EQUISTAR CHEMICALS, L.P.

Incident Narrative

AT APPROXIMATELY 10:24 AM ON JANUARY 3, 2020, A CALL WAS RECEIVED IN THE EQUISTAR PIPELINE CONTROL CENTER FROM A 3RD PARTY BARGE COMPANY REPORTING AN ODOR AND POTENTIAL LEAK IN THE VICINITY OF AN EQUISTAR PIPELINE ASSET. THE AREA OF THE LEAK IS PART OF A 5-LINE PIPELINE SYSTEM BUNDLE, AND THE PIPELINE CONTROLLER IMMEDIATELY STARTED SHUTTING DOWN THE 4 IN-SERVICE LINES TO TROUBLESHOOT. NO PRIOR INDICATION OF A LEAK WAS RECEIVED BY THE PIPELINE CONTROL ROOM. A TECHNICIAN WAS DISPATCHED TO THE AREA TO INVESTIGATE THE POTENTIAL LIQUID LEAK. AFTER SAMPLE COLLECTION AND FURTHER INVESTIGATION, IT WAS DETERMINED THE LEAK WAS FROM THE 6-INCH ETHANOL PIPELINE.INFORMATION REPORTED IN PART D IS BASED ON FIELD OBSERVATIONS AT THE TIME OF DISCOVERY AND THE ASSOCIATED CLEANUP OF THE IMPACTED SOIL. NO SURFACE WATER DISCHARGE WAS OBSERVED AT THAT TIME. CONTAINMENT DIKES WERE INSTALLED TO MINIMIZE OFFSITE IMPACT DURING CLEANUP ACTIVITIES. INFORMATION REPORTED IN PART A.11. REPRESENTS THE ESTIMATED VOLUME OF COMMODITY RECOVERED FROM CLEANUP ACTIVITIES AND MANAGED AT OFFSITE DISPOSAL FACILITIES. 2020-08-05 - ON JANUARY 3, 2020 KIRBY MARINE PERSONNEL CONTACTED THE CONTROL CENTER AND REPORTED THEY DETECTED AN ODOR AND SUSPECTED THE ETHANOL PIPELINE HAD A LEAK. UPON INVESTIGATION IT WAS FOUND THAT WHEN THE ETHANOL PIPELINE WAS RESTARTED AFTER ITC CONDUCTED MAINTENANCE ACTIVITIES ON DECEMBER 10, 2019, A LEAK DEVELOPED ON THE ETHANOL PIPELINE. THE PIPELINE CONTROL CENTER DID NOT RECEIVE A LEAK DETECTION ALARM THAT A LEAK WAS OCCURRING. THE LEAK RESULTED IN A RELEASE AT A RATE OF 2.5-12.2 BBL./HR. OVER THE COURSE OF 24 DAYS ENDING ON JANUARY 3, 2020. BASED ON CALCULATIONS, APPROXIMATELY 5200 BBL. OF MATERIAL WAS RELEASED FROM THE PIPELINE. THE PIPELINE CONTROLLERS WERE UNAWARE OF THE LEAK BECAUSE THE LEAK DETECTION SYSTEM MODEL FOR THIS PIPELINE WAS UNSTABLE AND NOT COMPUTING CORRECTLY RESULTING IN A FAILURE TO ALERT THE PIPELINE CONTROLLERS TO THE LEAK. CAUSES: THE LEAK WAS CAUSED BY A CRACK IN THE PIPELINE CAUSED BY ETHANOL STRESS CORROSION CRACKING (SCC). 2020-12-03 UPDATE: THE FOLLOWING POTENTIAL CONTRIBUTING FACTORS WERE FURTHER INVESTIGATED TO DETERMINE THE ROOT CAUSE OF THE CRACK. - LYONDELLBASELL BEGAN TRANSPORTING DOMESTIC ETHANOL IN THE PIPELINE STARTING IN 2019. FINDING - EQUISTAR ENGAGED A THIRD PARTY TO TEST SAMPLES OF PIPE WITH DOMESTIC ETHANOL AND FOUND THAT THERE WAS NO SIGNIFICANT DIFFERENCE IN SUSCEPTIBILITY FOR SCC COMPARED TO BRAZILIAN ETHANOL. - CATHODIC PROTECTION (CP) LEVELS ARE OPERATED AT A HIGH LEVEL ON THIS SEGMENT OF WHICH CAN CHARGE THE STEEL WITH HYDROGEN AT LOCATIONS OF LOCAL COATING FAILURE, POTENTIALLY REDUCING RESISTANCE TO SCC. FINDING - EQUISTAR ENGAGED A THIRD PARTY TO HYDROGEN CHARGE TEST SAMPLES OF PIPE TO SIMULATE HIGH CATHODIC PROTECTION AND TEST IN ETHANOL AND FOUND THAT THERE WAS NO CHANGE IN THE SUSCEPTIBILITY FOR SCC. - THE CRACK WAS IN AN AREA IDENTIFIED AS HAVING HIGH PHYSICAL STRESS DUE TO HORIZONTAL DIRECTIONAL DRILL LOCATION AND A SLIGHT DEFLECTION. A SMALL EXTERNAL DENT/GOUGE AT THE LOCATION OF THE LEAK WOULD HAVE ADDED TO THE TOTAL STRESS. FINDING - EQUISTAR, WORKING IN CONJUNCTION WITH THIRD PARTY EXPERTS AND RESOURCES, HAVE NOT SUBSTANTIATED THIS SUPPOSITION. WHILE RESIDUAL STRESS WELDING, PIPE MISALIGNMENT AT LIMIT OF CODE ALLOWED, BEND AT LOCATION OF FAILURE, SOIL STRESS, EXTERNAL INDENTATION, AND INTERNAL PRESSURE ARE ALL POTENTIAL CAUSE OF ADDITIONAL STRESS, NONE OF THESE POTENTIAL CAUSES WAS CONFIRMED DURING THE EXTENSIVE REVIEW AND EVALUATION PERFORMED. THE PIPELINE HAS BEEN HYDROTESTED SUCCESSFULLY THIS YEAR, IN-LINE INSPECTION PERFORMED AND TESTING OF WELDS EXPOSED SHOW NO OTHER SCC.