Tuesday, May 6, 2014

PHMSA Publishes ‘Lessons Learned’ from Enbridge Spill

Today the DOT’s Pipeline and Hazardous Material Safety Administration (PHMSA) published a notice in the Federal Register (79 FR 25990-25994) identifying lessons learned from the Enbridge pipeline spill near Marshall, Michigan on July 25th, 2010. The lessons are based upon the results of the National Transportation Safety Board (NTSB) investigation of the incident published last July.

The NTSB report identifies the probable cause of the spill as being “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”. Three Enbridge failures were identified as contributing to the extent of the spill:

• 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.

The PHMSA notice identifies specific actions that other pipeline operators should take based upon these lessons. They include:

• Reviewing their own IM programs for similar deficiencies and to take corrective action;
• Training their control room staff as teams to recognize and respond to emergencies or unexpected conditions;
• Evaluate their leak detection capabilities to ensure adequate leak detection coverage during transient operations;
• Assessing the performance of their leak detection systems following a product release to identify and implement improvements as appropriate;
• Reviewing the effectiveness of their public awareness programs;
• Reviewing whether local emergency response teams are adequately prepared to identify and respond to early indications of ruptures; and
• Reviewing NTSB recommendations following accident investigations.

It seems to me that all facilities that handle hazardous materials could do well to follow these recommendations.

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