SCM OPERATIONS, LLC

Incident Narrative

AT 4:31 AM SATURDAY MORNING (2/13/21) SCM OPERATIONS, LLC'S 3RD PARTY CONTROL ROOM (MIDSTREAM INTEGRITY SERVICES) RECEIVED A PROPANE HI ALARM FOR THE BRANDYWINE NGL METER STATION. MIS IMMEDIATELY IMPLEMENTED SCM CALLOUT PROTOCOL AND SUCCESSFULLY REPORTED THE ALARM TO SCM LEAD PIPELINE OPERATOR AT 4:48 AM. SCM LEAD PIPELINE OPERATOR NOTIFIED SCM LEAD MEASUREMENT TECHNICIAN AT 5:00 AM. AT 5:30 AM SCM LEAD MEASUREMENT TECHNICIAN, ACKNOWLEDGED RECEIPT OF THE NOTIFICATION. WEATHER AND ROAD CONDITIONS AT 5:30 AM WERE DETERMINED TO BE HAZARDOUS DUE TO THE ONGOING WINTER STORM (SNOW AND ICE) AND, THEREFORE, UNSAFE FOR TRAVEL TO THE BRANDYWINE SITE. THE SYSTEM CONTINUED TO BE MONITORED BY THE MIS CONTROL ROOM. NO ADDITIONAL ALARMS OR ABNORMAL OPERATING PARAMETERS OCCURRED AT THE SITE. WEATHER CONDITIONS CONTINUED TO BE EVALUATED BY SCM OPERATIONS PERSONNEL AND WERE DISPATCHED TO THE SITE AS SOON AS ROAD CONDITIONS ALLOWED, APPROXIMATELY 9:00 AM. UPON ARRIVAL AT THE SITE AT 9:20 AM SCM PERSONNEL SAW FROST ON THE PROVING LOOP OF THE METER STATION AND CONCLUDED THERE WAS AN NGL LEAK. SUCH OBSERVATION IS CONSIDERED CONFIRMED DISCOVERY OF THE LEAK AND WAS MADE AT APPROXIMATELY 9:20 AM. THE SOURCE OF THE LEAK WAS DETERMINED TO BE A LOOSE HAMMER UNION AT THE END OF THE PROVING LOOP. THE HAMMER UNION WAS SUFFICIENTLY TIGHTENED, WHICH STOPPED THE LEAK AT APPROXIMATELY 10:00 AM. SCM'S INTERNAL INVESTIGATION RESULTS DETERMINED THAT THE IMMEDIATE CAUSE OF THE LEAK WAS THAT THE PROVING ISOLATION VALVE WAS NOT FULLY CLOSED ALLOWING NGL TO REACH THE HAMMER UNION WHICH WAS LOOSE. THE ROOT CAUSE WAS A MANAGEMENT SYSTEM FAILURE TO ADEQUATELY AND COMPLETELY DEFINE AND DOCUMENT THE METER PROVING PROCEDURE IN THE METER PROVING CHECKLIST. SCM'S CORRECTIVE ACTIONS TO MITIGATE RECURRENCE ARE: 1 - MODIFY CHECKLIST - OPERATIONS TO MODIFY THE METER PROVING CHECKLIST TO INCLUDE CLOSURE AND LOCKOUT OF PROVING LOOP ISOLATION VALVES UPON COMPLETION OF METER PROVING. 2 - TRACK UPDATE - CORRECTIVE ACTION WILL BE ADDED TO FRONTLINE SYSTEM FOR THE MODIFICATION OF THE METER PROVING CHECKLIST 3 - COMMUNICATE RCA - EHS AND OPERATIONS WILL DISTRIBUTE THE ROOT CAUSE ANALYSIS AND COMMUNICATE LEARNINGS TO ALL FIELD PERSONNEL