COLONIAL PIPELINE CO

Incident Narrative

ON 12/31/2018 AT 07:30, A TECHNICIAN NOTICED AND INVESTIGATED PETROLEUM ODORS ALONG THE FACILITY DRIVEWAY AND ADJACENT CULVERT AT COLONIAL'S CHARLOTTE, NC FACILITY. OBSERVATIONS MADE CONFIRMED A SHEEN ON THE SURFACE OF WATER PRESENT IN THE CULVERT AND IN THE FACILITY POND AND WAS SUSPECTED TO BE ORIGINATING FROM A SHARED COLONIAL AND PLANTATION PIPELINE ROW. THE ROW CROSSES THE CHARLOTTE TANK FARM IN A NORTHEAST DIRECTION BETWEEN COLONIAL'S TANK DIKES #6 AND #7. THE COLONIAL LOCAL OPERATOR WAS IMMEDIATELY NOTIFIED AND ACTIONS WERE TAKEN TO SHUTDOWN COLONIAL'S OPERATING LINES WITHIN THE AREA. PLANTATION PIPELINE WAS NOTIFIED AND RESPONDED AND ASSUMED RESPONSIBILITY BECAUSE THE RELEASED PRODUCT WAS INITIALLY IDENTIFIED AS FUEL OIL AND WAS DIRECTLY OVER THEIR 26"" FUEL OIL/GAS LINE, WHICH WAS REPORTED IN FUEL OIL SERVICE AT THE TIME. PLANTATION BEGAN EXCAVATING AT 15:00 AND COMPLETED THEIR INVESTIGATION AT 03:29 ON 1/1/2019 WITH NO INDICATION OF A LEAK FROM THEIR LINE. AT THIS POINT, COLONIAL ASSUMED THE LEAD FOR THE RESPONSE WITH A FOCUS ON THE 32"" DIAMETER 762 TANK LINE. THE DIRECTOR OF OPERATIONS WAS NOTIFIED IMMEDIATELY. THE LOCATION OF THE TANK LINE RELATIVE TO OTHER INFRASTRUCTURE AT THE CHARLOTTE DF REQUIRED HAND EXCAVATION, WHICH LIMITED PROGRESS DURING THE RESPONSE DUE TO THE LIMITED WORKING SPACE, DEPTH OF EXCAVATION, AND MANUAL METHODS REQUIRED. EXCAVATION TO EXPOSE TANK LINE 762 AND IDENTIFY A LEAK SOURCE CONTINUED FOR SEVERAL DAYS. ON JANUARY 3, 2019, THE LEAK SOURCE WAS IDENTIFIED. THE LEAK SOURCE WAS AN APPROXIMATELY 0.5-INCH DIAMETER HOLE IN THE TANK LINE WALL LOCATED ON THE BOTTOM SIDE OF THE LINE (07:30 POSITION). AT 02:20 ON JANUARY 4TH, A 2 FT. TYPE B STEEL SLEEVE WAS INSTALLED ON TANK LINE 762 TO PERMANENTLY REPAIR THE LEAK SOURCE. A MAGNETIC PARTICLE TEST WAS COMPLETED AT APPROXIMATELY 14:00 ON JANUARY 4 AND VERIFIED THE INTEGRITY OF THE TYPE B SLEEVE WELDS. THE TANK AND TANK LINE REMAIN OUT OF SERVICE. APPROXIMATELY 145 BBLS OF PRODUCT HAVE BEEN RECOVERED AS OF JANUARY 21, 2019, WITH AN ESTIMATED 407 BBLS OF KEROSENE BEING RELEASED. APPROXIMATELY 750 TONS OF CONTAMINATED SOIL HAS BEEN EXCAVATED AND DISPOSED OF AT A CPC APPROVED FACILITY. IT IS ESTIMATED THAT ANOTHER 8,250 TONS OF SOIL IS AFFECTED, FOR AN ESTIMATED TOTAL OF 9,000 TONS CONTAINING AN ESTIMATED 221 BBLS OF PRODUCT. THE NRC WAS NOTIFIED BY THE COLONIAL CONTROL CENTER AT 10:07 ON THE JANUARY 1ST BECAUSE OF THE SURFACE WATER IMPACTS. THE NCDEM WAS NOTIFIED AT 10:45 ON JANUARY 1ST SINCE THE RELEASE WAS GREATER THAN 25 GALLONS AND THERE WERE SURFACE WATER IMPACTS. UPDATE 1/29/2020: AFTER REVIEWING THE DATA COMPILED FROM THE INTERNAL INSPECTION, THE PRIMARY CAUSE OF THE RELEASE WAS DETERMINED TO BE INTERNAL CORROSION ALONG THE BOTTOM OF THE TANK LINE. CONTRIBUTING FACTORS OF THE INCIDENT WERE FOUND TO BE INADEQUATE INSPECTION AND INADEQUATE PLANNING. A CORRECTIVE ACTION PLAN WAS COMPLETED TO EVALUATE THE SUGGESTIONS MADE BY THE ASSET INTEGRITY TEAM TO DETERMINE NEXT STEPS IN REPLACEMENT OF THE TANK LINE. SEVERAL PREVENTATIVE ACTION PLANS WERE ALSO COMPILED TO INCLUDE; A RE-EVALUATION OF THE RISK PRIORITIZATION LIST OF TANK LINES TO ENSURE TANKS WITH INTERNAL FLOATING SUCTIONS THAT DO-NOT EXPERIENCE BI-DIRECTIONAL FLOW ARE THOROUGHLY ASSESSED AND TO CONSIDER INSTALLING INTERNAL MONITORING SYSTEM TOOLS IN AREAS KNOWN FOR HIGHER RISK OF INTERNAL CORROSION. TO DATE A TOTAL OF 8,088 TONS OF SOIL HAS BEEN EXCAVATED, CONTAINING A CALCULATED 4,050 GALLONS OF KEROSENE. FROM VACUUM EXTRACTION EFFORTS, A TOTAL OF 9,082 GALLONS OF FREE PRODUCT HAS BEEN RECOVERED. TOTAL RECOVERED VOLUME FOR THE RELEASE IS 13,852 GALLONS (329.81BBLS). UPDATE 11/02/2020: COLONIAL IS SUBMITTING THIS REPORT AS A SUPPLEMENTAL FINAL REPORT. NO CHANGES OF SUBSTANCE HAVE OCCURRED SINCE SUBMITTING THE MOST RECENT UPDATE IN JANUARY 2020. TANK 762 AND THE REPLACEMENT TANK LINE ARE IN-SERVICE.