COLONIAL PIPELINE CO

Incident Narrative

ON 10/21/15 AT APPROXIMATELY 09:00 AM CST, A MAINTENANCE CREW WAS INSTALLING BLINDS TO ISOLATE THE MARATHON INCOMING MANIFOLD AT BATON ROUGE JUNCTION TANK FARM #2 WHEN THEY DISCOVERED DIESEL FUEL DISCHARGING THROUGH THE MANIFOLD'S OIL WATER SEPARATOR (OWS) WATER OUTLET WHICH GOES TO THE FACILITY RETENTION POND. IN THE DAYS PRECEDING THE SPILL, THE TWO INCOMING MARATHON LINES WERE DRAINED TO THE MANIFOLD SUMP IN PREPARATION TO REMOVE THE LINES FROM SERVICE. MULTIPLE ATTEMPTS WERE MADE TO COMPLETELY DRAIN THE PRODUCT WITHOUT COMPLETE SUCCESS; BECAUSE, IT WAS LATER DETERMINED, PRODUCT WAS LEAKING BY ONE OR MORE OF THE FUEL MANIFOLD VALVES. THE OWS WAS IMMEDIATELY ISOLATED ALONG WITH ALL OTHER OPERATIONS IN THE MANIFOLD. AT 10:00 THE OM NOTIFIED THE EAST FELICIANA PARISH DIRECTOR OF EMERGENCY PREPAREDNESS AND THE LA STATE POLICE WAS NOTIFIED VIA SPOC HOTLINE AT 10:06 (INCIDENT NUMBER 15-04428). AT 11:20 A REPORT WAS MADE TO THE NATIONAL RESPONSE CENTER BASED ON THE POTENTIAL TO EXCEED $50,000 RESPONSE/ESTIMATED PROPERTY DAMAGE (REPORT #1131335). DIRT DAMS WERE IMMEDIATELY CONSTRUCTED IN THE DITCH AND BOOM WAS DEPLOYED ON THE POND. THE OWS WAS CLEANED OUT AND HAD WATER ADDED AND REMAINED ISOLATED. A CONTRACT CREW WAS DEPLOYED TO PROVIDE TWO LAYERS OF CONTAINMENT AND ABSORBENT BOOM IN THE POND. INITIAL CLEANUP EFFORTS WERE COMPLETED AT 20:15. ON 10/24 DURING A PERIOD OF HEAVY RAIN, PRODUCT WAS IDENTIFIED ON THE RETENTION POND AGAIN AND A VACUUM TRUCK AND CREW WAS CALLED IN TO RECOVER THIS PRODUCT. THE PRODUCT HAD BEEN PUSHED INTO A CULVERT ON 10/21 BY THE PREVAILING WIND AND WAS FLUSHED OUT OF THE CULVERT WHEN RAIN WATER WAS INTRODUCED INTO THE CULVERT. A CONTRACT CREW WAS ALSO DISPATCHED TO ADD ADDITIONAL CONTAINMENT AND ABSORBENT BOOM TO THE POND IN ANTICIPATION OF MORE RAIN THROUGH THE WEEKEND. THE RECOVERY EFFORTS ON THIS DAY STARTED AT 16:30 AND CONTINUED UNTIL 2:30 ON 10/25. SUBSEQUENT INVESTIGATION DETERMINED PRODUCT WAS FLOWING INTO THE OWS WHEN THE MARATHON LINES WERE BEING DRAINED TO THE MANIFOLD SUMP. THE DRAIN LINES ARE CONNECTED TO THE OWS PRODUCT DISCHARGE PIPING (TO THE SUMP), WHICH IS DESIGNED TO GRAVITY DRAIN TO THE SUMP. IT WAS ALSO FOUND THAT THE OWS INTERFACE DETECTOR ALARM FAILED TO OPERATE PROPERLY (NO ALARM WAS GIVEN). INCIDENT ANALYSIS DETERMINED THREE IMMEDIATE CAUSES: 1) FUEL MANIFOLD VALVES NOT HOLDING (LEAKING BY), 2) MANIFOLD DID NOT DRAIN AS DESIGNED (FLOWED TO OWS AND SUMP), 3) OWS INTERFACE ALARM DID NOT WORK PROPERLY. ANALYSIS ALSO DETERMINED FOUR BASIC CAUSES: 1) INADEQUATE/IMPROPER ENGINEERING (IMPROPER DRAIN), 2) LACK OF PROCEDURES (NO PM OR MAINTENANCE PROCEDURES FOR OWS ALARM DEVICE), 3) LACK OF PROCEDURES (NO DRAIN-UP PROCEDURES FOR MARATHON INCOMING MANIFOLD), 4) LACK OF MOC. MULTIPLE CORRECTIVE ACTIONS WERE IDENTIFIED DURING ANALYSIS: 1) ISOLATE (COMPLETED) AND DEVELOP A PROJECT TO REMOVE THE DRAIN LINES FROM THE MARATHON INCOMING MANIFOLD TO THE OWS DISCHARGE PIPING, 2) ENSURE OWS PRODUCT DISCHARGE PIPING HAS PROPER VENT INSIDE SUMP TO MAINTAIN ADEQUATE FLOW (COMPLETED), 3) DEVELOP PROJECT TO EVALUATE PROPER ELEVATION GRADIENT ON THE DISCHARGE PIPING FROM THE OWS TO THE SUMP, 4) DEVELOP A PROJECT TO REMOVE THE DEAD LEG PIPING CREATED BY DECOMMISSIONING MARATHON LINES. A CORRECTIVE ACTION FROM A SPILL AT COLONIAL'S HOUSTON STATION ON 9/25/15 WAS ALSO LINKED TO THIS INCIDENT: CONSIDER CREATING MAINTENANCE AND/OR PM PROCEDURES FOR OWS ALARM DEVICES.