LOOP LLC

Incident Narrative

THE UNAUTHORIZED DISCHARGE WAS THE RESULT OF THE INJECTION STATION SUMP OVERFLOWING DURING A DRAIN DOWN EVENT. AT APPROXIMATELY 0500 ON 12/14/2017 LOOP OPERATIONS BEGAN DRAINING DOWN THE INJECTION METERING OUTLET HEADER INTO THE INJECTION STATION SUMP. AT APPROXIMATELY 0615 OPERATIONS STOPPED THE DRAIN DOWN DUE TO A SCHEDULED ELECTRICAL OUTAGE. AT THIS TIME IT WAS VISUALLY DISCOVERED THAT THE SUMP HAD BEEN OVERFLOWING CRUDE OIL INTO THE WATER BELOW. LOOP PERSONNEL SHUTDOWN THE SYSTEM IMMEDIATELY UPON DISCOVERY. THE INJECTION STATION WHERE THE SUMP IS LOCATED WAS ISOLATED AND PRESSURE REMOVED FROM THE SYSTEM (THE SUMP WAS PUMPED DOWN). APPROXIMATELY 280 GALLONS WAS RELEASED. THE AMOUNT DISCHARGED WAS ESTIMATED UTILIZING A CALCULATION BASED ON THE SURFACE AREA AND DEPTH OF THE OBSERVED OIL. THE ENTIRE VOLUME RELEASE WAS TO AN AREA BELOW THE SUMP, WHICH WAS PERMANENTLY BOOMED. PERSONNEL IMMEDIATELY TOOK ACTIONS TO PREVENT THE POSSIBLE SPREAD OF THE SPILL BY PLACING ADDITIONAL CONTAINMENT BOOM AT CRITICAL LOCATIONS. CRUDE OIL WAS RECOVERED MECHANICALLY USING A SKIMMER FROM THE LOOP INVENTORY OF RESPONSE EQUIPMENT. RECOVERED OIL WAS RETURNED TO THE PIPELINE SYSTEM VIA THE INJECTION STATION SUMP. ABSORBENT PADS WERE ALSO UTILIZED TO RECOVER SURFACE OIL. ALL RESIDUAL MATERIALS WERE COLLECTED AND DISPOSED OF IN PROPER MANNER. PART D OF THIS REPORT CONTAINS QUESTIONS REGARDING PLANNED LONG TERM IMPACT ASSESSMENT. LOOP RESPONDED ""NO"" TO THIS QUESTION, BECAUSE NO IMPACT ASSESSMENT WAS PERFORMED/PLANNED SPECIFIC TO THIS EVENT, AS ALL THE OIL WAS CONTAINED AND PROMPTLY REMOVED FROM THE ENVIRONMENT. WHILE NO IMPACT ASSESSMENT WAS PERFORMED SPECIFIC TO THIS EVENT, IT SHOULD BE NOTED THAT THERE IS AN ONGOING ENVIRONMENTAL MONITORING PROGRAM (EMP) WHICH HAS BEEN IN PLACE FOR 40+ YEARS, AS REQUIRED BY LOOP'S FEDERAL AND STATE LICENSES, TO ASSESS IMPACTS ASSOCIATED WITH LOOP'S OPERATIONS AND/OR ASSOCIATED CONSTRUCTION ACTIVITIES. A PROGRAM REVIEW COMMITTEE CONSISTING OF REPRESENTATIVES FROM STATE AND FEDERAL AGENCIES, AS WELL AS A UNIVERSITY REPRESENTATIVE, SERVE AS A TECHNICAL ADVISORY GROUP FOR THE EMP TO INSURE THAT ANY IMPACTS ASSOCIATED WITH LOOP'S OPERATIONS AND CONSTRUCTION ACTIVITIES ARE IDENTIFIED AND MITIGATED. THE LOOP EMP IS ADMINISTERED BY THE EXECUTIVE DIRECTOR OF LOUISIANA OFFSHORE TERMINAL AUTHORITY WITH OVERSIGHT BY USCG CAPTAIN OF THE PORT AND THE SECRETARY OF LOUISIANA DEPARTMENT OF TRANSPORTATION AND DEVELOPMENT. IT WAS DISCOVERED THAT THE SPILL CAN BE ATTRIBUTED TO EQUIPMENT FAILURE OF TWO RADAR LEVEL TRANSMITTERS MALFUNCTIONING BY GIVING INACCURATE READINGS AND A FLOAT SWITCH FAILING TO ENGAGE THE SUMP PUMPS DUE TO THE FLOAT GETTING HUNG UP ON ITS TRACK (ROD). THE FLOAT SWITCH ROD HAS BEEN ADJUSTED TO CORRECT THE HANGING UP ISSUE. BOTH LEVEL TRANSMITTERS ARE CURRENTLY FUNCTIONING PROPERLY. FOR THE AVOIDANCE OF CONFUSION, IT SHOULD BE NOTED THAT A SIMILAR, BUT UNRELATED EVENT, OCCURRED AT THIS LOCATION (INJECTION STATION SUMP) ON DECEMBER 13, 2017 (NRC # 1199582). WHILE ""BLOWING OUT"" A 2-INCH DRAIN LINE IN PREPARATION FOR THE DRAIN DOWN TO BE PERFORMED ON DECEMBER 14, 2017, A CLOG IN THE LINE GAVE WAY ALLOWING CRUDE TO RUSH INTO THE SUMP AT A HIGH RATE CAUSING A MIST THAT EXITED THE SUMP THROUGH THE VENT. APPROXIMATELY 1.5 GALLONS WAS RELEASED TO THE WATER. THE RELEASE WAS CONTAINED AND REMOVED USING ABSORBENT PADS. ALL RESIDUAL MATERIALS WERE COLLECTED AND DISPOSED OF IN A PROPER MANNER. AT THIS TIME, LOOP HAS NOT DETERMINED THAT THESE TWO EVENTS ARE RELATED.