LOUISVILLE GAS & ELECTRIC CO

Incident Narrative

ON AUGUST 6, 2020 A GAS STORAGE WELL CASING FAILURE OCCURRED AT THE A.H. PERKINS 5 (PERKINS #5) GAS STORAGE WELL IN HARRISON COUNTY NEAR LACONIA, INDIANA, RESULTING IN A UNCONTROLLED NATURAL GAS RELEASE. AT THE TIME OF THE FAILURE, A COMPANY CONTRACTOR CREW WAS INSTALLING AN UNDERGROUND PIPELINE DRIP. THE WELL CASING FAILURE OCCURRED AT THE BOTTOM OF AN ABOVE GROUND CASING COLLAR. THE FAILURE DID NOT CAUSE ANY INJURIES OR SIGNIFICANT THIRD-PARTY PROPERTY DAMAGE. NO IGNITION OF GAS OR LIQUIDS OCCURRED DURING THIS EVENT. LG&E IMPLEMENTED ITS EMERGENCY PROCEDURES AND THE WELL WAS SUCCESSFULLY ISOLATED AND CAPPED ON AUGUST 11, 2020. DNV GL, A GLOBAL QUALITY ASSURANCE AND RISK MANAGEMENT COMPANY, WAS RETAINED TO INVESTIGATE THE WELL CASING FAILURE BY CONDUCTING A METALLURGICAL ANALYSIS AND FINITE ELEMENT ANALYSIS TO DETERMINE THE LIKELY METALLURGICAL CAUSE(S) AND IDENTIFY ANY CONTRIBUTING FACTORS. A CROSS-FUNCTIONAL INTERNAL TEAM WAS FORMED TO PERFORM AN INCIDENT INVESTIGATION. THE TEAM REVIEWED GAS STORAGE WELL DOCUMENTATION, DOCUMENTATION ASSOCIATED WITH PIPELINE DRIP REPLACEMENT, DNVGL METALLURGICAL ANALYSIS REPORT AND THE POST INCIDENT EMERGENCY RESPONSE DOCUMENTATION. THE TEAM ALSO CONDUCTED WITNESS INTERVIEWS AND PERFORMED A ROOT CAUSE ANALYSIS. THE INCIDENT INVESTIGATION TOOK PLACE DURING THE COVID 19 PANDEMIC WHICH LIMITED SOCIAL INTERACTIONS AND REQUIRED STRICT PROTOCOLS FOR ANY IN PERSON MEETINGS, INTERVIEWS, AND COLLABORATIONS. THE INVESTIGATION ULTIMATELY CONCLUDED THE PRIMARY FACTOR CONTRIBUTING TO THE FAILURE OF PERKINS #5 WAS INADEQUATE OPERATIONAL CONTROLS. SPECIFICALLY, CONSTRUCTION ACTIVITIES WERE UNDERTAKEN WHILE FIELD PIPING WAS CONNECTED TO THE GAS STORAGE WELLHEAD RESULTING IN DUCTILE OVERLOAD STRESSES ON WELL CASING FROM EXTERNAL FORCES LIKELY ASSOCIATED WITH THE INSTALLATION OF THE PIPELINE DRIP. THE METALLURGICAL ANALYSIS REPORT BY DNV GL STATED ""THE RESULTS OF THE METALLURGICAL ANALYSIS INDICTED THAT THE FAILURE OCCURRED AS A RESULT OF DUCTILE OVERLOAD FROM A SIGNIFICANT EXTERNAL BENDING OR LONGITUDINAL FORCE, LIKELY ASSOCIATED WITH EXCAVATION, AND INSTALLATION OF THE DRIP PIPING"". THE INCIDENT INVESTIGATION FOUND THESE PRIMARY FACTORS CONTRIBUTING TO THE INCIDENT INCLUDED: A. CONNECTION OF FIELD PIPELINE TO THE WELLHEAD WHILE UNDER CONSTRUCTION RESULTED IN DUCTILE OVERLOAD AND FAILURE OF THE WELL CASING PIPE. B. PIPELINE DESIGN DRAWINGS WERE NOT ACCOMPANIED BY CONSTRUCTION PROCEDURES THAT PROHIBITED CONNECTION OF FIELD PIPELINE TO THE WELLHEAD WHILE UNDER CONSTRUCTION. C. FIELD PIPELINE DRIP WAS NOT PREFABRICATED IN CONFORMANCE WITH DESIGN DRAWING. D. DESIGN DRAWINGS DID NOT INCLUDE DETAILED NOTES OR REFERENCES. D3 - COMPONENT THAT FAILED IS GAS STORAGE WELL CASING, SO PIR DOESN'T APPLY. USED DEFAULT VALUE OF ""1"". PIR IS NOT APPLICABLE TO STORAGE WELL. E2 - 3 BECAUSE THE FIELD REQUIRED A NUMERICAL VALUE WE USED THE PIPELINE SYSTEM MAOP. HOWEVER, THE WELL CASING THAT FAILED DOES NOT FALL UNDER 192.619 OR 192.620. E9 - THERE IS NOT A CHOICE FOR RESERVOIR GAS STORAGE WELL. WE CHOSE THE CLOSEST AVAILABLE OPTION. E11 - THE STORAGE FIELD INJECTION RATE AND INJECTION PRESSURE ARE MONITORED BY GAS CONTROL BUT THE INDIVIDUAL WELLS ARE NOT MONITORED. G7.5 - OQ RELATED CONSTRUCTION ACTIVITIES ASSOCIATED WITH THE INSTALLATION OF THE FIELD PIPELINE COMPONENTS RESULTED IN STRESSES IMPOSED ON STORAGE WELL CASING RESULTING IN FAILURE.