ITC PIPELINE COMPANY, LLC

Incident Narrative

ATTACHMENT A: NARRATIVE DESCRIPTION ON SEPTEMBER 13, 2017, AT APPROXIMATELY 0712, AN ITC OPERATOR, WHILE MAKING NORMAL FACILITY ROUNDS, OBSERVED AN AREA OF WET SOIL WITH A HYDROCARBON ODOR IMMEDIATELY NEAR THE FACILITY PIPELINE MANIFOLD AREA. THE MANIFOLD AREA IS LOCATED COMPLETELY WITHIN THE ITC TERMINAL PROPERTY LINE, NEAR ABOVEGROUND STORAGE TANKS P012-002 AND P012-003. IMMEDIATE RESPONSE ACTIONS WERE UNDERTAKEN UPON DISCOVERY, INCLUDING BUT NOT LIMITED TO MAKING INTERNAL NOTIFICATIONS, ISOLATING THE AREA, CONDUCTING AIR MONITORING FOR DETERMINATION OF SAFE/HOT ZONES, AND INITIATING EXPLORATORY HAND DIGGING TO DETERMINE IF A SURFACE SPILL HAD OCCURRED, OR IF AN UNDERGROUND LEAK EXISTED. HAND DIGGING COMMENCED AT APPROXIMATELY 0810. THE EXCAVATION ACTIVITIES REVEALED THAT AN UNDERGROUND LEAK WAS OCCURRING NEAR AND AROUND A SECTION OF 16"" DIAMETER UNDERGROUND PIPING (THE ""SURGE LINE"") THAT CONNECTS THE INCOMING PIPELINE MANIFOLD TO TANK P012-003. THE SECTION OF PIPING IS USED TO PROVIDE SURGE PROTECTION FOR THE PHMSA REGULATED PIPELINE. AT THE TIME OF DISCOVERY, THE PIPELINE CONTAINED GASOLINE BLENDSTOCK, BUT THERE WAS NOT A TRANSFER UNDERWAY. FURTHER INVESTIGATION REVEALED THAT THE SPECIFIC LEAK SOURCE WAS A PINHOLE LEAK IN AN ELBOW OF A 2"" DIAMETER SECTION OF PIPE THAT WAS WELDED ONTO THE UNDERSIDE OF THE SURGE LINE. THE 2"" LINE WAS INSTALLED TO PROVIDE A LOW POINT CONNECTION TO EMPTY THE PIPING WHEN NECESSARY. THE RELEASE WAS ONLY TO SOIL NEAR AND AROUND THE LEAK POINT - THERE WAS NO IMPACT TO WATER, AND NO OFF-SITE IMPACT. INITIAL EFFORTS TO VACATE PRODUCT FROM THE SURGE LINE WERE INITIATED AT APPROXIMATELY 9:20 A.M., AND THE LEAK STOPPED AT APPROXIMATELY 10:00 A.M. THE REMAINING LIQUID WAS REMOVED FROM THE PIPING USING A VACUUM TRUCK AT APPROXIMATELY 2:50 P.M. SOIL EXCAVATION CONTINUED THROUGHOUT THE DAY, AND SMA LL AMOUNTS OF POOLED PRODUCT WERE REMOVED. CONTAMINATED SOILS WERE PLACED INTO ROLL-OFF BINS FOR DISPOSAL. ON SEPTEMBER 16, 2017, THE SECTION OF 2"" DIAMETER PIPING WAS REMOVED, AND THE CONNECTION TO THE 16"" SURGE LINE CAPPED AND WELDED. REPAIRS WERE COMPLETED AT APPROXIMATELY 12:15 P.M. HYDROSTATIC TESTING OF THE PIPING SYSTEM WAS COMPLETED ON SEPTEMBER 17, 2017, AT APPROXIMATELY 11:15 A.M. THE LINE WAS RETURNED TO NORMAL SERVICE ON SEPTEMBER 18, 2017, AT APPROXIMATELY 10:00 A.M., AND THERE HAVE BEEN NO FURTHER ISSUES ADDITIONAL INFORMATION: IT SHOULD BE NOTED THAT THIS IS A NEWLY CONSTRUCTED PIPELINE THAT WAS PLACED INTO SERVICE IN 2016. UPON COMPLETION OF INSTALLATION AND PRIOR TO PLACING IN SERVICE, THE SECTION OF PIPING INVOLVED IN THE INCIDENT WAS SUBJECT TO RADIOGRAPHIC AND HYDROSTATIC TESTING. ITC BELIEVES THAT THE LOCALIZED PITTING CORROSION WAS PRIMARILY BY MICROBIOLOGICAL INDUCED CORROSION, IN THE ABSENCE OF CATHODIC PROTECTION. AT THE TIME OF THE INCIDENT, ITC WAS IN THE PROCESS OF A CATHODIC PROTECTION (CP) SYSTEM. INSTALLATION WAS COMPLETED ON OR ABOUT OCTOBER 9, 2017.