U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA Western Region Overview
Tempe, AZ
August 20, 2014
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA Region Updates
• Relatively Quiet Year for Accidents but busy 2010-2012
• Total Switch to Integrated Inspection Process (II)
• Use the Integrated Inspection Assistant Tool (IA)
• Continued Construction Oversight of pipeline boom in
MT, WY and NE Colorado
• Aging Workforce and More Departures
• Focus was on:
– Lesson Learned from Near Misses and Accidents
– Jump on even smallest incidents hard and anticipate
questions, e.g. flooding, Bakken crude
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA Region Contacts & SMEs
•
Chris Hoidal – Director of Western Region
•
Bryn Karaus – Western Region Counsel
•
Huy Nguyen, Jeff Gilliam, Terry Larson– Supervisors
•
Peter Katchmar – Accident Coordinator
•
Ross Reineke – Construction Coordinator
•
Tom Finch and David Mulligan – Community Assistance and Technical
Services (CATS)
•
David Mulligan and Kim Nguyen - Inspection Assistant Power Users
•
Dustin Hubbard and Claude Allen - PDM and Mapping Issues
•
Jerry Kenerson – Safety Related Condition Follow-up
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PHMSA Regions
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Western Region Offices
Western Region Office –
16 Engineers
12300 West Dakota Avenue, Suite 110
Lakewood, CO 80228
720-963-3160
Satellite offices in:
Cheyenne, WY (Accident Investigator)
Billings, MT (1 engineer)
Reno, NV (1 engineer)
Ontario, CA (3 engineers)
Anchorage, AK (5 engineers)
One Regional Attorney – DC
Openings – One Engineer/Inspector
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Recap of Western Region
Priorities – (2010-2013)
– Continue to roll on more accidents, even low level ones
• Multiple Orders completed or finishing up.
– Construction Oversight of Bakken Field pipelines (Intense
public scrutiny due to commodity characteristics)
– Get Better at II, IA and tweak process – Better not great
– Finish CRMs and DIMP - COMPLETED
– Do more IMP validations in field (mandated by HQ)
• Moving to Next Level of IMP (Focus on Prevention
and Mitigation Measures)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Incidents Continue to Set Pipeline
Safety Agenda
Integrity Management Regulations prompted by:
Olympic Pipeline Rupture in Bellingham, WA (6/10/99)
El Paso Pipeline Explosion in Carlsbad, NM (8/19/00)
PG&E Pipeline Fire in San Bruno, CA (9/9/10)
SCADA/CRM, remote valves, and Leak detection prompted
and/or reinforced by the above and the more recent failures
Enbridge Pipeline Spill in Marshall, MI (7/25/10)
Chevron Pipeline Spills (Salt Lake City) June/Dec 2010
Exxon/Mobil Spill into Yellowstone River (7/1/11)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
2013/2014 Accidents – High
Profile
• Recent Accidents and Near Misses:
– 7/2/13 – P66 Seminoe P/L, Crow
Nation, Wyoming
– 9/10/14 – Alyeska failure of
encapsulation, MP 38
– 3/31/14 – Plymouth, WA LNG Plant –
WUTC (lead) and PHMSA investigating
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
P66 Seminoe Pipeline Spill
Crow Nation near Lodge Grass, MT
July 2, 2013
• Compression and buckling of 8-inch refined products line
resulted in 600 BBLs released on to Crow Nation land
• Crow Nation cooperative but demanding of P66. Wanted
routine updates from PHMSA
• Terrain was hilly but not particularly steep, evidence of
soil movement
• No CAO issued due to fast response by operator and
couldn’t add anything
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Crow Nation Rupture – Rolling Hills
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
P66 Actions Taken
• Replaced 500 feet of pipe.
• Relieved stress on over 4000 feet of pipe based on
Geotechnical Engineer evaluation.
• Installed additional strain gauges in the area of the failure
post stress relief and monitor for a year to validate if there
was movement.
• Stand up test to ensure no other seepers in area.
• Perform weekly aerial patrols on pipeline until the
completion of a deformation/strain tool and other slope
movement areas remediated.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Seminoe Pipeline Lesson Learned
• Ground movement doesn’t need to be a sudden
catastrophic slope failure to fail pipe
• ILIs should be selected to look for deformation,
ovality, and wrinkles caused by ground movement
• Remember to treat incidents on Sovereign Nations
differently
• Companies must consider land movement and
water crossings in their IMP preventative and
mitigative measures.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Alyeska Vent Encapsulation Failure
September 2013
• Large 10-inch diameter coupon of carrier pipe found in
Valdez Back Pressure Valve
• Recent ILI data showed that it had come from recently
installed vent encapsulation over 400 miles to north
• No release but encapsulation and hole sleeved. It appears
epoxy in sleeve expanded and pushed carrier pipe inwards
• Over 100 of these had been put on during previous 2 years
• Simulated encapusulation in Fairbanks yard failed
• Issued Order to investigate other encapsulations on pipe
requiring additional testing, ILI runs, and repairs
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Vent Encapsulation Photos
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Sleeved encapsulation at MP 385.77
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lesson Learned
• Don’t use untried methods of repair
that don’t follow manufacturers
guidelines.
• Need boots on ground – neither us or
JPO knew these were being put on.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
P66 Spill “Out of Service” Pipeline Spill
Wilmington, CA – March 17, 2014
On March 17, 2014, Phillips (P66) is notified by emergency
responders of crude oil leaking up from below pavement in a
residential area of Wilmington, California. While leak was close
to a P66 Wilmington refinery, they didn’t think it was theirs.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
P66 Wilmington, CA spill
• On March 18th, P66 excavated the leaking pipeline and
determined it was actually their line. P66 had purchased
the pipeline from the previous operator in 1998. P66
thought it had been properly abandoned and purged prior
to their purchase.
• The leaking pipeline was a 10-inch diameter, 0.25 inch
thick wall, carbon steel pipe installed in 1952. The cause of
failure was an internal “pinhole” corrosion leak on a weld.
• P66 estimates that 39 barrels of crude oil was released and
recovered. Estimated property damage reported $400,900.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lesson Learned
• Pipelines are either active or abandoned. There is no “out of
service” or “idled” designation for pipelines under Parts 192
or 195.
• Even if the previous operator says lines were abandoned
make sure you review how it was done and confirm it is
actually isolated, cleaned and purged.
• Treat idled lines like active lines under IMP.
• California Congresswoman may propose legislation
clarifying and confirming status of pipelines.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Williams LNG Facilty
Plymouth, WA – March 31, 2014
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lesson Learned
– Look at pre-liquefaction processes or any
processes that could affect LNG facility
– Evacuation zones are much wider than is
common knowledge
– Change must be focus, e.g. this plant had
had its adsorbers recently overhauled
– Good State Agents Garner Public
Confidence and are Priceless to PHMSA
(WUTC will cover in more detail)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Accidents w/ Oversight Impact
July 2011- June 2013
• Exxon Mobil Silvertip Pipeline Spill – July
1, 2011
• TransCanada Bison Pipeline Rupture – July
20, 2012
• Chevron Willard Bay, Utah Spill – March
2013
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Exxon Mobil Pipeline Spill
July 1, 2011
• Exxon Mobil Pipeline spills 1500 BBLs into
Yellowstone River during record flooding.
• CAO issued 7/5 to take out of service until they
put HDD under Yellowstone River, did water
crossing surveys and remediation, rework
SCADA training and abnormal operating
procedures.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
ExxonMobil Silvertip – July 2011
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Preliminary Findings
– ExxonMobil Silvertip pipeline released estimated
1500 barrels of crude oil into the Yellowstone
River near Laurel, Montana; Est. $42M damages
– River scour is cause of ruptured pipeline
– EMPL was aware of the flood conditions
– EMPL detected pressure drop at river and shut
pipeline pumps down in 7 minutes
– Despite having numerous remote actuated valves
at rivers, controllers took 56 minutes after first
alarm to close valve adjacent to river allowing
crude oil to drain into the river
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Montana Governor’s Task Force
• Reason for Study: As a result of the July 2, 2011 crude oil
spill into the Yellowstone River, ensure the integrity of
petroleum pipelines at major water crossings that affect
rivers in Montana.
• Primary Purpose: Collaborate with State of Montana to
compile an inventory of petroleum pipelines at water
crossings and determine if they are currently safe.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Other Purposes of Survey and
Lessons Learned
• Determine if additional steps are required before Spring
2012 run off.
• Determine adequacy of pipeline operators’ patrolling
methods and remedial actions at water crossings
• Develop recommendations regarding:
– Enhance PHMSA inspection guidance to ensure operators
are meeting all aspects of regulations, particularly with
respect to protecting their pipelines from water-related
damage.
– Identify possible regulatory changes to PHMSA
leadership expanding the requirements for water
crossings.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
TransCanada Bison Rupture
Near Gillette, WY
July 20, 2012
• Pipeline ruptured within 6 months of being
put into service
• Pipeline was first pipeline to be put into
service using the Alternative MAOP
regulation
• CAO issued on 7/21 requiring DCVG,
completion of ILI run and remediation digs.
• Metallurgical analysis
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Bison Pipeline Rupture – 7/20/11
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
TransCanada Lesson Learned
• Pipeline companies still need to ensure there is
good quality control during all phases of
construction.
• The defect can manifest itself before the baseline
pig run, in this case 6 months, can be analyzed
– Happened within a few days after being smart
pigged
• DCVG revealed other areas of “lowering in”
damage.
• Relative low Charpy value in steel (still met API 5L)
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Chevron Pipeline Spill
March 18, 2013
• Chevron Products Pipeline spilled 500+ BBLs adjacent to
Willard Bay due to corrosion near longitudinal seam
• split on Low Frequency ERW pipe.
• CAO issued 3/22 to reduce pressure, hydrotest LFERW
pipeline in area of Willard Bay, notify emergency
responders and stakeholders during start up, and
conduct metallurgical examination of failed pipe.
• Will expand CAO scope based on these findings.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Chevron Northwest Products _
Willard Bay, UT – March 2013
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lesson Learned
– Ensure that IMP program reflects all of
line pipe
• Match up alignment sheets with
corporate IMP plans
– Just because LFERW has not failed doesn’t
mean it’s not seam susceptible
• Spike Hydros do have place
– Can not communicate enough – Keep logs
of contacts
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Older Accidents w/ Oversight Impact
June 2010- June 2011
• Major Accidents:
– Bridger Lake Spill April 2010
– Chevron Crude Oil Spill June 2010
– Chevron Crude Oil Spill in December 2010
– Alyeska PS9 Tank Overfill in May 2010
– Alyeska PS1 Corrosion Leak at PS1 in January 2011
– PG&E San Bruno, CA explosion in September 2010
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Pipeline Spill
April 5, 2010
• Unknown crude oil line spills 2000 BBL near Mt View, WY
• CAO issued 4/28 to take out of service until O&M, OQ, and ILI
conducted. Tank allowed to come back into service.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lessons Learned
• Inspectors missed this pipeline by not looking
around for new pipelines when in the area
• Check out pipeline facilities in person; we called
about this one and took operator’s word of
regulatory exemption without verifying
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Another High Profile Accident in Alaska
• Alyeska Pump Station (PS) 9 – May 25, 2010
– Overfilled Breakout Tank at PS 9
– 5000 BBLs spilled out vents and into containment area.
– Failed Unit Power System (UPS) prevented
communications, tank monitoring and valve control.
– Tank appears to be damaged.
– Issued a CAO requiring full time monitoring at PS9 and
staffing by OQ personnel at site. Verification that
pipeline could operate without PS 9 relief.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Photo of Alyeska Spill
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lessons Learned
• Maintain Close Working Relationship with State and Federal
OSCs
• Move Fast – Have an Enforcement Strategy to Move Quickly
• Focus on Change During Inspections
• Ensure Operators have Some or Sufficient Qualified
Individuals Present During All Maintenance Operations
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Chevron – Salt Lake City, June 12, 2010
•
Approx 750 BBL of crude spill into Salt Lake City creeks and small lakes on
June 11/12, 2010.
•
Power company built substation immediately adjacent to pipeline. Fence
post directly on top of pipeline.
•
Fault current burned dime sized hole in pipeline.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Damaged Pipe - Salt Lake City, June 12, 2010
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lesson Learned
• Roll quick and get there quick
– Personal experience is to lean into it
• Put someone embedded in Unified Command during High
Profile Accidents
• Just because you are talking to Operator and FOSC doesn’t
mean your message is getting out; Goes better when people
know someone is in charge (people want to be in loop)
– Keep State Partner informed first
– Work with Mayors or County Commissioners
– Volunteer to Speak at Community Meetings
– Talk to Congressman
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lesson Learned
• We need to spend more time on the right of way
• AC and fault current mitigation not being looked at hard
enough
• ROW patrol methods are not appropriate for terrain or
foliage cover
• Prediction – Rulemaking for remote valve actuation, or
stronger focus on the preventative and mitigative part of
IMP
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Salt Lake City, Utah – December 1, 2010
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Salt Lake City, Utah – December 1, 2010
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lesson Learned
• Don’t have a release in same area after remedial actions
• Make sure that the operators fix or your remedial actions
didn’t introduce other risks
• Outreach needs to be even greater – Now regulator’s ability
is in question.
• Figure out someway to give other stakeholder input
– Worked with Mayor’s consultant
– Realize that even then, you need to give local officials
some credible input – valve placement planning, extra
time.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Alyeska Pump Station 1
January 8, 2011
• A crude oil release was discovered on the TransAlaska Pipeline (TAPS) at Pump Station #1 (PS1).
• The leak source was from below ground piping that
led to the basement of the of booster pump building.
The piping was encased in concrete and could not be
accessed.
• The TAPS could not be operated without the booster
pumps so the entire pipeline system needed to be
shutdown to stop the leak and enact the repairs.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Alyeska Pump Station 1
• Cold weather and lowering crude oil temperatures
within the TAPS pipeline became a serious concern.
• If the temperature on TAPS got much below freezing
on other sections of the 800-mile long pipeline, or on
idled North Slope production lines, there was a
strong possibility of other crude oil releases
occurring during the shutdown period or after
eventual restart of the systems
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Alyeska Lesson Learned
• PHMSA needs inspectors to focus more on station piping
during IMP inspections.
• Sync up expectations with other responders; in this case
we were lucky to have a long standing relationship where
we were comfortable recommending line be restarted with
leak.
• Sometimes it is better to let someone else take lead and
work behind scenes.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
San Bruno, CA - September 9, 2010
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
PG&E, San Bruno, CA
September 9, 2010
• 30 inch gas transmission pipeline in dense suburb
• Ruptured at 6:11 pm during rush hour
• 8 fatalities, over 50 injuries
• 38 homes destroyed
• Over an hour to close two valves less than a 1 ½ miles apart
• Grandfathered Pipelines (1948 and 1956) – No hydro
• PG&E used Direct Assessment
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Lesson Learned
• Feds and State Need to support each other • Gas IMP rule is interpreted differently by different
operators, States, and Feds
• NTSB doesn’t conduct investigations – they coordinate
• Helps if you have a strong enforcement record with
operator in past
• Direct Assessment is being misapplied – many companies
do not know what they have in ground
• Western Region had many small operators that had not
gone through and IMP review in CA.
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Integrated Inspections
• System approach – contiguous, same vintage,
same risks, one or more inspection units
• Heavy focus on Preparation to determine what to
ask prior to inspections
• Tap multiple experts
• Data driven approach to determine where we
focus our inspection resources
• Are beginning to find common precursors to
recent incidents, e.g. hydraulic changes, parallel
structures, AC interference, type of assessment
- 53 -
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Integrated Inspection
• Time consuming and labor intensive – taking 6 to 15
months from start to finish
• Teams are hard to assemble and coordinate
• Operators are complaining about time to conduct
• Staff committed to inspections for months – lose
management ability to re deploy staff
• Concerns that if we wait too long to conduct periodic
inspections that operator will backslide
• Inconsistency on II approach between regions needs to be
reduced further
- 54 -
U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration
Questions?