THE FIRST THREE YEARS OF OUR OIL POLLUTION ACT OF 1990 DRILL PROGRAM
The OPA '90 exercise program
started out with fairly elementary
table top and area drills in Fiscal
Year 1997. Three years later, the
drills build on lessons learned
and relationships forged at the
table top and area exercises OPS
has hosted. Perhaps the most
valuable aspect of the exercise
program is that it allows
emergency responders from
industry, Federal, State, and local
agencies to get acquainted and
work together before an actual
spill.
In recent discussions with people
who had participated in OPS
table top exercises, we found
encouraging results and some
areas to improve. Eighty-seven
percent of the responders believe
the key issues that should have
been raised were. Most industry
representatives are better
preventing and responding to
spills by using lessons learned
from the drills. Three quarters of
those polled report relationships
between industry and
government responders are
stronger since the drills.
Operators are learning more
about where environmentally
sensitive areas are and how to
protect them. Most companies
have thought about whether their
highest consequence spills would
differ from their worst case
discharges. Sixty-one percent of
operators have modified their
response plans. Eighty-nine
percent considered the drills
valuable.
When we examined the exercise
evaluation reports, we drew the
following conclusions. Most
operators understand and use
unified and incident command
but could hone these skills with
more practice. Most spill
management teams understand
how to manage emergencies and
are fairly good at it. Most
industry representatives know
who in the Federal, State, and
local governments to call about
an oil spill. Operators need to
update their notification lists
more often and to assign more
than one person to make the
calls.
We are taking several steps to
strengthen our exercise program.
The first is to continue to choose
operators that carry products in a
wide range of operating
conditions and that range in size
and in the environmentally
sensitive areas the pipelines
cross. The second is to use high
technology tools such as maps
showing sensitive areas and spill
trajectories to bring more reality
to the exercises. We are also
asking our facilitators to ask
tough questions and to challenge
assumptions about response
capabilities. We welcome
suggestions for how to improve
our exercise program. If you
have an idea, please contact Jim
Taylor at jim.taylor@rspa.dot.gov or
Melanie Barber at
melanie.barber@rspa.dot.gov.
WHERE THE PIPELINES ARE
When Congress reauthorized the
Pipeline Safety Act programs,
they directed OPS to require
operators to create and maintain
accurate maps that have the
operator's natural gas
transmission, significant
distribution, and major hazardous
liquid pipeline facilities. The
maps must describe the products
transported through the
operator's pipelines, characterize
the pipelines, and contain other
information that will let a State
know pipeline facilities are
operating in the State.
On March 30, in New Orleans,
Louisiana, OPS had the fifth
mapping workshop. The
workshop highlights include
operator standards changes. The
new attribute data describes
owner, operator, commodities,
diameter, and metadata, which
tells how the data was collected
and processed. The templates
should help pipeline operators
submit data to the National
Pipeline Mapping System
(NPMS) repositories. About
fifty pipeline operators took part
in the workshop. OPS asks
pipeline operators to submit data
to the NPMS.
OPS created a Joint
Government/Industry Mapping
Quality Action Team (MQAT I)
to find ways to get pipeline data.
The Team considered data bases
that might help with mapping.
A second MQAT finished
standards for creating and
operating the national map in
December 1998. The Repository
Standards have details for the
National and State repositories
on collecting, processing, editing,
disseminating, and storing data.
OPS asked operators to submit
reasonably accurate location data
on United States natural gas
transmission pipelines, the
hazardous liquid pipelines, and
LNG facilities. The data should
have an accuracy of up to plus or
minus 500 feet of its location.
The NPMS has a National
Repository and many State
Repositories. The State
Repositories create and maintain
the data for their States while the
National Repository creates and
maintains the data for States that
have no Repository. Michael
Baker Corporation runs the
National Repository and
California, Kansas, Kentucky,
Louisiana, Minnesota, New
Jersey, Oklahoma, Pennsylvania,
and Texas have State
Repositories. OPS is funding up
to half the costs for collecting,
processing, and maintaining the
pipeline data for each State.
States that did not submit
proposals for this first round of
State Repositories may submit
proposals in the Summer of 1999
to join the NPMS in the Fall of
1999.
The National Pipeline Mapping System website is:
www.npms.rspa.dot.gov
or contact Steven Fischer,
GIS Coordinator at the OPS: (202) 366-6267 or e-mail steven.fischer@rspa.dot.gov
DEFINING UNUSUALLY SENSITIVE AREAS
How can unusually sensitive
areas (USAs) be defined so that
whole States are not USAs and
special areas are protected? This
is the challenge Congress gave
OPS in the 1992 Pipeline Safety
Act reauthorization. OPS invited
Federal and State environmental
protection agency and industry
representatives to help us choose
how to define USAs.
With the industry and other
agencies' help, we agreed on a
USA definition and approved a
model for protecting drinking
water and ecological resources,
guiding principles, definitions for
USA terms, and a way to winnow
the environmentally sensitive
area list. We agreed on USA
candidates and criteria for
drinking water resources, and
USA candidates for ecological
resources. We could not get
everyone to sign off on
ecological filtering criteria.
Major differences were whether
all threatened and endangered
species' habitats should be USAs
and whether entire national parks
or only certain areas within the
parks should be considered
USAs.
The American Petroleum
Institute (API) intends to publish
the USA work as guidelines the
pipeline industry can use to
define USAs. OPS and API will
conduct pilot tests on the USA
model and have asked other
government and industry
environmental experts to help us
further evaluate the model.
Evaluation will determine the
model's effectiveness as a basis
for operator decision making and
for the pertinence and
accessibility of environmental
data to strengthen decision
making.
OPS and API will send
the pilot test results to drinking
water and ecological experts to
verify that the USAs in the model
are unusually sensitive areas and
that the model has not missed
other USAs. The pilot testing
results and industry guidelines
will be used to write the USA
regulation.
If you have questions
about the USA project, you can
reach Christina Sames at
(202)366-4561 or e-mail at
christina.sames@rspa.dot.gov
TANK UPDATE
On April 2, 1999, OPS published
a final rule amending our
regulations for pipeline breakout
tanks. These are tanks that are
used to store hazardous liquids
that pipelines transport. The new
rule adopts industry standards for
tank construction, operations,
maintenance, repairs, and spill
prevention. The rule will greatly
improve our ability to protect
people and the environment from
leaking breakout tanks. Pipeline
operators will have 18 months
from April 2, 1999 or until
September 2, 2000 to bring their
facilities into compliance. If
you have questions about the
rule, please call Mike Israni at
(202) 366-4571 or zap him an e-mail at mike.israni@rspa.dot.gov
CHECK THE EXPIRATION
DATE ON YOUR FACILITY
RESPONSE PLANS
When is the last time you used
your facility response plan? Was
it for a drill or a spill? Is the
information accurate?
If you're like many pipeline
operators, you might not think
much about your spill plan until
you need it. By then, it's too late
to update the phone numbers in
the notification list or find out
that your response contractor has
gone out of business.
In a recent informal check of a
sample of response plans in our
library, we found that a number
of operators had not sent OPS
plan revisions since the plan was
originally submitted several
years ago. That could be a
problem, because people and
companies come and go and the
plans have to keep pace with
those changes. If it's been a
while since you updated your
response plan, take a look at it
again. If the plan is out of date,
revise it and send the changes to
OPS. Questions? Please call Jim
Taylor at OPS, (202) 366-8860
or e-mail him at jim.taylor@rspa.dot.gov
SUBMITTING PLANS ELECTRONICALLY
Operators can submit their plans
to OPS electronically or in hard
copy. We can accept electronic
media and software formats
including: 1.44M 3.5" HD floppy
disks, CD-ROMs, Iomega Zip
format, Iomega Jazz format, and
Imation Superdisk format. We
can accept the following word
processing documents with
figures, tables, and images:
- For PC's: ClarisWorks 1.0 or
higher, MS Word for Windows
6.0 or higher, MS Works 2.0 or
higher, PDF, WordPerfect
Windows 6.1 or higher, and any
Microsoft Office product.
- For Macintosh: Clarisworks 1.0
or higher, Macwrite, MS Word
for Windows 6.0 or higher, and
WordPerfect Windows 6.1 or
higher.
- Graphics: Windows ArcView,
GIF, TIFF, and DWG
Many other word processing
programs that may be acceptable
are not on the list. Please call
Jefferson Tancil (202) 366-8075 or
e-mail him at Jefferson.Tancil@rspa.dot.gov with your electronic
submission questions.
PLANNING FOR THE WORST CASE
OPA '90 requires facility
operators to draft oil spill
response plans that predict the
worst case discharge. The OPS
regulations explain how to do the
calculations. But how do the
calculated worst case discharge
volumes compare with the
amount of oil released in spills?
OPS is answering that very
question. We will look at several
case studies to see if the spills
were larger or smaller than the
worst case discharge calculated
in the plans. The results will help
us know how to prepare better
for future spills. Watch this
space in the next newsletter for
details.
PUBLIC MEETING ON CORROSION
OPS is evaluating the need to
modify our corrosion control
standards for gas and hazardous
liquid pipelines. We are
reviewing the gas standards to
see if they need to be clarified,
made more effective, or upgraded
to be consistent with modern
safety practices. The review will
help us carry out the President's
Regulatory Reinvention Initiative
and determine if rule changes are
needed to reduce the potential for
corrosion-caused accidents. We
have held a public meeting and
met with industry and State
agencies on the standards. To
get feedback on these efforts,
OPS invited the public to come
to the public meetings and to
submit written comments.
The public meeting was part of
the National Association of
Corrosion Engineers (NACE)
54th Annual Conference and
Exhibition, CORROSION/99, in
San Antonio, Texas on April 28,
1999 at the Marriott Riverwalk
Hotel in San Antonio, Texas. If
you have questions, please call
Richard Lopez at (713) 718-3956
or send him an e-mail at
richard.lopez@rspa.dot.gov
SPILL RESPONSE IN TENNESSEE AND KANSAS
In the early morning hours of
February 10, 1999 Colonial
Pipeline had a spill that released
more than a thousand barrels of
diesel fuel into Goose Creek, a
tributary to the Tennessee River
in Downtown Knoxville. The
Environmental Protection
Agency was the Federal on scene
coordinator overseeing the
response and establishing a
unified command that included
Colonial, the Coast Guard, the
Office of Pipeline Safety, the
State of Tennessee, the City of
Knoxville, and the Tennessee
Valley Authority. A number of
emergency response contractors
worked for three days and
recovered most of the oil with
minimal disruption to the
community and the environment.
The National Transportation
Safety Board and OPS are
investigating the accident.
On May 10, 1999, a sixteen-inch
pipeline Williams Pipeline
operates spilled more than 5,000
barrels of fuel oil into
Independence Creek in Atchison
County, Kansas. Williams and
their contractors, U.S. EPA
Region VII, Kansas Department
of Health and Environment,
Missouri Department of Natural
Resources, U.S. Fish and
Wildlife Service, OPS, and
Atchison County responded to
the spill. The oil soon reached
the Missouri River and a sheen
was observed as far downstream
as Leavenworth, Kansas. After
four days, most of the oil had
been cleaned up and the
emergency phase ended. OPS is
investigating the accident.
INDUSTRY RESPONSE PLAN TRENDS
OPS analyzed the first four years
of our response planning
program. Here are some of the
highlights.
- In the initial round in 1994-1995,
OPS reviewed 657 response plans
for high-risk facilities. OPS
conducted 786 completeness
checks on response plans for
lower-risk facilities.
- Only one operator's plan was
approved in the first round
without revisions. All the other
operators had areas that had to be
corrected before OPS could
approve their plans.
- Small companies generally had
an easier time than larger
operators correcting deficiencies
in their plans. Small companies
passed the second round of plan
reviews.
The pipeline industry is better
prepared than it was five years
ago but there is still room for
improvement. One of the more
significant findings was that
operators who participate in table
top exercises often do not revise
their response plans to
incorporate lessons learned from
the drills. Operators need to
make sure their plans are living
documents that are updated as
often as necessary.
A FIELD REPORT FROM
FAIRFAX COUNTY, VIRGINIA
BATTALION CHIEF MIKE NEUHARD
Mike Neuhard has been
protecting Fairfax County,
Virginia from hazardous
materials, explosions, fires, and
other threats to people and the
environment for about twenty-two years. He played a leading
role in responding to the 1993
Colonial spill in Northern
Virginia, made a valuable
contribution on the Natural Gas
Risk Assessment Quality Team,
narrated the musical comedy
introducing risk management,
and brings important experience
to the Advisory Committee and to
OPS' Oil Pollution Act and risk
management work. Mike shares
the lessons learned since he
joined the Fire Department in
that magical time when sideburns
were long, rents were low, and
country music ruled the
airwaves.
OPS: What is your philosophy
on how governments from the
County to the Federal level can
best protect people and the
environment?
MN: Environmental protection
and human safety are a
stakeholders game. An agency
or one group of people can not
do it all. Every day, you have to
engage and build effective
relationships with all the effected
and interested parties. Public
servants have to be extremely
open and must take the lead in
doing the right thing. Public
needs and expectations have to
be balanced with the need to
keep energy flowing reliably.
OPS: What is the most valuable
contribution local emergency
responders and environmental
protection workers make to
human safety and environmental
protection?
MN: Local people can share their
knowledge of and experience
with the area and culture
surrounding pipelines. They can
recommend ways to strengthen
prevention and response. They
can train and take part in drills
with their State and Federal
government and industry
counterparts. We can share
response and prevention
strategies that have worked in
Fairfax County with people
working in other parts of the
Nation. Most of all, they can
inject reality into what can be
esoteric plans and procedures.
OPS: Speaking of reality, can you
tell us the lessons Fairfax County
learned from responding to the
1993 release in Northern
Virginia?
MN: We know the tremendous
amount of resources needed to
respond to a large spill. We
learned the public was not
involved in making pipeline
safety policy. The public needs
to have a place at the table. That
is why we started working with
OPS and why we testified before
the congressional committees that
oversee OPS. Local, State, and
Federal Government
representatives and the industry
workers need to hammer out
policy continually. The overseers
and the industry should not just
work together after an incident.
Our understanding of how
pipelines are built and operate is
much deeper than it was six years
ago. We work much more
closely with all our partners on
human safety and environmental
protection. Two good examples
of this kind of work are my
service on the Pipeline Safety
Standards Committee for Gas and
on the Virginia State Corporation
Commission Underground
Utilities Damage Prevention
Advisory Committee.
OPS: Let's go from lessons
learned from releases to OPS' Oil
Pollution Act of 1990 table top
and area exercises. The Fairfax
County Fire and Rescue
Department made an excellent
contribution in hosting, taking
part, and helping to evaluate a
table top drill in February. How
can OPS strengthen its drills?
MN: First, OPS should use
1990's technology to map the
incident site, to post response
action, and to teach participants
concepts they have not mastered.
Second, hard follow up questions
need to be asked and answered.
Three, insufficient, vague,
unrealistic answers need to be
challenged. Four, lessons
learned need to be communicated
across the United States.
OPS: What did OPS learn from
responding to the 1993 incident?
MN: The spill forced OPS to
examine command and control,
information, and enforcement.
OPS started its risk management
program and is trying to base all
its regulations on risk. OPS did
not have all the information
about the industry it needed to
make strong, effective policy.
OPS: What is your sense about
the risk management
demonstration program?
MN: I won't have a final
judgment on risk management
until we have more information
on how the demonstrations
worked over four years. Here
are
some of the questions I have. (1)
Is OPS getting the information
they need from the industry? (2)
What are the consequences when
companies don't meet their
commitments to OPS? (3) Are
people and the environment as
safe
under risk management as they
are under the current one size fits
all regulatory scheme? (4) What
will motivate skeptical operators
to try risk management?
OPS: What challenges will the
Fairfax County Fire and Rescue
Department face as we approach
the next century?
MN: Human exposure to
pipelines will increase as the
County population grows.
Pipeline integrity will be even
more important. Growth and
safety have to be balanced. We
have to better use technology to
protect the public and the natural
world. The product pipelines
carry may change from
hazardous liquids to natural gas.
The public must be engaged in
making policies that safeguard
our surroundings and ourselves
and make sense.
PIPELINE SPILL STATISTICS
Pipeline Spills 1993-1999 greater than 10,000 GAL. |
230 |
Pipeline Spills > or = Worst Case Discharge in FRP |
9 |
Pipeline Spills Affecting Environmentally Sensitive Areas In FRP |
12 |
Spill Reports with Named ESA's Spills Affect |
33 |
Largest Difference Between Spill Volume and Calculated WCD Volume in FRP |
483,000 gallons |
OPS studied large pipeline spills since our OPA regulation was published in 1993. Most spills were smaller than
the calculated worst case discharge (WCD) volume in the operators' facility response plans (FRPs). Only four
percent of spills were greater than the calculated WCD.
- The largest difference between calculated WCD volumes and spill volumes was a spill in which the quantity
spilled exceeded the WCD by 483,000 gallons.
- Most facility response plans (FRPs) did not identify environmentally sensitive areas specifically enough to
be useful in responding to spills. Only 36 percent of the spills took place in environmentally sensitive areas
that were named in the FRPs.
FISCAL YEAR 1999 OFFICE OF PIPELINE SAFETY TABLE TOP AND AREA EXERCISES |
OPERATOR |
LOCATION |
DATE |
Niagra Mohawk
Power
300 Erie Blvd., West
ESD-1
Syracuse, NY |
#0406-0407
Oswego Steam
Station Zone |
June 2 |
Vastar Resources
15375 Memorial Drive
Houston, TX 77079 |
Lake Charles, LA
#1227 Gibbs-town
LA Zone |
June 7 |
DYNEGY
Midstream, Lowry
Gas Plant
Lake Arthur, LA |
Lake Arthur
#1292 |
June 8 |
Transcanada Gas Processing
P.O. Box 907
Eunice, LA 70535 |
Eunice, LA
#1272
Mermentau Pipeline Zone |
June 10 |
Enbridge Pipeline
2626 Sixth Avenue, N.E.
Minot, ND 58703-5043 |
Minot, ND
#0665 |
June 15 |
Mid-America Pipeline Company |
Omaha, NE
#2021 |
June 17 |
Oiltanking Houston
P.O. Box 96290
Houston, TX 77213-6290 |
Galveston, TX |
FY 2000 |
WV Oil Gathering
9320 Blackrun Road
Nashport, OH 43830 |
Clay/Bell's Run/St. Mary's Pipeline
Zone, WV
#1256 |
FY 2000 |
TEPPCO Crude Oil, LLC
100 North Broadway
Suite 2500
Oklahoma City, OK 73102 |
Alabama Ferry Field Zone
Centreville, TX
#0974 |
FY 2000 |
BP/Amoco
Belle Chase, LA |
New Orleans, LA |
August 9 - 11 |
Scurlock Permian LLC
P.O. Box 4648
Houston, TX 77210-4648 |
Johnson Bayou
Louisiana Zone
#0779 |
FY 2000 |
Colonial
945 East Paces Ferry Road
Atlanta, GA 30326 |
Baton Rouge, LA |
FY 2000 |
1999 CALENDAR FOR NATIONAL AND REGIONAL RESPONSE TEAMS
For a WordPerfect document of the NRT
Calendar.
June 1999
- Joint Region JRT Meeting with CANUSLANT/PREP '99 - 6/2-3
- Alaska Region RRT Meeting - Cordova, AK - 6/10
- NRT Regular Meeting - 6/24
- Region V RRT Meeting - Houston, TX - 6/28-7/1
July 1999
- NRT Regular Meeting - 7/29
August 1999
- NRT Regular Meeting - 8/26
For a spreadsheet (.xls) of NRT members.
HOW TO REACH US
At OPS, we'd like to hear from
you. If you have questions or
comments about the newsletter or
OPS programs please give us a
call or send us a fax, or e-mail.
U.S. Department Of
Transportation
Office of Pipeline Safety
Room 2103
400 Seventh Street, S.W.
Washington, DC 20590
Fax: (202)366-4566
Jim Taylor (202) 366-8860
jim.taylor@rspa.dot.gov
Melanie Barber (202) 366-4560
melanie.barber@rspa.dot.gov
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