Almost four years after the Enbridge crude oil spill near Marshall, Michigan, PHMSA issued an Advisory Bulletin urging operators to evaluate their safety programs and implement changes to eliminate deficiencies identified by the NTSB’s investigation of the release.  PHMSA specifically directs operators to review integrity management programs, control center operations and public awareness plans, as recommended by the NTSB’s 2012 Pipeline Accident Report for the Marshall incident.

The Agency emphasizes the need for self-assessments in all three areas:

  • With regard to integrity management, the Agency stresses that the IM regulations are performance-based and process-oriented, and that continual improvement of analytical processes are a key objective of the IM program.  PHMSA reiterates that operators should strive to improve data integration and perform self-assessments of their IM programs in accordance with its prior Advisory Bulletin: ABD-2-12-10, “Using Meaningful Metrics in Conducting Integrity Management Program Evaluations.”  See prior pipelinelaw alert.
  • The Advisory urges operators to consider establishing control center training programs regarding recognition and response to emergency and unexpected conditions to perform periodic evaluations of leak detection capabilities including for transient operations, and to identify and implement improvements to leak detection systems following a release, in accordance with ADB 10–01, ‘‘Leak Detection on Hazardous Liquid Pipelines,’’ 75 Fed. Reg. 4134 (Jan. 26, 2010).
  • PHMSA advises operators to perform periodic self-assessments of their public awareness programs against their written public awareness plans and API Recommended Practice 1162, and to review emergency communication procedures in order to ensure a prompt, effective, and coordinated emergency response in compliance with prior PHMSA Advisory Bulletins.