CITGO REFINING & CHEMICAL CO. L.P.

Incident Narrative

AT 10:30 AM ON 1/20/2021, VALERO PERSONNEL REPORTED TO CITGO A POSSIBLE UNDERGROUND LEAK AT THE PUBLIC DOCKS, SOUTH OF OIL DOCK #7. THE POTENTIAL LEAK WAS DISCOVERED DUE TO A STAIN ON THE GROUND. THE SUSPECTED LEAK AREA WAS NEAR CITGO'S D10 6"" LCO WASH PIPELINE AND CITGO'S D08 24-INCH CAT FEED PIPELINE, WITH SEVERAL OTHER THIRD PARTY PIPELINES IN THIS AREA. BOTH OF CITGO'S PIPELINES WERE ISOLATED AND NOT IN SERVICE AT THE TIME OF THIS LEAK DISCOVERY AND THERE WAS NO ACTIVE LEAK VISIBLE. A PRESSURE TEST WAS CONDUCTED ON THE CITGO D10 PIPELINE FIRST, DUE TO RECENT POSITIVE PRESSURE TEST DATA ON THE CITGO D08 PIPELINE. THE D10 PIPELINE WAS PRESSURE TESTED AND WAS ELIMINATED AS THE SOURCE OF THE LEAK. THE D08 24-INCH CAT FEED PIPELINE WAS THEN HYDRO TESTED ON 1/28/2021, WHICH FAILED. THIS PIPELINE HAD JUST RECENTLY PASSED A PRESSURE TEST ON 6/25/2020. THE PREVIOUS TEST CONSISTED OF A SPIKE TEST OF 139% (397 PSIG) OF THE MOP FOR AT LEAST 30 MINUTES, A PRESSURE TEST OF 125% (357 PSIG) OF THE MOP FOR AT LEAST 4 HOURS AND AN ADDITIONAL HOLD OF 110% (314 PSIG) OF MOP FOR AT LEAST 4 MORE HOURS SINCE THE ENTIRE LINE WAS NOT VISIBLE. THE PREVIOUS TIME THE D08 PIPELINE WAS UTILIZED FOR A PIPELINE MOVEMENT WAS TO TRANSFER SWEET CAT FEED FROM PUBLIC OIL DOCK #3 TO THE DEEP SEA TERMINAL INITIATED ON 11/30/2020. MAXIMUM DISCHARGE PRESSURE REACHED DURING THE TRANSFER WAS 60 PSIG AND THE TRANSFER WAS COMPLETED ON 12/1/2020. AFTER THE FAILED HYDRO TEST ON 1/28/2021, FURTHER EXCAVATION AND TESTING CONFIRMED THAT THERE WAS A PINHOLE LEAK AT A 24-INCH ELBOW IN THE CAT FEED PIPELINE AND WAS DETERMINED TO BE THE SOURCE OF THE LEAK. THE LINE HAD BEEN ISOLATED, DE-INVENTORIED AND FILLED WITH WATER AT THIS TIME FOR THE HYDRO TEST. CALLS TO THE NRC AND THE RRCT WERE MADE AT THIS TIME REPORTING THE CONFIRMATION OF THE LEAK. THE SCADA SYSTEM WAS FUNCTIONAL AND OPERATING AT THE TIME OF THE EVENT, HOWEVER, DID NOT INDICATE ANY ISSUES DUE TO THE SMALL LEAK. THE D08 LINE IS UNDER CATHODIC PROTECTION BUT NOT CATHODICALLY INSULATED FROM OTHER LINES IN DEEP SEA AREA OR PUBLIC DOCK FACILITIES AND SO INDIVIDUAL CATHODIC PROTECTION HAS NOT BEEN APPLIED. THE D08 PIPELINE WAS LAST ASSESSED FOR ATMOSPHERIC CORROSION ON 5/1/2020, WITH SOME COATING LOSS/CHALKING AND WAX TAPE DAMAGE NOTED TO BE ADDRESSED BEFORE NEXT ASSESSMENT INTERVAL. THE LEAK RESULTED IN 2.2 GALLONS (0.1 BARRELS) OF HYDROCARBON RELEASED TO SOIL. THE VOLUME WAS CALCULATED BASED ON THE AREA OF HYDROCARBON CONTAMINATION ON THE GROUND (14.1 FT2 X 0.25 INCHES DEEP). THE INVESTIGATION CONCLUDED THAT THE CAUSE OF THE LEAK WAS FAILURE OF THE BITUMASTIC COATING RESULTING IN LOCALIZED CORROSION AT THE SOIL TO AIR INTERFACE DUE TO ITS SHALLOW BURIAL DEPTH (~2 TO 3 INCHES). ADDITIONAL INVESTIGATION DETERMINED THAT THE PIPELINE WAS INSTALLED IN 1959 AND THAT APPROXIMATELY 552 FEET OF THE D08 PIPELINE (D08 IS A TOTAL OF 4,805 FEET LONG) WAS BURIED AT THIS SHALLOW DEPTH. THE SHALLOW PORTION RUNS FROM THE DOCK ROAD CROSSING TOWARD PUBLIC DOCK 7. REMEDIATION OF THE SITE HAS COMMENCED, BUT IS NOT COMPLETE DUE TO ADDITIONAL EXCAVATION ACTIVITIES STILL OCCURRING IN THE AREA AS PART OF ADDITIONAL INSPECTION, INVESTIGATION, AND REPAIR. A TOTAL OF 20 YARDS OF SOIL HAVE BEEN REMEDIATED. DUE TO THE MANY PIPELINES IN THE AREA, HYDRO-EXCAVATION WAS DETERMINED TO BE THE ONLY SAFE METHOD TO EXPOSE THE PIPELINE. AS A CONSEQUENCE, ALL SOIL BEING REMOVED FROM THE EXCAVATION HAS BEEN DISPOSED OF AS CONTAMINATED SOIL. THIS HAS SIGNIFICANTLY INCREASED ENVIRONMENTAL DISPOSAL COSTS FOR THE INVESTIGATION AND REPAIR. THE CITGO D08 24-INCH CAT FEED PIPELINE SEGMENT TO PUBLIC DOCK #7 IS STILL ISOLATED, BLINDED AND DE-INVENTORIED, AS THE PIPELINE REPAIR AND ASSESSMENT HAS NOT BEEN COMPLETED DUE TO OTHER PRIORITIES. THIS D08 PIPELINE WILL CONTINUE TO BE OUT OF SERVICE IN THIS SAFE ISOLATED STATE UNTIL RESOURCES CAN BE ALLOCATED TO COMPLETE THE REPAIR AND ASSESSMENT OF THE SHALLOW BURIED PIPE.