ENBRIDGE STORAGE (CUSHING) L.L.C.

Incident Narrative

ON MARCH 24, 2022 AT APPROXIMATELY 1:40 PM CDT, MAINTENANCE TECHNICIANS DISCOVERED CRUDE OIL ON THE WEST SIDE OF TANK 2001 AT GRANDSTAFF TERMINAL. THEY PROCEEDED TO INVESTIGATE THE SITE AND DETERMINED THE LEAK SOURCE WAS A STEADY DRIP AT THE REDUCER AT VALVE (315-V-2001A) FOR THE SUMP REINJECTION LINE. THE CUSHING CONTROL CENTER WAS IMMEDIATELY NOTIFIED OF THE RELEASE. APPROXIMATELY 19 BARRELS OF CRUDE OIL WAS RELEASED. PRODUCT HAD ESCAPED THE TANK BERM/SECONDARY CONTAINMENT DUE TO A VALVE THAT DID NOT HOLD AND MIGRATED TO A DRAINAGE DITCH THAT LED TO A CONTAINMENT POND LOCATED ON BOTH ENBRIDGE PROPERTY AND ON THIRD-PARTY PROPERTY. THE NRC WAS NOTIFIED ON MARCH 24, 2022 AT 2:29 PM CDT (REPORT #1331886). A 48-HOUR NRC NOTIFICATION WAS MADE ON MARCH 26, 2022 AT 8:59 AM CDT (REPORT #1332016). ICS WAS STOOD UP AND OSRO CONTRACTORS WERE MOBILIZED TO THE SITE TO COMMENCE THE CLEAN UP. ALL CONTAMINATED SOIL HAS BEEN REMOVED FROM THE RELEASE SITE. AFTER FURTHER INVESTIGATION IT WAS DETERMINED THAT THE RELEASE WAS DUE TO INADEQUATE INSTRUCTIONS AND PROCEDURES ALLOWING THE REMOVAL OF A LOCK AND OPENING THE VALVE TO AN ISOLATED SUMP REINJECTION LINE CAUSING A RELEASE. THE SUMP REINJECTION LINE WAS ISOLATED PRIOR TO THIS EVENT (VALVE CLOSED AND LOCKED OUT) DUE A PREVIOUSLY IDENTIFIED PINHOLE THAT WAS DISCOVERED DURING A NON-REPORTABLE RELEASE EVENT AND WAS THEN OPENED AT THE DIRECTION OF THE CONTROL CENTER OPERATOR. A RED LOCK HAD BEEN APPLIED TO THIS VALVE PREVIOUSLY, BUT A RED LOCK IS USED FOR PERSONAL SAFETY AND HAS A 7-DAY WINDOW OF USE. THOSE SEVEN DAYS HAD EXPIRED, AND PERSONAL SAFETY WAS NOT AN ISSUE AS THAT LINE HAD BEEN DRAINED UP. A BLUE LOCK AND CHAIN WITH TAG WAS WHAT WAS IN USE AT THAT TIME. ENBRIDGE INCORPORATES COLORED LOCKS FOR OPERATIONAL SECUREMENT. IN THIS CASE THE DRAINED-UP SEGMENT WAS ISOLATED WITH A BLUE OPERATIONAL LOCK. A CUSHING CONTROL CENTER OPERATOR CALLED OUT TO THE FIELD AND REQUESTED THE VALVE OPEN BASED ON THEIR DATA SCREEN NAMING CONVENTION, THROUGH INVESTIGATION IT WAS IDENTIFIED THE 2 INVOLVED VALVES WERE LABELED IN REVERSE. THE SUMP REINJECTION LINE WAS IN THE PLANNING PROCESS TO BE PHYSICALLY DISCONNECTED FROM THE SYSTEM AT THE TIME OF THE RELEASE. ADDITIONAL TRAINING OF TERMINAL OPERATIONS PERSONNEL WILL BE IMPLEMENTED TO BETTER UNDERSTAND ROLES AND RESPONSIBILITIES AND THE ABILITY TO STOP OR SLOW WORK WHEN NOT CLEAR ON ACTION OR IMPACT.