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Table of Contents, thru level 3 Summary ..................................................................................................................... 1 Notable CI disasters 2007 ................................................................................................... 2 2007 Spain .................................................................................................................. 5 2007 May 01 NTSB report on Bergenfield NJ PSE&G ................................................. 5 NTSB examines PSE&G pipe .................................................................................... 6 American Tank Procedures and Training ................................................................... 7 PSE&G Standards....................................................................................................... 8 Relevant Government Standards................................................................................. 8 NJ Board of Public Utilities........................................................................................ 8 U.S. Occupational Safety and Health Administration ................................................ 9 Federal Pipeline Safety Requirements ........................................................................ 9 Industry Guidance..................................................................................................... 10 Excess Flow Valves .................................................................................................. 10 Bergenfield Fire Department Procedures and Training ............................................ 11 NTSB Recommendations.......................................................................................... 12 2007 Jun 14 Kingman KS NTSB report ....................................................................... 13 Enterprise pipeline integrity standards...................................................................... 15 Enterprise procedures for abnormal conditions ........................................................ 15 Enterprise post accident procedural repairs .............................................................. 18 NTSB Recommendations.......................................................................................... 19 2007 July 17 Baltimore Md ................................................................................... 20 2007 Sep 10 Mexico .............................................................................................. 20 2007 Oct 7 Sacramento Ca PG&E pipeline repair problem ...................................... 20 Pipelines - how parts can be criminally defective .................................................... 20 Pipeline repair found defective parts ........................................................................ 22 2007 Nov 01 - Dixie Fire in Carmichael MS............................................................ 23 Continued in more documents .......................................................................................... 23
Summary
Heres my summary when I upload this time line installment to Scribd:
http://www.scribd.com/doc/114094060/Indy-Boom
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6 Tags: fire, solutions, NTSB, incompetence, training lacking, leak, We continue to see many of the same old human errors repeated in other communities, leading to death, mayhem, destruction, and environmental disasters. The only improvement I am seeing, is the quality of investigatinve reports. So long as companies may operate in defiance of safety standards, it does not matter how good those standards.
http://www.scribd.com/doc/114094060/Indy-Boom
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Next morning it took the construction crew 20 minutes to recognize there was an emergency, and call 911 and the gas company. First responders arrived in 5 minutes, the gas company in 25 minutes. The gas company needs faster response. Despite strong evidence of a gas leak,3 first responders did not evacuate the building. The good news is that there is strong evidence that lessons learned from this incident have been communicated through training at the gas company, first responders throughout the state of NJ, and the construction company whose neglect triggered this disaster. Companies often have manuals for personnel spelling out how to deal with various crises, with good training to know that stuff. These guidelines start out in accordance with industry standards and government regulations, both of which change over time. Someone at the companies needs to notice when the source of the guidelines evolves, and update their manuals and training accordingly. Construction work scheduled, in the vicinity of a gas line, would normally call for the gas to be shut off for safety, but this is impractical in the middle of winter. So why not schedule the work during warmer weather? Construction work, in vicinity of a gas line, with inadequate measures taken to protect the gas line from mishaps. Critical Infrastructure personnel have awesome duties, whether they work air traffic control, operate nuclear power plants, or control pipelines. They can be overwhelmed with data and alarms. They need systems to manage the data and alarms wisely, such as color coding severity, and they need good training in interpreting what the data is telling them. Many disasters occur for lack of that support. Industry standards exist, which if followed, can avoid disasters. But they are not always followed. Kingman KS pipeline rupture: No one was killed or injured but 204 thousand gallons of anhydrous ammonia leaked into the environment. This accident cost $680,715 including $459,415 for environmental remediation. 1973, or later, construction damaged the pipeline. 2002-2004 events See PHMSA in this time line summary. 2004 Oct 27 the pipeline ruptured. Because of the scale of this disaster, I have a lot of info in my time lines about what we have learned about the circumstances. I include time line of this particular incident, and lots of other related info, in time line 2000 thru 2006; PHMSA Info. PHMSA = US pipeline and Hazardous Materials Safety Administration. I include links to various PHMSA info, and summarize what was in them.
In addition to the tenant who smelled gas, and failed to report it, all of the construction crew smelled the leak, and also a local businessman, who called 911.
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PHMSA safety advisory Aug 2002 to US industry in general. The Kingman disaster showed some challenges implementing this advisory in the real world. PHMSA audit 2003 Sep-Oct on the Kingman KS Pipeline which has a 2004 Oct incident, then 2007 June NTSB report on that incident. PHMSA notice 2004 Apr to the Kingman KS Pipeline, which has a 2004 Oct incident. The 2003 Sep-Oct audit had found many safety deficiencies at the company, and this notice identified what the company needed to fix, to avoid disaster. Kingman responded to the latest PHMSA notice in 2004 May-July, in which they said they had fixed some, but not all of what PHMSA had asked for. This led to PHMSA closing the notice 2004 Oct 18, a week and a half before the Kingman 2004 Oct disaster.
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Utilities need to be sure their curb valves can be turned off by their personnel in an emergency. This means either able to turn by hand, including in cold weather, or issue tools to personnel to get the job done when muscles cannot do the job. Vehicles carrying stuff, which might explode at any moment, going thru populated areas without police escort, or evacuation of people in harms way. Witnesses smell the distinct odor of a leak. They fail to notify authorities. The leak ultimately leads to a disaster.
2007 Spain
Estaca de Bares The NPK fertilizer cargo of the ship Ostedijk sustained a self-sustained decomposition (SSD) fire for 11 days. The fire plume reached 10 m in diameter and several hundred meters in length. Special water spears were inserted inside cargo to extinguish the fire. 4
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o American Tank failure to shore up the trench, so the gas pipe was not supported, fell down, pulled loose. o Apartment tenant smells gas, does not report it. o American Tank personnel slow to recognize there is an emergency, requiring faster reaction. PSE&G and first responders are not called until maybe 20 minutes after they see there is a problem. o Time it takes PSE&G personnel to arrive on scene where gas leak reported. 25 minutes better than some other incidents with other gas companies, but not as good as 5 minutes for first responders. Probable cause determined by NTSB: The NTSB determined that the probable cause of Dec 13, 2005, natural gas explosion and fire in Bergenfield, New Jersey, was the failure of American Tank Service Company to adequately protect the natural gas service line from shifting soil during excavation, which resulted in damage to the service line and the release and migration of natural gas into the apartment building. Contributing to the accident was failure of PSE&G to conduct effective oversight of excavation activities adjacent to the gas service line, and to be prepared to promptly shut off the flow of natural gas after the service line was damaged. Contributing to casualties in the accident was failure of Bergenfield Fire Department to evacuate the apartment building, despite strong evidence of a natural gas leak, 6 and the potential for gas to migrate into the building.
Gas had been smelled by the businessman who called 811, and by all the American Tank crew members. This was probably from American Tank effort to support the pipe Dec-13 morning, after the damage was done, from Dec-12 work.
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Thus, unlike many other gas disasters, there was nothing wrong with the gas pipe, although difficulty closing the valves means a related problem with PSE&G.
Uncover top of tank to determine its direction and hand excavation of nearby utilities. Evaluate nature of the soil to determine possibility of collapse. 8 Contact the utility company and request shutoff. Protect and support the utility; contact the utility company if damaged.
If damage to the utility is observed, call the emergency telephone numbers for the utility, and call 911 or fire and police department emergency telephone numbers. American Tank had no formal training program on the protection and support of utilities.
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PSE&G Standards
PSE&G participated in the New Jersey One Call system, and also various damage prevention and awareness activities in 2005. These activities included distributing damage prevention materials to home improvement stores, contractors, equipment rental companies, retail stores, and municipalities. PSE&G has not been using direct mailing to contractors unless damage has been reported. Then, PSE&G sends information letters about New Jerseys damage prevention laws to contractors who have damaged their companys underground facilities. PSE&G has an emergency plan developed in accordance with State and Federal regulations. However, this plan does not have a provision requiring testing curb valves to determine whether the valves can be quickly operated to shut down a service line when excavation activities place the line at risk.
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Industry Guidance
GPTC9 publishes the Guide for Gas Transmission and Distribution Piping Systems to help natural gas operators ensure regulatory compliance. The section of the GPTC guide referring to Section 192.614c(6) states the following: Where required, the inspection may include periodic or full-time surveillance and may include leakage surveys during and after construction. The operator should consider maintaining field contact with the excavator during the excavation activities to avoid potential problems. Section of GPTC guide referring to Section 192.615(a) states, Emergency plan objective should be to ensure that personnel, who could be involved in an emergency are prepared to recognize and deal with the situation in an expeditious and safe manner. The Common Ground Alliance Best Practices10 manual, version 3.0, states that the excavator must use reasonable care to avoid damaging underground facilities. The excavator should plan the excavation to avoid damage or minimize interference with the underground facilities in or near the work area. The manual also states that the protection of exposed underground facilities is as important as preventing damage to the facility when digging around the utility. Section 522 of the manual indicates that excavators are to support or brace exposed underground facilities and protect them from moving or shifting, which could result in damage to the facility. Methods to support, brace, and protect these facilities include shoring the facility from below or providing a timber support with hangers across the top of the excavation to ensure that the facility does not move or bend. Thus, it is evident that industry standards existed, which were not followed by American Tank or PSG&E.
The GPTC is an American National Standards Institute technical committee composed of technical specialists from industry, government, and the public.
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The Common Ground Alliance, composed of technical specialists from industry, government, and the public, provides a guide on underground utility damage prevention best practices and promotes their use throughout the United States.
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The NTSB investigation examined whether an excess flow valve that was compatible with the operating conditions for the apartment building would have been effective. Had the break in the service line been exposed to the open atmosphere, an excess flow valve would have activated immediately to restrict the flow of gas; however, in this accident, the broken section of pipe was underground and under asphalt pavement. A leakage test conducted 2 days after the accident resulted in a flow rate of natural gas through the broken service line of about 1,600 standard cubic feet per hour. The leakage test could not be conducted until the excavation site was stabilized. 11 Soil conditions at the time of the leakage test were significantly different than at the time the service line was broken; this difference likely affected the flow rate measured during the test. Further, the flow rate of natural gas to the apartment building at the time the service line was fractured cannot be determined.12 At the time of the accident, it was quite cold; the temperature was about 18 F. It would be reasonable to assume that the heating system and the replenishment of hot water for the tenants would have been operating near maximum capacity. However, given the uncertainty in the leakage test results and the unknown flow rate to the building, NTSB was not able to determine whether an excess flow valve, had one been installed, would have activated after the service line was broken in this accident.
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During firefighting operations, significant amounts of water had been used in the area. The trench adjacent to the broken section of pipe had been filled as a precautionary measure due to concerns that the building wall might collapse. Later, the trench was partially excavated then refilled because of unstable soil. Trench boxes were necessary to stabilize the excavation before NTSB investigators could access the site. 12 The flow rate to the building could not exceed 2,500 standard cubic feet per hour because of the capacity of the metering equipment.
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When the presence of gas is strong, the best rule is to evacuate people from the dwelling and move them across the street or a distance far away that would prevent injuries if the structure were to explode.13 The video Natural Gas: Recognizing and Avoiding the Hazards, which was produced with the cooperation of several companies and government agencies in New Jersey, including PSE&G, is also included as part of the Firefighter I course. As a result of a July 1999 accident in Fairlawn, New Jersey, and a March 2006 agreement with NJ Board of Public Utilities, PSE&G agreed to expand its emergency response training, coordinated with the Bergen County Fire Academy. As a result of the Bergenfield accident and a March 2006 agreement between NJ Board of Public Utilities and the PSE&G, the Board of Public Utilities obtained permission to distribute a PSE&G-produced video for firefighters and first responders in the State of New Jersey. This video includes information on how to handle gas leak emergencies, and when to check the building, and when to evacuate. October 2006, PSE&G mailed a computer disk containing electric and gas hazard awareness information to police departments, fire departments, and emergency management officials within PSE&Gs service area to help them to develop standard operating procedures for electrical and gas emergencies.
NTSB Recommendations
As a result of its investigation of the Bergenfield, New Jersey, pipeline accident, NTSB made safety recommendations listed below. For more information about these recommendations, see the safety recommendation letters14 to the recipients. To the Pipeline and Hazardous Materials Safety Administration: Provide a summary of the lessons learned from the Bergenfield, NJ, accident to recipients of emergency planning and response grants. (P-07-1) To the New Jersey Department of Community Affairs: Establish a requirement that all career and volunteer firefighters receive recurrent training on natural gas safety and incident response. (P-07-2) To the Borough of Bergenfield: Establish and implement written operating procedures for responding to natural gas incidents and emergencies. (P-07-3)
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However, as we see from the time line, gas was not smelled by first responders, and the explosion occurred immediately after PSE&G confirmed gas leak. 14 These letters are available on the National Transportation Safety Boards web site.
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To the American Tank Service Company: Establish and implement written procedures for safe excavation near pipelines, and provide initial and recurrent training on these procedures to employees. (P-07-4) To PSE&G: Modify your excavation damage prevention program and emergency plan to require sitespecific risk assessments of excavators plans, and implement procedures to effectively manage the risk, such as increased surveillance of excavator actions to protect the pipeline and ensuring that gas shut-off valves are tested so that they can be closed promptly if the pipeline is damaged. (P-07-5) To the International Association of Fire Chiefs: Notify your members of the circumstances surrounding the Dec 13, 2005, accident in Bergenfield, NJ, and urge them to establish and implement procedures for emergency responders to rapidly assess situations involving natural gas leaks and to determine whether prompt evacuations are warranted. (P-07-6)
http://www.ntsb.gov/investigations/reports_pipeline.html http://www.ntsb.gov/investigations/fulltext/PAB0702.htm
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Anhydrous ammonia is classified in 49 Code of Federal Regulations (CFR) Part 195 as a highly volatile liquid. Anhydrous ammonia is transported as a liquefied gas in a pipeline and, when released, will immediately return to a gaseous state and rapidly expand. It is a hazardous liquid that is highly corrosive and toxic, and its vapors also are extremely irritating and corrosive. Anhydrous ammonia may be fatal if inhaled, ingested, or absorbed through the skin.
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Enterprise = Enterprise Products Operating L.P. EPA = U.S. Environmental Protection Agency. Magellan = Magellan Midstream Partners, L.P. NTSB = National Transportation Safety Board PHMSA = US Pipeline and Hazardous Materials Safety Administration SCADA = supervisory control and data acquisition. Williams = Williams Companies, Inc., the owner and operator of the pipeline, prior to Magellan being owner, and Enterprise being operator.
NTSB report provides technical detail about the pipe which ruptured. The pipe segment that ruptured was removed and sent to NTSBs Materials Laboratory for examination and testing. The segment had four external gouges. 18 The approx 11.7inch-long rupture occurred at one of the gouges. Over most of the rupture length, the gouge penetrated 0.019 inch (approx 12.2 % of the pipe wall thickness) into the pipe wall. Within the gouge, shear cracks penetrated the metal. From the base of the shear crack that led to the rupture, a fatigue crack propagated toward the interior of the pipe. The fatigue crack extended approximately 0.080 inch below the shear crack with no external corrosion that resulted in a loss of material thickness. A detailed examination showed that the fatigue region had five bands, each with a different shade of gray, consistent with crack arrest marks. The area below the fatigue crack had a shear lip created during the sudden and final rupture of the pipe. An examination of a cross section of the gouge at the fracture origin area showed that metal of a different composition had transferred to the wall of the pipe. Elemental analysis of a metal tooth from the backhoe bucket owned by the property owner did not provide a unique signature when compared to the transferred metal in the gouges. The examination of the cross section revealed no manufacturing defects (such as laminations, voids, or porosity) in the pipe material. The examination of the inside surface of the pipe showed no corrosion degradation or additional cracking. While these NTSB reports are highly technical, I am getting so I can read between the lines. I conclude that SOMEONE did excavation construction work and hit the pipeline, not once but several times. The NTSB was unable to determine if that SOMEONE was the Pipeline company installation in 1973; previous owner of the property; owner of the property since 1989; someone else doing construction work, for which no records could be found. The four gouges located longitudinally along the top half of the pipeline are consistent in shape and location with the type of mechanical damage caused by excavation equipment such as a backhoe.
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NTSB concludes that heavy equipment damage to the pipeline during construction or subsequent excavation activity created a pipe gouge that initiated metal fatigue cracking and led to the eventual rupture of the pipeline.
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that solved the problem. He expected that in 10 to 15 minutes, he would get more info to see if problem solved, or further analysis of alarms needed. 11.48 p.m., phone call arrived from 911 dispatch, was first pipeline controller knew there was a rupture, so he immediately started shutting down the pipeline. 12.15 p.m., he reported situation to his superiors, who were too busy to do anything about it, so they passed buck back to the controller to initiate required reporting to the government.
The controller who operated the pipeline during the accident started at Enterprise as an area operator and was promoted to operations supervisor in the field in 1996. He took controller training, consisting of classroom study of company procedures and manuals, operations, SCADA information retrieval, and site-specific information. He functioned as a pipeline scheduler from 1997 until 2003. In February 2003, he began on-the-job controller training. Enterprise assessed the effectiveness of his training by testing his knowledge and observing his actions in operating pipelines. He completed refresher training on May 21, 2003. His training included the study of procedural and training manuals for the ammonia pipeline. The study material explained how to respond to abnormal conditions and use trend screens with graphical displays. He successfully completed written examinations covering this material on September 13, 2003, and was qualified by Enterprise to operate the pipeline. Enterprise did not have a pipeline simulator for controller training but did use noncomputerized simulations in post accident controller training sessions in 2001. Review of non-computerized simulations of accidents is not a requirement listed in Enterprises training program. Enterprises procedure manual defined an abnormal operating condition as any condition that may cause, create, or contribute to a situation which exceeds the design or normal operating parameters of the pipeline. The manual instructed controllers to treat an unexplained variation in pressure or flow as an abnormal operating condition. It also instructed controllers to continue to monitor pipeline operations and follow specific steps that include checking with others involved with the operations to determine the cause of the variation and to be especially attentive for any sign that an emergency condition may follow. To investigate a variation in pressure or flow, control room personnel were to notify oncall field personnel or supervisors; review flow data; check instantaneous line balance by comparing simultaneous meter readings at point of origin, destination, and intermediate locations; and contact customers for possible explanation of the pressure or flow variation. If a logical reason for a variation could not be determined, the control room operator was to shut down the pipeline and monitor pressure. 16 Critical Infrastructure disasters 2007
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Enterprises draft Natural Gas Liquids Pipeline Control Operations and Maintenance Training Manual19 also contained information regarding the monitoring and control of anhydrous ammonia pipelines. The manual noted that rate-of-change alarms usually occur at the onset of an abnormal condition or a pipeline leak. Controllers were instructed to investigate all rate-of-change and parameter alarms immediately, and they were advised that if an alarm resulted from a known cause, the pipeline system in the area of the alarm would stabilize in a short period of time. If the cause of a rate-of-change or parameter alarm was not readily apparent and the alarm was accompanied by one or more indications of a product release, or the pressure or flow failed to stabilize, controllers were instructed to shut down and block in the line segment. If a sudden unexplained decrease in operating pressure without a corresponding increase in flow rate was observed, the controller was instructed to shut down and block in the line segment for 30 minutes and then observe the line segment for any sign of a leak. Controllers were instructed during training to use trend screens to monitor the pipeline pressure and, if the pressure continued to fall or did not stabilize, to perform an emergency shutdown. This procedure was included in the training manual. The alarm response matrix in the training manual described the SCADA alarm color scheme and listed a rate-of-change alarm as a high-level alarm. The matrix also indicated that rate-ofchange alarms for pressure and flow (high-level, immediate attention) were shown in red on the SCADA screen and that these alarms indicated a possible line break. Enterprise defined an emergency as a significant change from steady state operating conditions that could include an accidental release of hazardous vapors or liquid s from a pipeline causing a hazardous situation. When a controller determined that an emergency existed, the manual required him to shut down pumps that feed the affected facility and close the nearest upstream remotely operated block valve. Pump stations downstream of the facility were to remain operating until they shut down on low flow, and then the nearest remotely operated downstream block valve was to be closed. The controller also was to notify identified personnel within the company as well as customers and emergency response agencies. Enterprises Procedural Manual for Operations, Maintenance, and Emergencies stated that operations personnel are accountable for telephoning a report of an accident to the National Response Center. The procedure repeats the requirements for telephonic reporting in 49 CFR 195.52. Enterprises draft Natural Gas Liquids Pipeline Control Operations and Maintenance Training Manual stated that its reporting contractor would do all reporting of releases and accidents to Federal, State, and local authorities for Magellans ammonia pipeline, and that the Enterprise field supervisor was responsible for reporting releases and accidents to the contractor.
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Enterprise did not have a policy about who was responsible for deciding whether to send an additional report to the National Response Center in order to comply with the August 30, 2002, PHMSA advisory bulletin urging operators to update a telephonic report with significant new information, including a change in the estimate of the release volume. Before the accident, Enterprises central region operations manager had supplemental reporting guidelines drafted for training field personnel. The operations managers objective was to improve timely reporting of accidents in his region, using the reporting contractor. The guidelines identified reporting responsibilities and included a list of questions that the contractor would ask. However, the guidelines did not address how to estimate the quantity of product released or how to make a dollar estimate of damages. The draft guidelines were used in a training session conducted during a quarterly safety meeting in the quarter ending March 31, 2003. The draft guidelines, Release Reporting Roles and Responsibilities, dated June 3, 2003, was the last update of the draft.
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pipeline. Enterprise has not made non-computerized simulations a part of its recurrent training program. Enterprise developed a new telephonic reporting procedure, dated January 20, 2006, for estimating the amount of product released and related damages based on pipeline physical characteristics and available operating data. When sufficient operating data are not available for anhydrous ammonia pipelines, the initial release amount to be reported will be the quantity of product contained between the valves closed on either side of the leak. The procedure also addresses a potential delay in telephonic reporting for releases that exceed the EPA reportable quantity. Specifically, to expedite the reporting to the National Response Center, Enterprise now requires the employee who reports the release to the reporting contractor to stay on the phone with the reporting contractor while the report is made. Enterprise also has designated company employees who will supply telephonic updates, as necessary, to the National Response Center. Since the accident, Enterprise has revised its risk assessment model to incorporate a pipeline leak history factor in its risk assessment calculation. It also has revised its baseline assessment of pipeline segments using all risk factors to schedule baseline assessments.
NTSB Recommendations
As a result of its investigation of the October 27, 2004, anhydrous ammonia pipeline accident, the NTSB made multiple safety recommendations. For more information about these recommendations, see the safety recommendation letters20 16 to the recipients. To PHMSA: Require in 49 Code of Federal Regulations 195.52 that a pipeline operator must have a procedure to calculate and provide a reasonable initial estimate of released product in the telephonic report to the National Response Center. (P-07-7) Require in 49 Code of Federal Regulations 195.52 that a pipeline operator must provide an additional telephonic report to the National Response Center if significant new information becomes available during the emergency response. (P-07-8) Require an operator to revise its pipeline risk assessment plan whenever it has failed to consider one or more risk factors that can affect pipeline integrity. (P-07-9) To Enterprise:
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These letters are available on the National Transportation Safety Boards web site.
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Provide initial and recurrent training for all controllers which includes simulator or noncomputerized simulations of abnormal operating conditions that indicate pipeline leaks. (P-07-10)
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Knowing when manufactured is important, because nothing lasts forever. Different types of materials have different lengths of time before it tends to wear out, where various industry associations have figures on what that is. This is impacted by how heavily it is used, under what pressures, temperatures, other factors. Some public utility pipes, electrical wires, etc. really do need to be replaced every few decades, before they die of old age. If you are using materials which are not labeled as to age, and where you are not doing regular inspections of the older stuff, you dont know what the risks are. When product is purchased direct from domestic manufacturer, we have assurance of the industry standard label, because the industry standard associations do regular inspections of domestic manufacturers, using their standard, to verify they are meeting it. Applying this labeling, typically adds 1 cent to the cost of something which may total a few dollars. The customer, of the manufacturer, states whether or not they want this 1 cent cost included. Consequently, there are products in the market place which do not have this supply chain traceability, opening a door to counterfeit parts, which seldom measure up to industry standards. A major source of counterfeit parts are off-shore manufacturers, who apply labels to match what the domestic market wants. For example, something actually made in China, or Mexico, may say made in USA because that is labeling desired by buyers in the USA. These counterfeit parts might also be labeled with id of whatever standard, even though they do not satisfy it, and were never subject to any inspections by the standard associations to verify anything. The original manufacturer has pricing based on volume purchased. Some distributors order in such large quantities, that they get very low prices, and are able to resell to the market place at a lower price than the manufacturer is selling to customers which order low volumes. Some of these distributors may be in foreign nations, not subject to the same standards as the domestic market. When buyers are shopping around for lowest price, it is not always obvious where the supplier is really located. In addition to the product labeling, which can be fraudulent in the case of counterfeit parts, there are also accounting records of what was supposedly purchased from what suppliers, and similarly those suppliers have records of who they sold what stuff to. The materials have a life span much longer than the requirement how long to store these records. Supply chain may be able to trace supplier, through accounting records for a few years, while the materials have a life span of a few decades. So something goes haywire, it was purchased 20 years ago, you have no way of proving where it came from. There is also hacking and insider fraud. 21 Critical Infrastructure disasters 2007
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http://www.ntsb.gov/investigations/reports_pipeline.html http://www.ntsb.gov/investigations/fulltext/PAB1001.htm
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