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One Year Later: Update on Enbridge Lakehead System Improvements
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The failure on Enbridge’s Line 6B  on July 26, 2010 in Marshall, Michigan released approximately a million gallons of crude oil into Talmadge Creek and contaminated up to thirty-eight miles of the Kalamazoo River.  PHMSA’s spill investigation resulted in 24 violations of federal pipeline safety regulations and the collection of a $3.7 million civil penalty – the largest ever issued by the agency for pipeline safety violations. On July 27, 2012, Enbridge’s Line 14 failed near Grand March, Wisconsin and spilled an estimated 1,200 barrels of crude oil.

Based upon the history of failures on these lines, PHMSA and Enbridge signed a consent agreement requiring the operator to review its integrity management system for entire 1,900-mile Lakehead pipeline system, located in the Great Lakes Region. This system transports crude oil and liquid petroleum in the Mid-Continent and Gulf Coast regions of the United States. The U.S. portion of the Lakehead system consists of Enbridge lines 1, 2A, 2B, 3, 4, 5, 6A, 6B, 14, 61, 62, 64, 65, and 67.

Lakehead System

While PHMSA enforcement actions are resulting in safety improvements to the entire Lakehead pipeline system, many of the required corrective activities have been targeted on lines 6B and 14, which were the subject of recent failures and enforcement actions. The following is a summary of the activities that have been conducted on these lines.

PHMSA Enforcement Actions on Line 6B

Repair, Safety, and Integrity Verification Actions on Line 6B

  • The pipeline, which includes 75 miles in Indiana and Michigan, is being replaced.
  • Nine PHMSA engineers have spent 79 days in-office and 113 days out-of-office overseeing Enbridge’s remedial activities on Line 6B.
  • Prior to the decision to replace the pipeline, more than 60 digs were conducted based on inline inspection (ILI) ultrasonic crack inspection results.
  • Enbridge was required to train personnel, enhance the effectiveness of emergency and operating procedures and improve the overall safety culture in response to control room process failures.
  • NTSB completed metallurgical reports and a root cause failure analyses on the Line 6B failure.

PHMSA Enforcement Actions on Line 14

Repair, Safety, and Integrity Verification Actions on Line 14

Five PHMSA engineers spent a combined 61.5 days in-office and 47 days out-of-office overseeing remedial actions on Line 14.

  • PHMSA required a 20% pressure reduction for Line 14 before approving Enbridge’s restart.
  • Enbridge’s integrity verification and remedial work plan covering all relevant operating data (including historical repair information, construction, operating, maintenance, testing, metallurgical analysis, and assessment data) must be completed and approved before returning to higher pressure.
  • Metallurgical testing on the failure section has been completed.
  • Review of prior ILIs has been completed.
  • Review of new ultrasonic crack ILI results has been completed.
  • New and reviewed ILI results have been comprehensively integrated into Enbridge’s integrity verification program.
  • A Management Oversight and Risk Tree (MORT) root cause failure analysis and a Root Cause Failure Analysis (RCFA) are being conducted.
  • PHMSA required ILI anomalies to be repaired to a higher standard.
  • Scheduled integrity management digs currently in process on multiple segments include ILI-driven, priority notification, and hydrostatic pressure test digs.
  • PHMSA required more extensive hydrostatic testing.
  • Hydrostatic testing has been completed with no leaks or failures.
  • PHMSA personnel were provided with hourly updates during hydrostatic tests and participated in evaluation and feedback throughout the process.
  • Enbridge has been required to submit monthly progress reports through the duration of the CAO.
  • Monthly  reports show  the following costs have been expended so far by Enbridge in compliance:
    • $7,262,000—to prepare and revise  procedures, studies, testing, evaluations, and information analyses;
    • $14,251,000—to make physical changes to pipeline infrastructure, including repairs, replacements and other modifications;and
    • $9,335,000—it environmental remediation:.

 

NEXT STEPS

Pursuant to PHMSA’s requirements, Enbridge has completed implementation of an in-line inspection and repair program and a hydrostatic pressure testing program to verify the integrity of the system’s Line 14 pipelines as well as an engineering assessment to confirm Line 14’s ability to safely operate at pre-failure pressures.

There remain numerous requirements in PHMSA’s enforcement documents and consent agreement for Enbridge to execute on its comprehensive plan to enhance the system’s continued safe operation.  As work progresses on execution of this plan, PHMSA will continue to closely monitor the company’s activities and will consider input from an independent expert who is also monitoring the company.  PHMSA will continue to provide periodic updates up implementation of the consent agreement periodically.

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