SHELL PIPELINE CO., L.P.

Incident Narrative

SHELL PIPELINE COMPANY LP IS REPORTING 58.09 GALLONS (1.38 BBL) OF OIL RELEASED AT THE SMI-128 PLATFORM, SPECIFICALLY FROM THE BASE OF THE OIL EXPORT RISER ON THE EUGENE ISLAND PIPELINE SYSTEM (BSEE SEG NO. 4006), EIPS. SHELL PIPELINE COMPANY LP (SPLC) CALCULATED THE RELEASE VOLUME FROM THE TOTAL SHEEN AREA REPORTED ON 1/24/22 (58 GALLONS) AND A BUMP TEST WAS SUBSEQUENTLY INITIATED ON 1/31/22 AND RESULTED IN A RELEASE OF 0.09 GALLONS. THE SHEEN REPORTED ON 1/23/22 RESULTED IN A FULL PIPELINE SHUT DOWN & DEPRESSURIZATION. LINE VOLUME CALCULATION INDICATED THE MAXIMUM RELEASE VOLUME OF MIXED WATER, INHIBITOR, AND CRUDE OIL AT A TOTAL VOLUME OF ~5021 BBLS, WHICH WOULD CONSIST OF 1.38 BBLS CRUDE OIL, APPROXIMATELY 2.3 BBLS OF INHIBITOR (HYDROHIB-P), AND SEAWATER. BECAUSE OF LOW AND INTERMITTENT FLOW RATES ON THE UPSTREAM PORTIONS OF THE EUGENE ISLAND PIPELINE SYSTEM, SHELL PIPELINE USED INHIBITED SEAWATER (~25,000 BBLS) TO LAUNCH AND PUSH AN IN-LINE INSPECTION TOOL IN LATE DECEMBER '21 FROM SMI-128 TO THE AUGER 12' (SEG. NO. 10221 & 11228) SUBSEA TIE-IN (SSTI) AT EI-314. WATER PICK-UP VELOCITY IN THE 20' EIPS PIPELINE (19' ID) WAS 3.6 FT/S. TYPICAL INTERMITTENT FLOW FROM SMI-128 RESULTS IN A VELOCITY OF 0.3 FT/S AND 0.4 FT/S WHEN THE SSTI FROM SMI-107 IS INCLUDED; NOT HIGH ENOUGH TO SWEEP THE SEAWATER OUT OF THE PIPELINE. THE ESTIMATED VOLUME OF SEAWATER CURRENTLY REMAINING IN THE SECTION OF PIPELINE BETWEEN SMI-128 AND EI-314 HAS BEEN DETERMINED TO BE GREATER THAN ~20,000 BBLS. EIPS WAS SHUT-IN AND ISOLATED 1/24/22 AT 08:00 IN RESPONSE TO THE REPORT TO SPLC OF A WORSENING SHEEN BY QUARTERNORTH OPERATIONS AT SMI-128A, THE ORIGINATING PLATFORM FOR EIPS. IT WAS NOT CLEAR IF EIPS WAS THE SOURCE OF THE LEAK AT THAT TIME. ON JANUARY 26, 2022 AN ROV WAS DEPLOYED TO THE SITE FOR FURTHER INVESTIGATION. DURING THE INVESTIGATION WITH ROV IN THE EVENING, INTERMEDIATE HYDROCARBON DROPLETS WERE FOUND EMITTING FROM UNDER VARIOUS DEBRIS (PIPING VARIOUS SIZE AND LENGTHS, OLD TIRE, ROPE, ETC) FOUND DIRECTLY OVER THE LINE DURING ROV'S SURVEILLANCE INTO THURSDAY MORNING. ON JANUARY 27, 2022 SPCL STOOD UP AN IMT AND TOOK OVER RESPONSE TO THE INCIDENT. ON FEBRUARY 1, 2022 A BUMP TEST WAS CONDUCTED ON EIPS. DURING THIS TEST A SMALL AMOUNT OF HYDROCARBON WAS OBSERVED COMING FROM THE AREA OF THE VALVE ASSEMBLY, CONFIRMING EIPS AS THE SOURCE OF THE RELEASE. ESTIMATED RELEASE VOLUME WAS .09 GALLONS. (NRC #1327793) ____________ DUE TO PHMSA PORTAL ISSUE THE REPORT WAS NOT SUBMITTED ON TIME. CORRECTIVE/MITIGATIVE ACTIONS: AFTER THE INVESTIGATION, IT WAS DETERMINED THAT THE BOLTS AND END-PLATE WERE REMOVED AT SOME POINT IN THE PAST AND NEVER RE-INSTALLED. THE CHECK VALVE WAS REMOVED ALONG WITH AN ADJACENT BALL VALVE. A NEW SPOOL PIECE AND A SINGLE BALL VALVE REPLACED THIS ASSEMBLY.