"BOARDWALK PETROCHEMICAL PIPELINE, LLC"

Incident Narrative

"ON JUNE 7, 2024, A CONTRACTOR WORKING FOR COLONIAL PIPELINE NOTIFIED BOARDWALK PETROCHEMICAL PIPELINE (BPP) OF A POTENTIAL LEAK ON ITS EVANGELINE PIPELINE REFERRED TO AS BPP-100. THE POTENTIAL LEAK WAS LOCATED ON THE SOUTH BANK OF THE INTRACOASTAL WATERWAY. BPP PERFORMED A LAB ANALYSIS TO CONFIRM THE LEAK WAS ETHYLENE. THE SITE WAS EXCAVATED AND A LEAK WAS DISCOVERED UNDER AN EXISTING PLIDCO CLAMP. THE LEAK WAS FOUND TO BE A VERY SMALL PINHOLE TYPE LEAK, WITH A LEAK RATE AT 0.7 LB/DAY. SINCE A REPAIR BY CUT OUT WOULD REQUIRE A PLANNED OUTAGE TO REMOVE THE PRODUCT FROM THE PIPE IN THAT SECTION, THE SITE WAS RETURNED TO ITS PREVIOUS CONDITION AND THE LEAK WAS MONITORED BI-MONTHLY UNTIL REPAIRS WERE COMPLETED. BPP DEVELOPED AN ACTION PLAN AND DISCUSSED IT IN DETAIL WITH PHMSA. THE PLAN INCLUDED REMOVING THE LEAKING CLAMP PLUS ONE (1) OTHER CLAMP BY JUNE 14, 2025. BPP CUT OUT THE PIPELINE SEGMENT CONTAINING THE LEAKING CLAMP ON JANUARY 11, 2025, AND SENT IT TO A QUALIFIED LABORATORY FOR METALLURGICAL FAILURE ANALYSIS AND ROOT CAUSE ANALYSIS. PRESSURE TESTING PERFORMED BY THE LAB AFTER THE PIPELINE SEGMENT WAS CUT OUT CONFIRMED THE PRESENCE OF A LEAK, BUT ITS EXACT ORIGIN WAS UNCLEAR. BOTH PHMSA AND PLIDCO WERE PRESENT DURING THE METALLURGICAL TESTING. UPON REMOVAL OF THE CLAMP, VISUAL EXAMINATION IDENTIFIED THAT THE LEAK WAS OCCURRING AT THE INTERSECTION OF THE CORNER OF THE LONGITUDINAL GIRDER RING AND THE CIRCUMFERENTIAL SEAL OF THE CLAMP. MANUFACTURING TOLERANCES AND REQUIREMENTS FOR THIS AREA OF THE CLAMP WERE NOT MADE AVAILABLE BY PLIDCO UPON OUR REQUEST; HOWEVER, THE AREA WAS OBSERVED AS HAVING A NOTABLY DIFFERENT APPEARANCE THAN OTHER CLAMPS THAT WERE SIMILARLY REMOVED AND EXAMINED. THE SIDE BAR GAP ON THIS SIDE OF THE CLAMP WAS OBSERVED TO BE APPROXIMATELY 1/4-INCH. THIS READING WAS GREATER THAN SPECIFIED BY THE MANUFACTURER; HOWEVER, THE LEAK PATH WAS MINOR. IT IS UNCLEAR IF RELAXATION OF TORQUE ALONG THIS SIDE OF THE CLAMP WOULD HAVE RESULTED IN THE OBSERVED GAP AT SOME TIME AFTER INSTALLATION. THE ROOT CAUSE ANALYSIS IDENTIFIED A CASUAL FACTOR OF THE MANUFACTURER'S INSTALLATION INSTRUCTIONS NEEDING IMPROVEMENT. SPECIFICALLY, THE INSTRUCTIONS FOR SIDE BAR GAPS OF ""APPROXIMATELY 1/8-INCH"" ARE TOO AMBIGUOUS. SINCE THE TIME OF INSTALLATION OF THE LEAKING CLAMP, THE MANUFACTURER HAS RELEASED MORE DETAILED INSTALLATION INSTRUCTIONS WHICH, IN PART, ADDRESS THESE SPECIFIC FINDINGS."