Abstract of NTSB Public Meeting

September 4th,1996

(Text subject to editing)

Pipeline Special Investigation

Evaluation of pipeline failures during flooding and of spill response actions, San Jacinto River near Houston, Texas, October 1994

EXECUTIVE SUMMARY Between October 14 and October 21,1994, some 15 to 20 inches fell on the San Jacinto River flood plain near Houston, Texas resulting in dangerous flooding that far surpassed past flooding experience in the region. The floods forced over 14,000 people to evacuate their homes and resulted in 20 deaths.

Due to the flooding, 8 pipelines ruptured and 29 others were undermined both at river crossings and new channels created within the flood plain. More than 35,000 barrels (1.47 million gallons) of petroleum and petroleum products were released into the river. Ignition of the released products within flooded residential areas resulted in 547 people receiving (mostly minor) burn and inhalation injuries. The spill response costs were in excess of $7 million and estimated property damage losses were about $16 million.

The number of pipelines ruptured and damaged during the flooding, and the magnitude of the petroleum releases and spill response efforts again emphasize the threats posed to public safety and the environment by petroleum transportation by pipeline. Although one of the safest means for transporting petroleum, pipeline transportation also poses great risk potential to the environment because of the large volumn of hazardous liquids that can be released when a rupture occurs. Also, in a pipeline transport situation, as opposed to other transport options, there is a greater liklihood of releasing petroleum into environmentally sensitive areas. Concern about environmental consequenses of releases from pipelines have been expressed by the Congress, the States, and local interests.

The number of pipelines damaged during this flood, the volumn of petroleum and petroleum products released, and the massive quantities of personnel and equipment needed to respond to the spills prompted the Safety Board to undertake this special investigation to assess: (1) the adequacy of Federal and industry standards on designing pipelines in the flood plains, (2) the preparedness of pipeline operators to respond to threats to their pipelines from flooding and to minimize the potential for product releases, and (3) the preparedness of the Nation to minimize the the consequences of petroleum releases. The report also addresses the need for effective operational monitoring of pipelines and for the use of remote or automatic operated valves to allow for the prompt detection of product releases and rapid shutdown of failed pipe segments.

As a result of its investigation, the Safety Board made nine safety recommendations: one to the Research and Special Programs Administration, five to the National Response Team, and one each to the American Petroleum Institute, the Association of Oil Pipe Lines, and the Interstate Natural Gas Association of America.

RECOMMENDATIONS

To the Research and Special Programs Administration:

Require operators of liquid pipelines to address in their Oil Pollution Act of 1990 spill response plans, identifying and responding to events that can pose a substantial threat of worst case product release.

To the National Response Team

Make your membership aware of the circumstances and nature of the events in the 1994 environmental response at Houston, tExas, specifically in regard to the need for coordinating all planning and operational activities prior to conducting in-situ burn countermeasures.
Motivate National Response Team agencies to integrate into their area contingency plans the command and control principles contained in Technical Assistance Document Incident Command System/Unified Command and encourage them to train all personel assigned management responsibilities in those principles.
Include procedures for implementing your Unified Command/Incident Command system that will ensure that alls safety-critical operations are coordinated with parties at risk.
Establish guidance calling for Federal On-Scene Coordinators to conduct a conmprehensice after action critique of each spill response to incorporate the observations of all participating agencies to identify improvements needed in equipment, communications procedures, guidence, techniques and management.
Request that Federal On-Scene Coordinators document and forward to National Response Team headquarters all "lessons learned" developed from response critiques for review and implementation nationwide as appropriate.

To the American Petroleum Institute:

Take the lead to develope, in cooperation with the Interstate Natural Gas Association of America and the Association of Oil Pipe Lines, design and construction standards adequate for pipelines to safely cross flood plains and streambeds, including the development of recommended practices for periodically reassessing crossing designs in light of changes that have occured in the flood plain or streambed.

To the Association of Oil Pipelines and the Interstate Natural Gas Association of America:

Develop, in cooperation with the American Petroleum Institute,design and construction standards adequate for pipelines to safely cross flood plains and streambeds, including the development of recommended practices for periodically reassessing crossing designs in light of changes that have occured in the flood plain or streambed.

CONCLUSIONS

The design bases of most pipelines indermined of ruptured diring the flood did not include study of the flood plain to identify potential threats; rather, operators used only general design criteria applicable at the time the pipelines were installed.
Standards for designing pipelines across flood pleains are needed to define the multiple threats posed to pipelines and to address the research, study and future considerations that must be used for designing pipelines and peiodically reecaluating the integrity of their designs during their operating life.
Most operators of pipelines crossing the San Jacinto River flood plain continued operations without evaluating the capability fo the pipeline design to withstand the threats presented by the flood.
Few pipeline operators took effective response actions during the San Jacinto flood to minimize the potential for product releases.
Pipeline operators would have been more likely to have implemented early shutdown and or purging of products frompipeline segments crossing the San Jacinto flood plain had the Research and Special Programs Administration required tehm to develop plans for responding to substantial threats of a pipeline failure and product discharge.
The response by local, State and Federal government agencies to the flood emergency was well managed and effective.
Failed liquid pipelines continue to release excessive volumns of petroleum and liquid products into the environment because the Research and Special Programs Administration has not established requirements for rapid detection and shutdown of failed pipe segments, and the liquid pipeline industry has not incorporated means for rapidly detecting, locating and shutting down failed pipeline segments.
Risks to workers and the public were increased significantly when the unified command conducted an in-situ burn without having in place appropriate checks and balances to ensure that approved procedures and requirements were followed explicitly.
Spill management personnel responding from other regions of the country and trained on different incident command procedures created communications, command and control difficulties because they were not familiar with the incident command structure and procedures in use in the Galveston Bay Area.
Implementation of the unified incident command structure and operational principles in the NAtional Response Teams Technical Assistance Document Incident Command System/Unified Command will enhance the overall preparedness for responding to petroleum spills.
Many lessons on improving the area's soill response preparedness were not learned primarily because a comprehensive after action critique was not conducted.

EPA wants to end Exxon discharges

Baytown outflow target of plan

by Bill Dawson
Houston Chronical Environmental Writer
December 11,1996

The U.S Environmental Protection Agency has proposed to strip Exxon of its federal authorization to operate a vontroversial industrial discharge, which Harris County officials and environmentalists have criticized.

The Texas Natural Resourse Conservation Commission granted Exxon a state permit in May to continue the long contested discharge to Galveston Bay from its Baytown complex.

If the EPA's tentative decision on a federal permit stands, however, the company apparently would have to cease operating the discharge point as it has in the past. To discharge water pollution in Texas, a company must have state and federal permits, and stricter requirements in one take precedence over the other.

Rob Barrett, county pollution control director, said Tuesday that he believes the federal agency's action will "eliminate unnecessarry contamination of Galveston Bay and potentially protect the health and welfare of 3 million citizens who live in this region."

Rick Abraham, director of the Texans United environmental group, which has opposed the Exxon discharge for years, said Tuesday that the EPA has "taken the right action to prevent pollution and protect our public waters."

Texans United and Baytown citizens had sued Exxon over the issue in March, alleging in federal court that the company had dumped in excess of 2 billion gallons of untreated wastewater from the Baytown complex in the previous 5 years.

Exxon officials could not be reached for comment on the EPA action. Barry McBee, chairman of the state environmental commission declined to comment.

At the heart of the dispute os Exxon's occasional practice of mingling untreated wastes with its discharge of storm water to the bay.

In arguments before the state commission, county officials asked that Exxon be ordered to study whether it could feasibly stop "using the storm sewer as a chemical sewer."

Exxon told state officals that it's previous discharge violations resulted from excessive rainfall with minimal environmental damage, and that the plant improvements had reduced the possiblility of recurences.

An EPA summary of its proposed permit for Exxon says the contested discharge point should be "deleted" from the document, because overflows from the company's retention basin amounted to a "bypass" of the wastewater treatment system for the industrial complex.

Before winning it's state permit earlier this year, Exxon charges that the county pollution control officials were being "meddlesome" in advocating stricter requirements before the Texas commission. [ Click here to read that article ]

Barrett said Tuesday that the EPA's permit proposal "confirms the position we took in the first place."

New regulations could affect river residents

by Terri Juneau
The Lake Houston Sun
Thursday, January 23,1997

New regulations prohibiting the installation of on-site sewage facilities in a regulated floodway have many residents along the San Jacinto River steamed.

Beginning Feb 5, no new permits will be issued for installing septic systems in regulated floodways in Texas.

Residents of Rio Villa and Banana Bend subdivisions say they are angry that the Texas Natural Resource Conservation Commission passed these new regulations without notifying those who will be affected.

"We have found out through the grapevine tht theres new rules and nobody bothered to tell us," says Rio Villa resident Diana Hendrix. "There's been a lot of changes without even discussing this with us."

Residents further claim the rules are a way to prohibit people from living in what officials consider a flood prone area.

"It seems to us that what they're trying to tell us is they don't want any more buildings in the floodway," Hendrix says. "Basically what it means is you don't own your property. You buy it and pay taxes on it, but you can't build on it."

"The obvious intent is to run people off of the river," says Dickie Woods, owner of Banana Bend Beach in Highlands.

John Blout, who heads the Permit Division of the Harris County Engineering Department, disagrees that the TNRCC regulations were passed without notifying the public. They've been proposed for about the last seven years, he says, and meetings were held before their recent passage.

Blout admits, however, the changes may be a way to prevent people from building in a floodway.

"This is probably trying to curb people from building where they really shouldn't be," he says.

During the massive October 1994 flood, many homes and septic tanks "floated away," says Blout.

"Taxpayers have to pay for that," he says.

However, Blout says the regulations do not go into effect fo almost two weeks, so those who plan to build can get a permit now that would be valid for up to three years.

The Rio Villa Civic Association sent flyers to property owners informing them of the changes and recommending that they apply for permits before the deadline.

"The only thing we can do at this point is try to get permits for each lot," says Elvis Stulting, the civic associations outgoing president.

Stulting says that without a permit, lots worth $25000 to $30000 could become worthless.

"It's one thing to change some guidelines, but to flat take people's investment ... " Stulting trails off in frustration.

The regulations also prohibit "substantial" improvements to existion sewage facilities, but that basically means installing a new system.

The changes also create new regulations for people building in the 100-year floodplain and new certification guidelines for those that install sewage facilities.

The difference between a regular floodway and a flood plain, says Blout, is based on computer calculations.

In a flood plain, there is a chance of flooding once every 100 years, or a one percent chance the property will flood each year, says Blout.

The Federal Emergency Management Agency defines a regulatory floodway as "the channel of a river or other watercourse and the adjacent land areas that must be reserved in order to discharge the base flood without cumulatively increasing the water surface elevation more than a designated height."

Darla Branch with the TNRCC says the new rules were published in the Texas Registry Jan. 15, effective Feb 5.

She says the state is not targeting those who live on the San Jacinto River. The new regulations are statewide, and the changes will affect only new systems and installers.

Workshops are planned to explain the new regulations to property owners and other who are interested, says Branch.

A workshop is scheduled at the Leon Z. Grayson Center, 13828 corpus Christi in Cloverleaf, for Feb 10 at 2 pm. Another one will be held in Sugarland Feb. 11.

Stulting says many residents will likely attend.

"I'm sure the TNRCC will get an earful," he says.

New State Regulations Threaten existance of Banana Bend

Residents see "no-win" in sewage restrictions

by Bobby Horn JR.
Highlands Star-Courier
January 30, 1997

HIGHLANDS -- In what one Banana Bend resident termed a "clandestine move," new regulations written by the Texas Natural Resource Conservation Commission that would affect property owners along San Jacinto River will go into affect next week.

The new regulatiosn, said Raymond Anderson of the Harris County Permits Division, would prohibit the installation or substantial improvements of on-site septic systems in regulated waterways.

Anderson said the TNRCC defines regulated waterways as the channel and adjacent land that is necessary to carry and discharge water in the event of a flood.

Dickie Woods, owner of Banana Bend Beach, said the new regulations would hurt property owners along the river up to Lake Houston. By prohibiting the installation of septic systems in the 100 year flood plain, it is nearly impossible for land owners to develope their property.

Woods said property owners are put in a no-win situation because they can't develope the land without a septic system and with the new regulations, the property values will likely decrease.

This he said was a blatant attempt by the state to drive people off the river. "I don't think that you should be able to tell people where to live"

The TNRCC denied tht this was attempt to dissuade people from living in the area.

Michael Fahy, with the TNRCC's Austin office said that the new regulations were intended to clarify the provisions outlined in the the Clean Water Act. The main purposes behind the new regulations, he said, were to head off the potential dangers of septic systems washing away or leaking into the environment in the event of a major flood.

Woods said that he didn't buy the environmental argument from the TNRCC. During a flood, he noted, there is so much water that any septic release would be heavily diluted.

The main problem that Woods and other residents claim they have with the new regulations is not regulations themselves, but rather the method in which they were implimented.

Wood said that he heard about the regulations for the first time this month and he was told that eh would have until Feb. 4 to submit an application that would give him three years to to do any septic system repairs or installations. This, he said, is not enough time since the application bust be accompanied by an engineer's study of the property.

The TNRCC denied that the regulations were written to without giving residents a chance to respond. Darla Branch, with the TNRCC's Houston office, siad the regulations were under development for the last three years and that during this time comment hearings were held around the state for resident input. After these hearings, she said, the TNRCC had to address each comment made about the regulations before they could be finalized. She added that information about the regulations was also printed in the "Texas Register" as required by law.

Woods said that he was never notified about hearings in the past nor did he know anyone who was.

In responce to the new regulations, the Banana Bend Civic Club recently voted to take a position against the regulations and to write the TNRCC and area representatives, both in Austin and Washington D.C. for their assistance.

The TNRCC has planned a series of 15 workshops around the state to answer questions about the regulations.

What the New Law actually says

Texas Natural Resource Conservation Commission

Chapter 285 -- On-site Sewage Facilities
Rule Log No 95122-285-WT

(h) Flood Hazard. No new OSSF's (Ed note: On site sewage facilities) or substantial improvements to existing OSSF's shall be allowed in the regulated floodway, determined from either Federal Emergency Management Agency (FEMA) maps or a flood study prepared by a professional engineer registered in Texas. Any sites within the 100-ear floodplain, determined from either FEMA maps or flood stuies prepared by a professional engineer registered in Texas, shall be subject to special planning requirements to indicate the location of the OSSF will not result in damage to the OSSF or result in the contamination from the OSSF during flooding. Any planning materials submitted under this subsection shall indicate how possible tank floatation is eliminated.

Oil Spill test set for San JAcinto River on Saturday

Staff
The Baytown Sun
Thursday, March 6th, 1997

State officals are taking their oil-eating microbes out to breaakfast on the San Jacinto River Saturday.

The Texas General Land Office will conduct phase Three of the San Jacinto River Project beginning at 6 am at Parker's Cove, "The Liing Laboratory", on the San Jacinto River shoreline near Channelview.

The project is a small scale bioremediation study. For the study, small amounts of Arabian medium crude oil will be sprayed over several areas of the cove and then tested with bio-remediation products.

Bioremediation is the use of naturally occuring microorganisms to enhance normal biological breakdown. Microbes have been effective in cleaning oil and other hazardous materials spilled into the environment.

Parker's Vove is a 40 acre area greatly influencedby tides of the San Jacinto River. IT was heavily impacted by crude oil spilled by broken pipelines during flooding in 1994.

During spill cleanup, the site was isolated for bioremediation testing. It is the only known natural site approved for such research

Urbanization threatens Sheldon Lake

By BILL DAWSON
Copyright 1996 Houston Chronicle

Environment Writer

Sheldon Lake State Park, a popular fishing, boating and birdwatching spot, is becoming a "biological island" in the middle of an rapidly urbanizing area, its superintendent says.

Texas Parks and Wildlife Department officials say the wildlife at Sheldon is jeopardized by upstream development and drainage projects, which have greatly reduced the flow of water to the park's lake and marshes.

The park has lost about two-thirds of its watershed since 1987, mainly because of government-funded roadway and ditch construction, the agency estimates.

After months of talks at lower staff levels seeking other agencies' help, the parks department's executive director recently appealed to high-ranking officials of the Army Corps of Engineers and Texas Natural Resource Conservation Commission for help in restoring flows to Carpenter's Bayou, Sheldon's tributary.

"It's been very frustrating,"park Superintendent Robert Comstock said of the earlier discussions with other agencies. "All I'm trying to do is protect the integrity of the resources here."

"This is an important urban fishery and recreation area for an economically depressed area" of northeast Harris County, said Rollin MacRae, the agency's wetlands resource coordinator. "We could lose it all in a dry summer and this could be that summer."

Already, there are far fewer ducklings this year at the park, and a prolonged rain shortage could kill gamefish this summer and harm herons and egrets next year, department biologist Andy Sipocz said.

Alligators inhabit the swampy, cypress-studded lake, once a water-supply reservoir, and 200 bird species have been identified at the park. The tops of a few downtown skyscrapers are visible from Sheldon, where a major environmental education center is planned for area schoolchildren.

In letters to Col. Robert Gatlin, who heads Corps of Engineers operations in this region, and to Dan Pearson, executive director of the TNRCC, state parks Director Andrew Sansom identified three major public drainage projects that have had an impact on the park.

One was a city of Houston drainage ditch about two miles from the lake, he said, and another was construction of the northeast corner of Beltway 8 by the Texas Department of Transportation.

Sansom said that talks have been proceeding with state and local officials about those projects, but asked Pearson to require that water they diverted from Carpenter's Bayou be restored to it. A TNRCC spokesman said the matter was "still under review."

The other major issue cited by Sansom was construction of the West Lake Houston Parkway, a new roadway north of the park.

Although a Corps of Engineers permit issued to the Harris County Engineer's Office for the road had required that only the road itself be drained, it is "depriving the (Sheldon Lake) watershed of its legitimate flows and draining adjacent wetlands without authorization,"Sansom told Gatlin.

Corps of Engineers official Dewayne Johnson said his agency agrees that Sheldon Lake has "a problem" because of upstream projects.

The Corps is working with the County Engineer's Office toward resolving the issue and will investigate the parkway this Thursday to determine if it is draining nearby wetlands, Johnson said. The Corps regulates development in federally protected wetlands.

Terry Anderson, the Harris County engineer, said "there wasn't any violation of anything" in constructing the West Lake Houston Parkway.

He said he was surprised to learn from the Chronicle about Sansom's letters, because he thought the county, the parks agency, the Corps and Metro (which funded the parkway construction) "were all in concert" on how to address drainage concerns.

Early this year, the agencies agreed on several actions to keep water in wetlands near the roadway and out of storm sewers, Anderson said.

He said Metro was supposed to hire a new contractor to carry out this work. Metro officials familiar with the project could not be reached for comment.

Land along the West Lake Houston Parkway is being developed as the Summerwood subdivision by McCord Development Inc., which Anderson said hired consultants to design the portion of the West Lake Houston Parkway now built.

Charles Leyendecker, president and chief operating officer of McCord Development Communities, said the company is concerned about the future health of Sheldon Lake, which he called "a heck of an asset for Harris County" and "a big amenity to Summerwood."

Signs near the Summerwood entrance promote the community's "private lakes," which are visible near the West Lake Houston Parkway. Sipocz said he believes these lakes will reduce drainage into Sheldon, but Corps officials did not believe the area where they were created qualified as protected wetlands.

San Jacinto River site of testing

Scientists examine oil spill cleanup methods

by Bobby Horn, Jr.
Star-Courier Staff
March 13, 1997

HIGHLANDS -- Experiments on the natural recovery of oil spills, currently ongoing the San Jacinto River have now gained national attention, says Project Director Jim Bonner.

In 1994, after severe floods caused a pipeline to burst on the river near Highlands, Bonner, an associate professor at Texas A&M University, and the Texas General Land Office, took advantage of the accident to begin a study how the environment can naturally clean up oil spills and how the tprocess can be sped up.

The process, called bio-remediation, involves using naturally occuring microorganisms to speedup the breakdown of the oils.

After the accident, Bonner and his team began a multilevel study in which they would first study how the environment would clean it self up. Then last year, the added chemical oxidants and nutrient additives to the area to see what effect they would have on the cleanup.

The third part of the experiment, wich is expected to be started within the next week is the introduction of oil-eating microbes to the river. This along with a fresh supply of oil, will give scientist a better understanding of how nature can heal itself, said Bonner.

The experiment, which is taking place on the river, near the Interstate 10 bridge, was supposed to begin last weekend, hwever, Bonner said that weather conditions forced them to delay the introduction of the microbes.

Bonner said the expedriments were important because they give industry more knowledge of techniques that may be utilized in the case of oil spill. The use of microbes, Bonner added , is not limited to cleanup of crude il. He also noted that bioremediation was used by French Limited in the cleanup of the Sikes Superfund Site near Crosby.

Bonner said the experiments are being watched closely by colleagues across the country. "There are only two well controlled bioremediation projects of this type being conducted in the U.S. One is in Delaware, the other is on the San Jacinto River."

He added that the project not only helps the area, but gives people working on it a hands on learning experience.

Bonner noted that he has had 40 students on the projects that were using it for either Masters or PH.D post graduate work.