CAMINO REAL GATHERING CO LLC

Incident Narrative

OCTOBER 18, 2018 (ALL TIMES LOCAL): 07:59AM - LOCAL OPERATIONS PERSONNEL WERE CONDUCTING A ROUTINE WALK THROUGH OF THE CAMINO REAL GATHERING COMPANY (CRGC) STOREY TERMINAL WHEN THEY NOTICED A STRONG ODOR OF HYDROCARBONS AND AN OIL SHEEN IN THE DRAINAGE AREA BEHIND THE STOREY OFFICE. THE LINE WAS SHUT IN AND IMMEDIATE ACTION WAS TAKEN TO CONTAIN THE RELEASE. THE RELEASE WAS SUCCESSFULLY CONTAINED WITHIN THE CRGC FACILITY PROPERTY AND THERE WAS NO IMPACT TO ANY BODY OF WATER OR ANY SIGNIFICANT IMPACTS BECAUSE OF THE RELEASE. THE EVENT WAS REPORTED TO THE SUPERVISOR AND THE HOUSTON CONTROL CENTER WAS NOTIFIED. 08:15AM - INITIATED INTERNAL EMERGENCY RESPONSE LINE (ERL) CALL NOTIFICATIONS PER COMPANY PROCEDURES TO DISCUSS THE INCIDENT. 08:38AM - EVENT DETERMINED REPORTABLE TO NRC AND TRRC BASED ON ESTIMATED COST OF PROPERTY DAMAGE, INCLUDING COST OF CLEANUP AND RECOVERY, VALUE OF LOST PRODUCT, AND DAMAGE TO THE PROPERTY OF THE OPERATOR WOULD EXCEED $50,000. 08:40AM - CALL TO NRC INITIATED (NRC #1227806) 08:54AM - CALL TO THE RAILROAD COMMISSION OF TEXAS (TRRC #1863) OCTOBER 18 - 22, 2018: LOCATION OF THE LEAK EXCAVATED (NOTE THAT DUE TO THE RAIN, THE CUTOUT AND REPAIRS TOOK LONGER THAN ANTICIPATED) OCTOBER 22, 2018: TRENCH BOXES INSTALLED AND LINE DRAINED. OCTOBER 25, 2018: RECOVERY OF STANDING COMMODITY COMPLETED, SECTION CUTOUT AND PIPELINE REPAIRED AND RETURNED TO SERVICE. CUTOUT SENT FOR METALLURGICAL TESTING. DECEMBER 12, 2018 METALLURGICAL REPORT CONCLUDED THAT (1) ELECTROCHEMICAL EXTERNAL PITTING CORROSION CAUSED THE LEAK IN THE FITTING. THE FBE COATING DISBONDMENT APPEARS TO BE A FACTOR IN THE EXTERNAL CORROSION MECHANISM AND (2) MECHANICAL AND CHEMICAL TEST RESULTS FOR THE FITTING MET THE MSS SP-75 STANDARD WPHY-42 GRADE SPECIFICATION FOR HIGH-STRENGTH WROUGHT BUTT WELDING FITTINGS. INVESTIGATION DETERMINED THAT THERE WERE TWO CONTRIBUTING FACTORS TO THE CAUSE OF THE EXTERNAL CORROSION: 1. CONTRIBUTING FACTOR - ABSENCE OF CATHODIC PROTECTION (CP) WAS CAUSED BY A LACK OF UNDERSTANDING OF WHERE THE CUSTODY TRANSFER BETWEEN CRGC PIPELINE ENDED AND THE THIRD-PARTY PIPELINE BEGAN. CORRECTIVE ACTION - AREA WHERE THE LEAK AND EXTERNAL CORROSION WERE FOUND WAS PLACED UNDER CP. REVIEWED FACILITY PIPING AND RISERS TO LOCATE ANY ADDITIONAL AREAS WITHOUT CP. ALL OTHER AREAS MET THE CP CRITERIA. VERIFIED THAT THERE IS A CLEAR DEMARCATION OF THE CUSTODY TRANSFER POINT BETWEEN CRGC PIPELINE AND THIRD-PARTY PIPELINE. 2. CONTRIBUTING FACTOR - INADEQUATE COATING APPLICATION PRACTICES AT THE TIME OF CONSTRUCTION LED TO DISBONDED COATING. CORRECTIVE ACTION - DAMAGED PIPE AND FITTINGS WERE REPLACED WITH NEW PIPE AND FITTINGS. NEW COATING AND PROPER COATING APPLICATION WAS APPLIED. TWO ADDITIONAL 90 ELBOWS ADJACENT TO THE FAILURE WERE INSPECTED FOR EXTERNAL CORROSION AND BOTH WERE RECOATED WITH FBE COATING. MARCH 20, 2019 RELEASE RESPONSE SUMMARY (ENVIRONMENTAL SITE ASSESSMENT) CONCLUDED THAT BASED ON THE SITE ASSESSMENT AND ANALYTICAL LABORATORY DATA FROM THE RELEASE RESPONSE, THE RELEASE QUALIFIES FOR NO FURTHER ACTION AS DEFINED BY THE RAILROAD COMMISSION OF TEXAS STATEWIDE RULE 91. ADDITIONAL NOTES: 48-HOUR UPDATE NRC #1227993