KINDER MORGAN COCHIN LLC

Incident Narrative

ON MONDAY, JUNE 30, 2014, FIELD PERSONNEL ARRIVED AT OUR HECTOR PUMP STATION TO DRAIN IT IN PREPARATION OF UPCOMING STATION MODIFICATION WORK. FIELD PERSONNEL OBSERVED AND INVESTIGATED AN AREA OF STAINED GRAVEL LOCATED AROUND THE VALVE STEM OF AN UNDERGROUND TWO INCH PUMP UNIT DRAIN VALVE. DURING THIS INITIAL INVESTIGATION AN LEL METER WAS USED TO ASSESS THE STAINED GRAVEL AT SURFACE LEVEL AND NO TRACES OF FLAMMABLE VAPORS WERE DETECTED. BASED ON THIS ASSESSMENT PERSONNEL DISCOUNTED THE STAIN AS A WEATHERED GREASE STAIN RELEASE FROM THAT VALVE STEM AND THEN PROCEEDED TO DRAIN THE STATION. ON MONDAY, JULY 21, 2014, PERSONNEL WENT BACK TO THE STATION TO FILL IT WITH PRODUCT. THE AREA OPERATIONS MANAGER INSTRUCTED FIELD PERSONNEL TO INVESTIGATE THE PREVIOUSLY IDENTIFIED STAIN AGAIN BEFORE FILLING THE STATION WITH PRODUCT. DURING THIS SECOND INVESTIGATION AN LEL METER WAS USED TO ASSESS THE STAINED GRAVEL AT SURFACE LEVEL AND AGAIN NO TRACES OF FLAMMABLE VAPORS WERE DETECTED. PERSONNEL THEN PROCEEDED TO EXCAVATE AND REMOVE THE STAINED GRAVEL IN ORDER TO ASSESS THE DIRT BELOW THE GRAVEL. AS THEY STARTED TO EXCAVATE DIRT THEY DETECTED HINTS OF PETROLEUM PRODUCT. THEY UTILIZED AN LEL METER AND CONFIRMED THE PRESENCE OF FLAMMABLE VAPORS SO PERSONNEL WITHDREW FROM THE AREA AND CONTACTED THE AREA MANAGER. OUR SPILL RESPONSE CONTRACTOR WAS NOTIFIED AND NON-EMERGENCY SERVICES WERE REQUESTED FOR ASSESSMENT AND CLEAN-UP. SINCE THIS WAS NOT AN ACTIVE LEAK, OUR SPILL RESPONSE CONTRACTOR ARRIVED ON TUESDAY, JULY 22, 2014 AND CONDUCTED A SAFETY ASSESSMENT TO DETERMINE WHAT LEVEL OF PPE, HUMAN RESOURCES AND EQUIPMENT WOULD BE REQUIRED. ON WEDNESDAY, JULY 23, 2014, WITH LIMITED DATA, IT WAS DETERMINED THAT AT MINIMUM WE HAD A DOT 30 DAY REPORTABLE EVENT AND THAT THE MINNESOTA POLLUTION CONTROL AGENCY NEEDED TO BE NOTIFIED. ON AUGUST 21, 2014, THE COST OF CLEANUP AND DAMAGES HAD NOT YET EXCEEDED PHMSA'S $50,000 NRC REPORTING CRITERIA BUT WERE FORECASTED TO EVENTUALLY SURPASS IT THEREFORE THE NRC REPORT WAS MADE ON THIS DATE. AS OF AUGUST 21, 2014, OUR TOTAL EXPENDITURES WERE $33,300. OUR FINAL INVESTIGATION DETERMINED THAT A BELOW GROUND PIPE NIPPLE CONNECTION UNDERNEATH THE TWO INCH VALVE HAD BROKEN AT THE THREADED CONNECTION POINT DUE TO FROST HEAVE. THIS VALVE WAS CUT OUT AND THE PIPING WAS RECONFIGURED TO BRING THIS VALVE ABOVE GROUND. ON MARCH 24, 2015, BASED ON FOLLOW-UP DISCUSSIONS WITH PHMSA, THE ORIGINAL CAUSE CATEGORY OF G-6, EQUIPMENT FAILURE WAS REVISED TO REFLECT THE FROST HEAVE IMPACT UNDER G-2, NATURAL FORCE DAMAGE.