SHELL PIPELINE CO., L.P.

Incident Narrative

WHILE PERFORMING DAILY CHECKS, A THIRD PARTY OPERATOR NOTICED OIL STAINING WITHIN THE DIKE OF EMPIRE STATION. SPLC WAS NOTIFIED AND REPORTED TO THE SITE. UPON ARRIVAL, CRUDE WAS OBSERVED ON THE WATERS SURFACE NEAR THE PIG TABLE. CLOSER INSPECTION CONFIRMED A SINGLE ISOLATION VALVE IN THE PIG TABLE DRAIN LINE WAS ALLOWING BYPASS. AN INITIAL ESTIMATED TOTAL OF 20 GALLONS OF CRUDE HAD DRAINED INTO THE PIG TABLE WITH 5 GALLONS SPILLING OVER. LEADERSHIP AND EMERGENCY RESPONSE COORDINATOR WERE NOTIFIED (NRC# 1239121) THE VALVE ALLOWED BYPASS DUE TO BEING WORN OUT, WITH POTENTIAL DEBRIS. THE VALVE WAS INSTALLED AS PART OF THE ORIGINAL CONSTRUCTION (2003) AND HAS NO RECORD OF BEING MAINTAINED OR REPLACED. ALL VALVES IN THIS DRAIN LINE HAVE BEEN REPLACED SINCE THE EVENT AND A SECOND VALVE HAS BEEN CLOSED TO PROVIDE DOUBLE ISOLATION TO THE PIG PAN. FUTURE ACTIONS ARE TO CONSIDER PUTTING THESE VALVES ON A PERIODIC MAINTENANCE/REPLACEMENT SCHEDULE. PIG PAN WAS LAST DRAINED ON 2/24/19. OPERATOR VISITED EMPIRE ON 3/1/19 AND NOTICED NO SIGNS OF CONCERN AROUND THE PIGGING AREA OR RAIN WATER ACCUMULATION. THE STATION ATTENDANT DID NOT OPEN THE PIG PAN COVER TO INSPECT INSIDE, SINCE IT'S ONLY INSPECTED WHEN UTILIZING THE PIG PAN, A HEAVY RAIN EVENT OCCURRED AFTER THE OPERATOR LEFT THE SITE ON 3/1/19. WHEN ARRIVING ON SITE ON 3/3/19, THE OPERATOR NOTED HEAVY WATER ACCUMULATION IN THE AREA FROM THE PREVIOUS RAIN EVENTS. THE PIG PAN IS DRAINED ONCE A WEEK WHEN PULLING SAMPLES, WHICH USUALLY TAKES PLACE ON SUNDAYS.