SFPP, LP

Incident Narrative

2/11/19 UPDATE: SFPP, LP IS FILING THIS FINAL REPORT BECAUSE ONLY LONG-TERM REMEDIATION AND MONITORING WHICH IS BEING CONDUCTED UNDER THE AUSPICES OF THE LOS ANGELES WATER BOARD. THE ESTIMATED FINAL COSTS (ADDED A REMEDIATION RESERVE OF $1,219,200) AND VOLUME OF COMMODITY RECOVERED CAN BE PREDICTED WITH A REASONABLE DEGREE OF CERTAINTY (213 BBLS, ONLY 1 BBL OF ADDITIONAL RECOVERY SINCE THE LAST REPORT). IN ADDITION, THE VOLUME OF COMMODITY RECOVERED OVER TIME HAS CONSISTENTLY DECREASED TO THE POINT WHERE AN ESTIMATED TOTAL VOLUME OF COMMODITY RECOVERED CAN BE PREDICTED WITH A REASONABLE DEGREE OF ACCURACY. FINALLY, THE CONTINUATION OF SUPPLEMENTAL REPORT FILINGS IN THE FUTURE WILL NOT PROVIDE ANY ESSENTIAL INFORMATION WHICH WILL BE CRITICALLY DIFFERENT THAN THAT CONTAINED IN THIS FINAL REPORT. 10/10/18 SUPPLEMENTAL UPDATE: NEW COST INFORMATION BECAME AVAILABLE. TOTAL COSTS NOW ARE $310,420. 6/20/18 SUPPLEMENTAL UPDATE: THE KM REMEDIATION GROUP HAS RECOVERED 212.38 BBLS TO DATE. ADDITIONAL RECOVERY AND ASSESSMENT IS BEING PERFORMED. ACCORDINGLY, COSTS HAVE ALSO BEEN UPDATED AND ANOTHER SUPPLEMENT NEEDED FOR RELEASE AMOUNT AND RECOVERY. NOTE: PART G-6, # 6. THIS STYLE OF EIJ USES A DOUBLE SEALING GASKET SET AND EPOXY SEALANT TO PREVENT LEAKAGE AT THE JOINT INTERFACE. FAILURE ANALYSIS WAS CONDUCTED INCLUDING VISUAL INSPECTION, MECHANICAL SECTIONING TO ASSESS LEAK PATH, FOURIER-TRANSFORM INFRARED SPECTROSCOPY TO IDENTIFY GASKET MATERIAL, OPTICAL MICROSCOPY, AND SCANNING ELECTRON MICROSCOPY (SEM) OF THE GASKET FRACTURE SURFACE. THE EXPERIMENTAL RESULTS INDICATE THE EPOXY SEAL WAS COMPROMISED (MISSING AND CRACKING CONSISTENT WITH EXCESSIVE BENDING STRESSES) AT THE LOCATION OF THE RELEASE ALONG WITH A PROTRUDING (UNSUPPORTED) #1 GASKET (OUTER) AND #2 GASKET (INNER) HAD BROKEN (CONSISTENT WITH A PROGRESSIVE CRACKING MECHANISM, SUCH AS, FATIGUE) LIKELY DRIVEN BY UNEVEN LOADING DUE TO BENDING STRESSES AND RECOILED INTO THE CAVITY ALLOWING PRODUCT TO ESCAPE. 12/5/17 SUPPLEMENTAL CHANGES: CORRECTED LAT/LON ERROR. NO OTHER UPDATES MADE. ON SATURDAY, 5/20 AT APPROXIMATELY 0735 AFTER THE START-UP OF LS 105/108 (WA-CL 24/20""), A 1' X 1' POOL OF PRODUCT ESTIMATED TO BE 1.5 GALLONS WAS NOTICED AT THE OUTGOING CHECK-VALVE AREA. THE LINE WAS SHUT DOWN AND INTERNAL RELEASE NOTIFICATIONS WERE MADE. THE SITE HAD BEEN EXCAVATED THE PRIOR DAY (THE 19TH) BASED ON A HYDROCARBON ""LEL SNIFF"" AT THE CHECK VALVE SNIFF TUBE DURING A POST MAINLINE BLOCK VALVE INSPECTION. AFTER THE INVESTIGATION FRIDAY, THE FIELD CREW DID NOT OBSERVE ANY EVIDENCE OF A RELEASE, SO A STATIC PRESSURE TEST WAS CONDUCTED AND COMPLETED SUCCESSFULLY AT 0015, 5/20/2017. THE LINE REMAINED DOWN UNTIL THE RE-START LATER THAT MORNING. AT APPROXIMATELY 0815, KM DETERMINED THE $50K TELEPHONIC CRITERION WOULD LIKELY BE MET DUE TO THE INVESTIGATION EXCAVATION, SO THE NRC NOTIFICATION (#1178847) WAS MADE. THE 48-HOUR PHMSA UPDATE NRC NOTIFICATION (#1178958) WAS MADE MONDAY, THE 22ND CONFIRMING THE INITIAL RELEASE VOLUME.. AFTER REPAIR AND RETURN TO SERVICE (POST 48-HOUR NRC UPDATE), THE KM REMEDIATION GROUP CONDUCTED SAMPLING TO CALCULATE A RELEASE VOLUME OF 1440 GALLONS. (THE SOURCE OF THE RELEASE WAS A FAILED CP SYSTEM EIJ (ELECTRICAL INSULATING JOINT). NOTE: PART A, #4 ORIGINALLY CALLED IN AS THREATENED RELEASE ON 5/19 (NRC#1178759), RE-NOTIFIED WHEN DETERMINED TO MEET THE $50,000 CRITERIA (NRC#1178847) AND UPDATED ON 5/22 (NRC#1178958).