to detect cracks. A rulemaking entitled “Pipeline Safety: Standards for Conducting Condition Assessments of In-Service Pipelines” is under development. The final rule may incorporate consensus standards that assure better consistency, accuracy and quality of pipeline assessments that are conducted to detect SCC and to identify the appropriate tool for detecting anomalies including crack defects. Additionally, PHMSA recently held a research and development forum on July 18, 2012 in Washington, DC, which included a discussion of the need for a study of the effectiveness of crack detection tools for non-SCC anomalies. We believe this research study will provide the necessary recommendations concerning crack detection tools and crack defects that would be considered in any future PHMSA rulemaking.