TEXOMA CRUDE OIL PIPELINE CO., LLC

Incident Narrative

SUPPLEMENTAL AND FINAL REPORT SUBMITTED, DUE TO ALL INFORMATION HAS BEEN GATHERED AND ENTERED IN REPORT. ON 02-15-2018 AT 12:50, LANDOWNER DISCOVERED CRUDE OIL IN WHEAT FIELD ALONG C26 ROW AND IMMEDIATELY CALLED CONTROL CENTER. CONTROL CENTER PERSONNEL SHUT DOWN THE C26 PIPELINE AT 12:50. CONTROL CENTER NOTIFIED TEXOMA COPC PERSONNEL WHO RESPONDED AND WAS ON SITE AT 13:10. SWENSON'S BACKHOE SERVICE WAS DISPATCHED TO SITE WITH A BACKHOE AND VACUUM TRUCK. 15 GALLONS OF CRUDE OIL WAS RELEASED (THIS WAS BASED ON ESTIMATE OF TEXOMA PERSONNEL ON SITE). LINE WAS UNCOVERED AND CREW INITIALLY FOUND BLACK, DEAD OIL; NOT HIGH GRAVITY LIGHT OIL. EXCAVATION DISCONTINUED OVERNIGHT AND RESUMED ON 02-16-2019. LEAK POINT WAS FOUND ON 02-18-2019. SMALL PINHOLE LEAK WAS LOCATED AT 6 O'CLOCK, DUE TO INTERNAL CORROSION. PLIDCO CLAMP WAS INSTALLED. ALL IMPACTED SOIL WAS REMEDIATED ON SITE. NOTIFICATION WAS MADE TO RRCT PIPELINE SAFETY (MIKE SHIELDS) @ 13:31 ON 02-15-2019, INCIDENT #1398. RRCT INSPECTOR PHILLIP LANDTISER CALLED BRET SHOLAR WITH TEXOMA COPC AT 14:03 ON 02-15-2019 AND SAID HE AND HIS SUPERVISOR (WHO WAS ALSO ON THE PHONE LINE) DETERMINED THAT BECAUSE THE LINE WAS AN INTERSTATE LINE AND DID NOT MEET THE REPORTING CRITERIA, THAT IT DID NOT NEED TO BE REPORTED. RRCT INSPECTOR PHILLIP LANDTISER CALLED BRET SHOLAR AT 15:04 ON 04-01-2019 AND INFORMED HIM THAT RRCT HAS NOW DETERMINED THAT THE RELEASE WAS REPORTABLE AND WANTS TEXOMA TO FILL OUT AND SUBMIT A PHMSA FORM 7100 TO PHMSA AND PROVIDE A COPY TO RRCT. DUE TO DISCOVERY OF REQUIRED REPORTING, NO NOTIFICATION WAS MADE TO THE NRC AND THIS FORM 7100 WAS NOT SUBMITTED IN A TIMELY MATTER. TEXOMA CRUDE OIL PIPELINE COMPANY'S PLAN TO PREVENT REOCCURRENCE IS AS FOLLOWS: THE INSTALLATION OF ADDITIONAL MONITORING AND COUPON LOCATIONS TO ASSIST IN THE EVALUATION OF THE EFFECTIVENESS OF THE INTERNAL CORROSION PROGRAM. WE ARE CURRENTLY IN THE PROCESS OF INSTALLING THOSE ADDITIONAL LOCATIONS. THE ADDITIONAL LOCATIONS WILL BE LOCATED AT STRATEGIC LOCATIONS ALONG C26 INCLUDING JACKSBORO STATION, JACKSBORO JCT, BOWIE STATION, AND NOCONA STATION. DATA GATHERED WILL ASSIST IN EVALUATING OUR CHEMICAL TYPE, INJECTION VOLUME, ETC. INCREASED FREQUENCY OF OUR CLEANING TOOLS. WE HAVE ALREADY INCREASED THE FREQUENCY OF OUR CLEANING TOOL RUNS TO TWICE PER MONTH. EVALUATING THE EFFECTIVENESS OF OUR CLEANING TOOLS. WE USE PRIMARILY TD WILLIAMSON WCK PIGS, A HIGH- QUALITY, AGGRESSIVE CLEANING PIG THAT WE CONSIDER ONE OF THE BEST IN THE INDUSTRY. HOWEVER, WE ARE RESEARCHING OTHER POSSIBLE OPTIONS THAT WOULD PROVIDE BETTER CLEANING RESULTS. MAINTAINING A WELL-STOCKED INVENTORY OF CLEANING PIGS. WITH THE INCREASED FREQUENCY OF OUR CLEANING TOOL RUNS, IT IS IMPORTANT THAT WE MAINTAIN AN INVENTORY OF PIGS THAT ARE READY TO RUN AT ALL TIMES. WE HAVE INCREASED OUR INVENTORY OF SPARE CLEANING PIGS AND PIG PARTS TO MEET THAT DEMAND.