Jay Inslee: Washington's 1st Congressional District
Issues
Pipeline Safety
Letter to OPS #1
January 21, 2000
Kelly Coyner
Administrator
Office of Pipeline Safety
US Department of Transportation
400 7th Street SW, Room 7128
Washington, DC 20590Dear Administrator Coyner:
Thank you for taking the time on Thursday to further discuss possible future corrective action for Olympic Pipeline Company’s 16" line. I would also like to thank you for all of the personal attention you have given this matter since the tragic accident on June 10, 1999 in Bellingham, Washington. Today, I am writing you for two reasons:
First, I again strongly urge the Office of Pipeline Safety (OPS) to immediately amend your Corrective Action Order and require Olympic Pipeline to hydrostatically test their entire 16" line from Allen, Washington to Renton, Washington.
Second, in light of the information recently uncovered by my office (see attachment), I request that your agency investigate the apparent discrepancy in the information on which OPS based its initial Corrective Action Order to not hydrostatically test Olympic Pipeline’s entire 16" line.
I have made my recommendation for hydrostatic testing based on facts and science, not emotion. This decision came after being assured that hydrostatic testing is a widely used and an acceptable method to test potential longitudinal seam failures. Based on the large number of pipelines that have operated safely after being hydrostatically tested, it is clear that this is an effective procedure.
As you recall, on October 27, 1999, when we both testified before the House Transportation Subcommittee on the subject of pipeline safety, I called on OPS to require Olympic Pipeline to hydrostatically test their problematic 16" line. Your office referred my staff to an October 19, 1999 letter addressed to Congressman Metcalf explaining OPS’ reasons for hydrostatically testing only a portion of the line.
In that letter, you stated that OPS’ decision to only hydrostatic test portions of the 16" line, which contained pipe manufactured by the Lone Star Steel Corporation, was based on "the technical functionality which assures the integrity of the longitudinal seam and our experience with low frequency, pre-1970 ERW pipe."
However, OPS’ own regulations (CFR 195.303 (d)), clearly state that "All pre-1970 ERW pipe and lapwelded pipe is deemed susceptible to longitudinal seam failures…"
As to OPS’ decision to not require hydrostatic tests on other portions of the line, which is composed primarily of pipe manufactured by U.S. Steel Corporation, you offered the following explanation:
"The remainder of the pipeline, including the U.S. Steel pipe which was manufactured using high frequency ERW method, does not have a seam failure history similar to low frequency ERW pipe."
This explanation is continuously used by Olympic Pipeline Company as to why they refuse to hydrostatic test the entire line.
My office found information from your web site archives that seems to contradict the basis for OPS’ decision to not hydrostatically test the entire 16" line. Please see the tables enclosed. (This information was sent to your staff earlier today. It is my understanding that they are still evaluating it). The tables compare the number of failures of electric-resistance longitudinal welded pipes manufactured by U.S. Steel Corporation, and pipe manufactured by Lone Star Steel from 1970 to mid 1984 on gas pipelines.
This information seems to contradict the assertion that U.S. Steel does not have a seam failure history for high-frequency ERW manufactured pipe. I understand that these data reflect failures in gas pipelines, however, experts in the field have assured me that the only significant factor in causing a longitudinal weld failure is the pressure inside the pipe, regardless of the contents of the pipe. Unfortunately, your agency does not collect comparable information on liquid pipeline failures; therefore we are unable to directly determine the seam failure record of U.S. Steel liquid ERW pipelines. If your agency has such information I request that you provide me with it, as well as make it available to the general public on your web site.
Your timely response to these requests is very much appreciated. As you know, OPS’ Corrective Action Order does not prohibit Olympic Pipeline from restarting their problematic 16" line at any time – this causes great concern for the communities I represent.
Very Truly Yours,
Jay Inslee
Member of Congress