ENERGY TRANSFER COMPANY

Incident Narrative

ON 11/3/19 MEASUREMENT PERSONNEL NOTED INCONSISTENCIES IN VOLUME CALCULATIONS ON THE TX-107 VIOLA 8 INCH BUTANE PIPELINE. MEASUREMENT PERSONNEL BEGAN INSPECTING AND TESTING MEASUREMENT EQUIPMENT TO DETERMINE IF INCONSISTENCIES NOTED IN VOLUME WERE DUE TO EQUIPMENT ERRORS OR OTHER MALFUNCTION. ON 11/6/19 AT 21:15 THE LEAK DETECTION SYSTEM ALARMED ON THE TX-107 VIOLA 8 INCH. THE CONTROL CENTER NOTIFIED OPERATIONS AND MEASUREMENT PERSONNEL. A CREW WAS DISPATCHED TO PATROL THE ROW AND SEARCH FOR INDICATIONS OF A RELEASE HOWEVER DUE TO HEAVY RAINS AND FLOODING THE SEARCH COULD NOT BE FULLY COMPLETED THAT SAME DAY. AFTER CONDITIONS IMPROVED THE PATROL WAS RESUMED ON 11/7/19 AND AT APPROXIMATELY 14:00 THE CREW IDENTIFIED INDICATIONS OF A RELEASE, CONTACTED THE CONTROL CENTER AND THE LINE WAS SHUT DOWN IMMEDIATELY. UPSTREAM AND DOWNSTREAM BLOCK VALVES WERE CLOSED TO ISOLATE THE RELEASE. BASED UPON VISIBLE SURFACE CONDITIONS AND PRIOR TO EXCAVATION AN INITIAL ESTIMATE OF 10 BBLS OF UNINTENTIONALLY RELEASED PRODUCT WAS MADE. ON 11/7/19 THE NRC WAS CONTACTED AT 14:29 AND REPORT NO. 1263380 WAS ISSUED. THE TX RRC WAS CONTACTED AT 14:52 AND INCIDENT NO. 2089 WAS ASSIGNED. THE REQUIRED FOLLOW UP NRC REPORT WAS FILED ON 11/8/19 AT 13:42 AND REPORT NO. 1263465 WAS ISSUED. DUE TO EXTREMELY WET SURFACE CONDITIONS EXCAVATION EQUIPMENT WAS NOT ABLE TO BE FULLY MOVED IN UNTIL 11/8/19. EXCAVATION PROGRESS WAS SLOWED FURTHER BY PRESENCE OF OTHER PIPELINES IN THE SAME ROW AND PRACTICES TO ENSURE THE PRODUCT (BUTANE) DID NOT FLASH. DUE TO THE SLOW PACE OF EXCAVATION THE PIPE WAS NOT EXPOSED UNTIL 11/9/19. BASED ON OBSERVATIONS ONCE THE AREA WAS FULLY EXCAVATED AND THE PIPE EXPOSED IT WAS DETERMINED THAT THE RELEASE WAS LARGER THAN INITIALLY ESTIMATED. THE PRODUCT FORMED AN ICE BALL AND THE DIMENSIONS OF THAT ALLOWED A REVISED CALCULATION OF THE RELEASE TO BE MADE. APPROXIMATELY 2618 BBLS WAS CALCULATED TO HAVE BEEN RELEASED UNINTENTIONALLY. UPON EXAMINATION IN THE FIELD MULTIPLE EXTERNAL CORROSION PINHOLES WERE IDENTIFIED. PERMANENT REPAIR WAS MADE BY A REPLACEMENT OF APPROXIMATELY 184 FEET OF NEW PIPE AND THE PIPELINE WAS RESTARTED ON 11/21/19. A DEF/MFL ILI TOOL WAS RUN ON THE TX-107 VIOLA 8 INCH ON 10/8/19. THE VENDOR REPORT HAD NOT YET BEEN RECEIVED WHEN THE RELEASE OCCURRED. THE VENDOR FINAL REPORT WAS RECEIVED ON 12/18/19 AND INDICATED A HIGH PERCENTAGE METAL LOSS ANOMALY AT THE RELEASE LOCATION. OTHER METAL LOSS TOOL CALLS ON THE FAILED AND CUT OUT SECTION OF PIPE WERE MEASURED AND USED TO VALIDATE THE TOOL DATA. NO OTHER METAL LOSS CALLS REQUIRING TIMED REPAIRS WERE DISCOVERED IN THIS AREA. PRIOR ILI DATA SETS ARE ALSO BEING REVIEWED AND BASED ON RESULTS THE REASSESSMENT INTERVAL WILL BE CONFIRMED OR ADJUSTED. VIA FIELD TESTING AND SURVEYS, IT WAS DETERMINED THAT THE CATHODIC PROTECTION SYSTEM IN THIS AREA IS SUBJECT TO STRAY CURRENT INTERFERENCE. TO MITIGATE THE CONDITION SIX (6) NEW IMPRESSED CURRENT CATHODIC PROTECTION SYSTEMS ARE CURRENTLY BEING INSTALLED. ONCE INSTALLATION IS COMPLETE THE LINE WILL BE ALLOWED TO FULLY POLARIZE AND A CYCLED CIS WILL BE CONDUCTED. FOLLOWING THIS SURVEY A DEPOLARIZED CIS SURVEY WILL BE CONDUCTED TO ENSURE ADEQUATE AND COMPLIANT LEVELS OF CATHODIC PROTECTION ARE IN PLACE. BASED ON SURVEY RESULTS ADEQUATE CATHODIC WILL BE CONFIRMED OR ADDITIONAL REMEDIAL MEASURES IDENTIFIED AND IMPLEMENTED.