CITGO REFINING & CHEMICAL CO. L.P.

Incident Narrative

ON APRIL 6, 2020, THE E05 ULSD PIPELINE WAS ISOLATED, DE-INVENTORIED AND BLINDED IN PREPARATION FOR THE PIPELINE'S 5-YEAR DOT ASSESSMENT BY HYDRO-TEST. THE HYDRO-TEST FOR THIS PIPELINE WAS TO BE CONDUCTED IN THREE SEGMENTS. THE EAST-SIDE SEGMENT WAS COMPLETED ON APRIL 12TH AND WEST-SIDE SEGMENT WAS COMPLETED ON APRIL 13TH. THE CENTER SEGMENT WOULD NOT HOLD PRESSURE AFTER MULTIPLE ATTEMPTS. DIFFERENT METHODS OF TRYING TO GET A GOOD HYDRO ON THE LINE WERE ATTEMPTED WITHOUT SUCCESS. THE DECISION WAS MADE TO CONDUCT A UT SMART PIG ON THE PIPELINE ON APRIL 11TH, AND THE PROCESS TO AWARD THE CONTRACT WAS STARTED WITHIN CITGO PROCUREMENT REQUIREMENTS. THE CONTRACT WAS AWARDED AND SIGNED ON MAY 6TH. CONTRACT SURVEYORS MOBILIZED ON MAY 8TH AND THE SMART PIG WAS SUCCESSFULLY CONDUCTED ON MAY 13TH. ON THE EVENING OF MAY 13TH, CITGO RECEIVED PRELIMINARY RESULTS FROM THE PIGGING CONTRACTOR THAT INDICATED THE PRESENCE OF TWO UNDERGROUND FLANGES ON THIS PIPELINE (ONE AT THE 91 AREA AND ONE AT GATE 5 AREA). ON MAY 18TH, CITGO STARTING HYDRO-EXCAVATING/POT-HOLING THE AREAS IN QUESTION IN ORDER TO LOCATE THE UNDERGROUND FLANGES FOR INSPECTION AND REMOVAL. ON MAY 20TH, IT WAS DETERMINED THAT ONE OF THE POTHOLES AT THE 91 AREA HAD DEVELOPED A LAYER OF DIESEL IN IT AT A DEPTH OF ~18 FEET BELOW GRADE. WITH THE E05 PIPELINE OUT OF SERVICE FOR TESTING, THE SOURCE OF THE LEAK COULD NOT BE DETERMINED AT THAT TIME. HYDRO-EXCAVATION CONTINUED AT THE 91 AREA TO LOCATE THE UNDERGROUND FLANGES, WITH NONE OF THE OTHER POTHOLES INDICATING ANY SIGN OF DIESEL. WHEN THE FLANGES WERE LOCATED AT BOTH LOCATIONS, LARGE EXCAVATIONS, UTILIZING HYDRO-EXCAVATION TECHNIQUES, WITH THE PROPER SHORING WERE INSTALLED FOR THE INSPECTION AND REMOVAL OF THE FLANGES. OVER TIME, THE EXCAVATION AT THE 91 AREA WAS LEACHING IN DIESEL INTO THE SHORE BOX. THIS MATERIAL WAS PUMPED OUT PERIODICALLY INTO FRAC TANKS FOR CONTAINMENT. WITH THE FLANGES EXPOSED ON JUNE 10TH, A HYDRO-TEST WAS CONDUCTED AND INDICATED THAT THE FLANGE AT THE 91 AREA WAS LEAKING. ON THE EVENING OF JUNE 10TH, NOTIFICATION OF ALL AGENCIES WAS CONDUCTED, WITH THE COAST GUARD AND TGLO MAKING A SITE VISIT THAT EVENING. THE TCEQ AND RRCT CONTACTED US ON JUNE 11TH AND TCEQ ALSO VISITED THE SITE. TWO DEWATERING WELLS AND A RECOVERY SUMP WERE INSTALLED IN CLOSE PROXIMITY TO THE EXCAVATION AT THE 91 AREA TO LOWER THE GROUNDWATER TABLE AND PREVENT HYDROCARBON LEACHING INTO THE SHORE BOX. THIS ALLOWED MAINTENANCE TO SAFELY ENTER THE SHORE BOX TO REMOVE THE UNDERGROUND FLANGES. DELINEATION AND REMEDIATION ACTIVITIES WILL BE PERFORMED PER THE TCEQ 30TAC SPILL RULES OR TEXAS RISK REDUCTION PROGRAM (TRRP-13) AS REQUIRED. THE FLANGES AT THE GATE 5 AREA AND 91 AREA HAVE BEEN REMOVED AND REPLACED WITH PIPING SECTIONS. AN INCIDENT INVESTIGATION WAS CONDUCTED AND DETERMINED THAT THE ROOT CAUSE FOR THE LEAK WAS AN OUT-DATED PIPING DESIGN. THE E05 - ULSD PIPELINE WAS RETURNED TO SERVICE ON 7/31/2020.