ENTERPRISE PRODUCTS OPERATING LLC

Incident Narrative

ON 12/9/14 AT APPROXIMATELY 00:01 HRS, BAYTOWN OPERATIONS DISCOVERED APPROXIMATELY 10 GALLONS OF A DIESEL/GASOLINE MIXTURE ON TOP OF POOLED STORMWATER NEAR THE 0580 MANIFOLD AREA. A GASKET FAILURE ON THE P-98 METER RUN WAS IDENTIFIED AS THE SOURCE OF THE LEAK. A VACUUM TRUCK WAS USED REMOVE ALL STANDING PRODUCT AND THE GASKET WAS REPLACED. DURING THE INITIAL INVESTIGATION, AN OVERPRESSURE EVENT WAS DISCOVERED ON THE P-98 METER RUN ON 12/7/14 AT 18:43 HRS DURING SHUT DOWN OF A ULSD DELIVERY INTO TANK 644. THIS OVERPRESSURE EVENT WAS IDENTIFIED AS THE CAUSE OF THE GASKET FAILURE. BAYTOWN OPERATIONS ISSUED CLOSED COMMANDS FOR TWO VALVES, MOV9803 AND MOV0982, AS IDENTIFIED ON OPERATING PROCEDURE BAY-OP-343. THE DOWNSTREAM VALVE (MOV0982) WAS ISSUED A CLOSED COMMAND BEFORE THE UPSTREAM VALVE (MOV9803) WAS FULLY SEATED. BOTH VALVES WERE ISSUED CLOSED COMMANDS WHILE THERE WAS STILL FLOW ON THE PIPELINE, RESULTING IN BACKPRESSURE ON THE ANSI 150 RATED METER RUN. A MAXIMUM PRESSURE OF 367.7 PSI WAS OBSERVED ON THE METER RUN FOR LESS THAN 10 SECONDS. TO PREVENT A RECURRENCE OF THE INCIDENT, AN INTERLOCK WAS INSTALLED ON THE PLC TO PREVENT MOV0982 FROM RECEIVING A PERMISSIVE TO CLOSE WITHOUT MOV9803 FULLY SEATING. OPERATING PROCEDURE BAY-OP-343 WAS REVISED TO INCLUDE LANGUAGE REGARDING THE NEED TO LET MOV9803 FULLY SEAT PRIOR TO GIVING A CLOSED COMMAND TO MOV0982. THE BOARD OPERATOR'S OQ TASK 43.2 WAS SUSPENDED PER OQ MANUAL SECTION 8, TASK SUSPENSION AND/OR DISQUALIFICATION.