The US Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) is proposing a $2,659,200 fine against ExxonMobil for what the agency details as 9 probable violations of the Pipeline Safety Regulations related to the Pegasus pipeline rupture in March 2013. (Earlier post.)
Three violations carried the highest fines ($737,200; $737,200; and $783,300). These were, respectively:
The integrity assessment schedule established by ExxonMobil did not include consideration of certain manufacturing information in the determination of risk factors, as required. Specifically, ExxonMobil failed to include the susceptibility of its Youngstown, pre-1970 low frequency electric-resistance welded (ERW) pipe seam to failures as a risk factor for the Pegasus Pipeline System in the implementation of its integrity management program.
The pipeline operator experienced multiple hydrostatic test failures on the Pegasus Pipeline as a result of ERW long seam failures in 1991 hydrotesting and subsequent 2005-2006 hydrotesting. The pipe manufacturing information, fracture toughness, and hydrostatic testing failure history of the Youngstown pre-1970 low frequency ERW pipe in the Patoka to Corsicana segments of the Pegasus Pipeline provided more than adequate information for the pipe to be considered susceptible to seam failure, according to PHMSA. Further, the operator did not present an acceptable engineering analysis to PHMSA to demonstrate that the pre-1970 ERW pipe in the Pegasus Pipeline was not susceptible to seam failure.
The operator failed to establish a five-year re-assessment interval for the Patoka to Corsicana segment of the Pegasus Pipeline after the hydrostatic test of 2005 and 2006 identified a susceptibility to seam failures. The operator failed to consider all risk factors for establishing an assessment schedule for continual integrity assessments when they did not consider the pipeline's manufacture and results of the previous integrity assessments to conclude that the pipeline was susceptible to seam failures.
The operator failed to follow its Operations and Maintenance procedures by selectively using results of its Threat Identification and Risk Assessment Manual (TIARA) process in 2011 which resulted in the failure to properly characterize the risk of a release to the Lake Maumelle Watershed, and other HCAs in the Conway to Foreman segment of the pipeline.