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

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.

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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