SHELL PIPELINE CO., L.P.

Incident Narrative

WHAT HAPPENED: ON 2/12/2020, THE USCG NOTIFIED THE SHELL ROW TECHNICIAN ABOUT A POSSIBLE RELEASE ON THE NORCO 8INCH PRODUCTS PIPELINE NEAR INTERSTATE 10 MILE MARKER 217. THE PIPELINE WAS SHUT-IN. FOLLOW-UP INSPECTION DISCOVERED THAT APPROXIMATELY 260BBL OF THE PRODUCT HAD SLOWLY RELEASED FROM THE PIPELINE OVER AN ESTIMATED 14 TO 45 DAYS, IMPACTING LOCAL VEGETATION. THE ENVIRONMENTAL IMPACT WAS LIMITED TO THE IMMEDIATE AREA SURROUNDING THE PIPE. INSPECTION OF THE PIPELINE IDENTIFIED MULTIPLE AREAS OF PHYSICAL DAMAGE CAUSED BY AN IMPACT FROM AN UNKNOWN SOURCE. ONE DENTED AREA CONTAINED A 1.0-CENTIMETER STRESS CRACK, WHICH ALLOWED THE PRODUCT TO RELEASE TO THE ENVIRONMENT SLOWLY. WHY IT HAPPENED: KEY CAUSAL CHAINS - EVIDENCE SUGGESTS THAT DURING DEMOBILIZATION FROM A PREVIOUS REPAIR EXCAVATION THAT WAS COMPLETED IN JUNE 2019, THE EQUIPMENT OPERATOR LIKELY BECAME DISORIENTED REGARDING THE LOCATION OF THE PIPELINE AND CONTACTED THE PIPELINE WHILE USING THE EXCAVATOR TO PUSH BARGES THROUGH THE MARSH. - THE DAMAGE (STRESS CRACK) WORSENED AND LEAKED PRODUCT OVER A PERIOD OF 14 - 45 DAYS. SHELL PIPELINE WAS UNAWARE THAT THE PIPELINE HAD BEEN DAMAGED UNTIL 2/12/20 BECAUSE: O THE POINT OF FAILURE WAS COVERED (HIDDEN) BY DENSE MARSH VEGETATION AND THICK MUD SLURRY. (AND) O AT THE COMPLETION OF THE JUNE 2019 EXCAVATION WORK, FINAL INSPECTION OF THIS PARTICULAR EXCAVATION SITE, THE POINT OF REPAIR AND CONCLUDED THE PIPELINE WAS READY FOR OPERATION PRIOR TO DE-MOBILIZATION. O IN RESPONSE TO COMMUTER REPORTS OF AN ODOR BEGINNING IN DECEMBER 2019, MULTIPLE INSPECTIONS OF THE EXCAVATION SITE WERE PERFORMED BY THIRD PARTIES, WHICH CONCLUDED THE ODOR WAS FROM A SOURCE OTHER THAN THE NORCO 8INCH PL. THIRD PARTY DID NOT NOTIFY SPLC OF THESE ODOR REPORTS. O SCADA DATA INDICATED THE PIPELINE WAS OPERATING WITHIN NORMAL PARAMETERS BECAUSE THE LEAK RATE WAS LOWER THAN THEIR ABILITY TO DETECT (I.E. >20BBL/HR).