COLONIAL PIPELINE CO

Incident Narrative

ON 9/8/2020, A PIPELINE CREW WAS PREPARING FOR THE LINE 03 - UNIT 2 CHECK VALVE CUTOUT AT BEL AIR STATION. AT 13:52 (LOCAL), THEY NOTICED A SHEEN IN THE UNIT 2 CHECK VALVE EXCAVATION, SUSPECTED TO BE RESIDUAL PRODUCT FROM A HISTORICAL LEAK. THIS SHEEN WAS NOT PRESENT EARLIER IN THE DAY. THE COLONIAL CREW INSPECTOR NOTIFIED THE DORSEY FACILITY OPERATOR OF THE SHEEN, WHO THEN NOTIFIED ALPHARETTA CONTROL CENTER AT 13:54. THE INSPECTOR CONTINUED TO PERFORMING ADDITIONAL INVESTIGATION IN THE STATION. THE ALPHARETTA CONTROLLER SHUT DOWN LINE 03 - UNIT 1 AT BEL AIR STATION AT 13:59. AT 14:04 THE ALPHARETTA CONTROL CENTER, LEAD CONTROLLER, CALLED THE INSPECTOR AND THE INSPECTOR DID CONFIRMED PRODUCT/WATER MIX IN THE WELLS AROUND LINE 03 - UNIT 3. ALPHARETTA CONTROL CENTER INITIATED CONTROLLED SHUT DOWN SEQUENCE AT 14:06 OF LINE 03 (MAINLINE). SHORTLY THEREAFTER, THE CREW ON SITE BEGAN TO EXCAVATE AROUND UNIT 3. LOCAL ER TEAM WAS MOBILIZED TO SITE AND BEGAN SETTING UP ICS FOR RESPONSE. UNIT 3 PIPING WAS EXCAVATED DURING THE RESPONSE PHASE AND THE POINT SOURCE WAS DETERMINED TO BE 6-INCH DIAMETER LOOP DRAIN LINE PIPING OF UNIT 3. THE PIPING WAS DISCONNECTED FROM THE STATION LOOP PIPING AND A FLANGE WAS INSTALLED AND THE DAMAGED SECTION OF THE DRAIN LINE WAS CUTOUT AND REMOVED. ONCE REPAIR WAS COMPLETED THE STATION WAS READIED FOR LINE 03 STARTUP. THE LINE 03 STARTED UP ON 9/11/20 AT 20:01 (LOCAL) TO ALLOW THE STATION TO BE PRESSURED FROM THE MAINLINE AND ALLOW VENTING TO READY THE STATION FOR STARTUP. AFTER VENTING, THE STATION WAS THEN UNLOCKED AND RETURNED TO NORMAL OPERATIONS ON 9/11/20 AT 20:49. DURING THE RESPONSE AND POST RESPONSE, ALL FREE PRODUCT AND WATER WERE REMOVED VIA VACUUM TRUCKS AND PLACED IN ON-SITE FRAC TANKS. THE FREE PRODUCT AND CONTAMINATED SOILS WERE LOCALIZED AND CONTAINED ON SITE. NO PRODUCT WAS IDENTIFIED IN THE OWS OR ON THE SITE POND. ALL EXCAVATED CONTAMINATED SOILS WERE SEGREGATED AND WERE PLACED IN EITHER LINED ROLL OFFS OR SEGREGATED IN STOCKPILES ON PLASTIC FOLLOWING BMPS FOR SOIL CONTAINMENT. DURING POST RESPONSE ACTIVITIES CONTAMINATED SOILS WERE EXCAVATED UNDER THE DIRECTION OF ENVIRONMENTAL AND IN COOPERATION WITH THE MARYLAND DEPARTMENT OF ENVIRONMENT. ALL REQUIRED SOILS WERE EXCAVATED AND WILL BE HAULED OFF SITE TO THE DISPOSAL/RECYCLING FACILITIES AS DIRECTED BY ENVIRONMENTAL. ALL PCW IS ON SITE AND WAITING ON DIRECTION FROM ENVIRONMENTAL FOR DISPOSAL/RECYCLING. 03-26-2021 UPDATE: COLONIAL CONDUCTED AN INCIDENT ANALYSIS OF THIS EVENT AND CONCLUDED THAT THE PRIMARY CAUSE OF THE LEAK WAS MATERIAL FAILURE - A SMALL PIN HOLE WAS DISCOVERED AT THE BOTTOM OF THE DRAIN LINE FROM LINE 03 - UNIT 3. THE HOLE WAS A RESULT OF INTERNAL CORROSION ON THE 6 INCH DRAIN LINE. THE CUT OUT PIPE WILL BE SENT OFF FOR LAB ANALYSIS. ALL ACCESSIBLE SOILS WERE HAULED OFF SITE TO DISPOSAL/RECYCLING FACILITIES. ALL PETROLEUM-CONTAMINATED WASTE (PCW) WAS SENT FOR OFF-SITE DISPOSAL/RECYCLING. THE UPDATED VOLUME WAS CALCULATED FROM SCALE TICKETS AND LABORATORY ANALYSES OF SOIL EXCAVATED AND SOIL BORINGS. THE COST ESTIMATES HAVE BEEN UPDATED. 2/7/22 UPDATE: COLONIAL CONTRACTED THE SOUTHWEST RESEARCH INSTITUTE (SWRI) TO ANALYZE PORTIONS OF THE REMOVED DRAIN SYSTEM AND EVALUATE THE CAUSE OF THE LEAK. SWRI DETERMINED THAT THE LEAK WAS A RESULT OF INTERNAL CORROSION MOST LIKELY CAUSED BY MICROBIOLOGICALLY INDUCED CORROSION (MIC). COLONIAL MITIGATED THE RISK OF FUTURE LEAKS BY REPLACING THE ENTIRE DRAIN SYSTEM AND ESTABLISHING A PERIODIC FLUSHING PROGRAM. IN PART TO THE INVESTIGATION EVENTS DISCUSSED ABOVE, THE ENVIRONMENTAL TEAM FOUND NO INDICATION OF A HISTORICAL LEAK. THE LAB ANALYSIS ASSOCIATED TO THIS UPDATE WAS RECEIVED AFTER AN INITIAL ANALYSIS ATTEMPT WAS REJECTED DUE TO SAMPLING ERROR, THEREBY CAUSING DELAY IN THE CLOSURE OF THIS INCIDENT. COLONIAL CONTINUES TO DEVELOP PROCESSES RELATIVE TO A FLUSHING PROGRAM IN ACCORDANCE WITH DEVELOPING PROCEDURES AND APPLYING LESSONS LEARNED TO MITIGATE REOCCURRENCES