KINDER MORGAN TEXAS PIPELINE CO

Incident Narrative

AT APPROXIMATELY 12:00 PM ON DECEMBER 12, 2019, A KINDER MORGAN TEXAS PIPELINE LLC (KMTP) EMPLOYEE ARRIVED AT THE KMTP CEDAR BAYOU TANK SITE TO PERFORM REGULARLY SCHEDULED OPERATIONS AND MAINTENANCE WORK. AT APPROXIMATELY 12:15 PM, THE EMPLOYEE NOTICED NATURAL GAS LEAKING OUT OF A BREATHER FITTING ON A COMPONENT OF THE ACTUATOR ON THE 10-INCH PRIMARY REGULATOR. THE EMPLOYEE CALLED HIS SUPERVISOR WHO THEN INITIATED THE INTERNAL EMERGENCY RESPONSE LINE (ERL) NOTIFICATIONS PER COMPANY PROCEDURES TO DISCUSS THE NATURAL GAS RELEASE EVENT. DURING THE CALL IT WAS DETERMINED THAT THE AMOUNT OF GAS LOSS DID NOT MEET THE INCIDENT REPORTING CRITERIA AND REPAIR COSTS WERE NOT EXPECTED TO REACH THE $50,000 REPORTING THRESHOLD. THERE WERE NO INJURIES OR PROPERTY DAMAGE ASSOCIATED WITH THE LEAK. IN ORDER TO SECURE THE LOCATION, THE EMPLOYEE CHANGED PRIMARY REGULATION FROM THE LEAKING REGULATOR TO A SECONDARY REGULATOR IN ORDER TO CONTINUE SUPPLYING GAS TO DOWNSTREAM CUSTOMERS. ONCE THE SECONDARY REGULATOR PICKED UP THE LOAD, THE UPSTREAM MONITOR VALVE AND DOWNSTREAM ISOLATION VALVES ON THE LEAKING PRIMARY REGULATOR RUN WERE SHUT AND SECURED USING COMPANY LOCKOUT/TAGOUT (LOTO) PROCEDURES ISOLATING THE PRIMARY REGULATOR RUN. THE PRIMARY REGULATOR RUN WAS THEN ALLOWED TO BLEED OUT TO ATMOSPHERE THROUGH THE BREATHER FITTING AND BODY BLEED ON THE PRIMARY REGULATOR. ON DECEMBER 16 AT APPROXIMATELY 10:00 AM, AFTER FURTHER INVESTIGATION AND REPAIR EVALUATION, FIELD OPERATIONS DETERMINED THAT THE COSTS OF REPAIR WOULD LIKELY EXCEED THE $50,000 REPORTABLE THRESHOLD. THE COSTS OF ESTIMATED REPAIRS HAD INCREASED BECAUSE THE EXCAVATION COSTS TO EXCAVATE THE BELOWGROUND REGULATOR EXCEEDED THE ORIGINAL ESTIMATE. A FOLLOW-UP ERL NOTIFICATION WAS INITIATED AND DURING THE CALL IT WAS DETERMINED THAT NOTIFICATION TO THE NRC AND RAILROAD COMMISSION OF TEXAS SAFETY DIVISION WAS REQUIRED. TRRC INCIDENT REPORT 2105 48 HOUR NRC REPORT 1266704 INITIALLY IT WAS DETERMINED THAT THE LEAKAGE WAS CAUSED BY BROKEN STEM SEALS ON THE PRIMARY REGULATOR. AFTER REPLACING THE STEM SEALS THERE WAS STILL SOME SMALL LEAKAGE DETECTED. AFTER CONSULTING WITH THE VALVE SERVICE COMPANY AND FURTHER INSPECTING THE VALVE STEM, IT WAS DETERMINED THAT THE VALVE STEM NEEDED TO BE REPLACED. THE NEW VALVE STEM WAS REPLACED ON FEBRUARY 3, 2020 AND AFTER PURGING, PACKING, AND OPERATING THE REGULATOR IT WAS CONFIRMED THAT NO LEAKAGE REMAINED.