PIPELINE SAFETY ADVISORY BULLETIN
Advisory Bulletin: ADB-94-01 Date: 01/13/94

To: Owners and Operators of Natural Gas Pipeline Facilities and Other Gas Pipeline Facilities and Hazardous Liquid Pipeline Facilities

Subject: Certain Requirements Applying to Supplemental Incident/Accident Reports and Estimated Property Damage Totals

Purpose:

This advisory (1) reminds pipeline facility owners and operators to submit supplements to gas pipeline incident and hazardous liquid pipeline accident reports as required by the regulations, (2) clarifies what should be included in estimated property damage totals on incidentl accident reports, and (3) cancels a previous interpretation on costs to be included in these estimated property damage totals.

Advisory:

Written incident reports are required under 49 CFR 191.9 for gas distribution systems and 49 CFR 191.15 for gas transmission and gathering systems and accident reports are required under 49 CFR 195.54 for hazardous liquid pipeline systems. After the initial report has been submitted, the operator is required to submit a supplemental written report whenever additional relevant information is obtained concerning the particular incident or accident. The form to be used for supplemental reports is the same as for the initial reports, and submittal must be no later than 30 days after acquiring the additional information. All relevant costs must be included in the estimated property damage total on the initial written incident or accident report as well as supplemental reports. This includes (but is not limited to) costs due to property damage to the operator's facilities and to property of others, commodity/product not recovered, facility repair and replacement, gas distribution service restoration and relighting, leak locating, right-of-way clean up, and environmental clean up and damage. Facility repair, replacement, or change that is not related to the incident but is done by the operator as a matter of convenience (for example, to take advantage of access to facilities unearthed because of the incident) should not be included. On April 2, 1974, a letter from the Office of Pipeline Safety (OPS) to Lakehead Pipe Line Company included an interpretation that " .... the value of any commodity lost or fittings used during repair which become permanently attached to the system ..." is not to be included in the estimate of total property damage. This interpretation is no longer applicable.

Background:

A review of sampling incident and accident reports has revealed two problems with the reports: (1) Supplemental reports were seldom submitted, and (2) many estimates of property damage totals were low and appeared to be incomplete, particularly in regard to environmental damage including costs associated with cleanup. With regard to item (I), this advisory is a reminder to operators that supplemental reports updating data in the report are required to be submitted to OPS. Concerning item (2), there has been some misunderstanding on what costs to include in estimating property damage totals, perhaps because of the April 2, 1974, OPS letter to Lakehead Pipe Line Company. OPS wants all property damage costs associated with the failures reported on the report forms, particularly the costs of environmental damage and cleanup costs. Property damage costs that are determined after the initial submittal of the report forms should be submitted in additional supplemental report forms.

Issued in Washington, DC, on January 13, 1994.

Richard L. Beam, Associate Administrator for Pipeline Safety