So much pipeline safety information!

Did you know we recently updated our briefing papers and added papers on three additional topics? These papers are a great source of ‘Pipeline Safety 101′ information – they are short and each focused on a single topic. They do not need to be read in order, though some basic understanding is helpful before reading about the more technical issues. Check them out if you haven’t already! Here is the full list:

 

Another pipeline incident anniversary – have things changed since 2009?

Question of the weekI think it was around this time in 2009 that a gas pipeline blew up in Palm City, Florida near a school. What really happened then, and have things gotten safer in the past 6 years?

On May 4, 2009, an 18-inch Florida Gas Transmission Company interstate pipeline ruptured about 6 miles south of Palm City, Florida, releasing about 36 million cubic feet of natural gas and causing three minor injuries in Martin County. The community was fortunate: the gas did not find a source of ignition and catch fire, nor did two other large gas lines buried parallel to the one that ruptured sustain any damage, though 106 feet (over 5,000 pounds) of buried pipeline was blown into the air and landed in the right-of-way between two major highways. The pipeline segment that failed was between two automatic shutoff valves, but only one closed in response to the pressure drop on the pipeline. A Supervisory Control and Data Acquisition (SCADA) system was in use by the pipeline operator at its control center in Houston, TX to remotely monitor and control the movement of gas through the pipeline. The SCADA system also failed to recognize the rupture or trigger any alarms.NTSB: Location next to I-95 and high school, in Rupture of Florida Gas Transmission Pipeline and Release of Natural Gas 20090504

The National Transportation Safety Board (NTSB) issued a pipeline accident brief on this incident, which found the cause of the accident to be the operator’s failure to detect cracking of the pipeline beneath protective coating. The NTSB also found that the operator failed to correctly identify the pipe as being within a high consequence area even though it was near a school.

As with most pipeline incidents, there were many contributing factors to this incident. The operator subsequently changed operations and procedures related to this pipeline in response to a PHMSA corrective action order as reported by the NTSB. But here, in response to the question about whether things have gotten safer in the past 6 years, we will focus on the issue of high consequence area (HCA) identification.

If the pipeline segment had been correctly identified as being within a high consequence area, then it would have been included in the pipeline operator’s integrity management program. There are specific rules in the federal regulations requiring the implementation of integrity management in high consequence areas, and these include specific inspection, analysis, maintenance and repair criteria designed to detect problems such as those that caused this 2009 incident.

As to whether these same mistakes could be happening today, the answer is yes. Are things safer? It’s hard to say. The same rules that allowed the identity and location of HCA’s to be kept secret from the public in 2009 are still in place. The public can’t know, until after an incident, whether an operator has accurately identified the HCAs along its route.  

A fundamental problem is that PHMSA essentially leaves the designation of high consequence area (HCA) boundaries up to the pipeline operators, and entrusts them to update the boundaries when any changes take place that would trigger a new inclusion in the HCA. There is no way for an average citizen to know about the details of these HCA boundaries, to know if PHMSA is enforcing the designation of those areas, and no way to help ensure operators encapsulate what needs to be included within those boundaries according to the regulations.

For example, on a gas transmission line like the one in Florida that ruptured in 2009, the presence of certain populated areas would trigger the HCA designation. There is a complicated way for gas pipeline operators to choose their method of designation and draw their boundaries (see 49 CFR §192.903). Put generally, any area near a pipeline with a high population (for gas pipelines, that means 20 or more homes), or with a populated activity center (e.g. school, office, assisted living, recreation area, campground, etc.; referred to as “designated sites” in the gas regulations), would be considered part of an HCA. Just how near to the gas pipeline these homes and activities need to be to trigger the HCA designation depends on how big the pipeline is, and the pressure inside it.

So what if a community is building a new school? Or what if a development goes in within a half-mile of an existing pipeline? In the case of a hazardous liquid (e.g. crude oil or petroleum) pipeline, nearby town water intakes or environmentally sensitive areas also trigger the HCA designation – what if a town changes their water intake or an agency recognizes a new critical habitat area? These types of changes and development happen all across the country, but only a very few communities have practices or rules in place that facilitate active dialogue between a pipeline operator and developer, or between an emergency management team and pipeline operator, to the degree that these types of changes are promptly reflected in a pipeline operator’s integrity management program.

In fact, PHMSA rules allow over 10 years – yes, TEN YEARS – from the time a natural gas pipeline operator identifies HCA changes to when that information must be part of a completed baseline assessment of the pipeline in the newly identified HCA. And PHMSA rules allow over 6 years from the time a hazardous liquid pipeline operator identifies an area of high population or sensitivity, to when that information must have been incorporated into its completed pipeline assessment. And the time between the actual on-the-ground change and the identification of that change by the pipeline operator adds even more time – a vague amount of time as this type of information analysis is only required by the operator ‘periodically.’

Contrary to some who think pipeline information needs to be less accessible, we think the secrecy surrounding pipeline operator’s designations of high consequence areas (HCAs) and other withheld information leads to more risky pipelines. If communities could access this type of information easily, it would be easy for planners, emergency responders, and concerned citizens to inform pipeline operators when a change is needed – thereby leading to SAFER pipelines, not more risky ones. Our experience is that those most impacted by pipelines – those who live in close proximity to them, are the ones with most at stake and most interested in keeping the pipelines and their community safe. Withholding information from these stakeholders disregards critical allies in our collective efforts toward safer pipelines.

Despite the lack of a transparent playing field in this area, there are some things you can do.

Communities with active Local Emergency Planning Committees (LEPC) often have regular open meetings, and the committee itself should include representation from community groups as well as emergency response professionals, elected officials, professional staff, and facility and pipeline operators. The emergency responders who participate in these meetings have the ability to access information from pipeline operators that the general public cannot access. Pipeline operators are required to share their emergency response plans with local first responders, and to maintain liaison with appropriate fire, police, and other public officials. Citizens can participate with the LEPC and request the committee work on accurate identification of HCAs in partnership with the pipeline operator. The LEPC topic is addressed in more detail in chapter 5 of our Local Government Guide to Pipelines.

PHMSA maintains a web-based National Pipeline Mapping System (NPMS), which is viewable on a county-level and depicts the location of hazardous liquid and natural gas pipelines, along with population areas and other information. While the population areas may give some indication of where a high consequence area is likely to be designated, there is not a direct link between the NPMS information and what the operators currently use to designate their HCAs. The PHMSA information is not up to date, and does not include the level of detail or environmental information needed to truly assess HCA boundaries. This is a problem. There are periodic opportunities for the public to comment on this issue, as the Trust did in December 2014 and October 2013 (comments of the Trust on a variety of pipeline safety topics are viewable here). The public needs to be able to view information and data gathered from pipeline companies on NPMS that depicts pipeline locations within an HCA with a high level of accuracy. There is in fact a statutory requirement that HCAs be incorporated as part of NPMS and updated biennially.[1]

Lastly, the Palm City, Florida incident was one of the incidents the NTSB highlighted in their recent safety study published earlier this year entitled “Integrity Management of Gas Transmission Pipelines in High Consequence Areas” and discussed in our January 30 Smart Pig blog post. This study included a number of additional changes needed to help make pipelines safer over time.

[1] Pipeline Safety Regulatory Certainty, and Job Creation Act of 2011; Section 6 made part of 49 USC 60132.