MAGELLAN AMMONIA PIPELINE, L.P.

Incident Narrative

A THIRD PARTY INDIVIDUAL HUNTING MUSHROOMS IDENTIFIED A DEAD SPORT OF VEGETATION AND NOTIFIED THE MAGELLAN OPERATIONS CONTROL CENTER. THE LINE WAS IMMEDIATELY SHUT DOWN AND AN INVESTIGATION WAS INITIATED. A PINHOLE SIZE ANOMALY IN A GIRTH WELD WAS SUBSEQUENTLY DISCOVERED. THE LINE WAS REPAIRED BY INSTALLING A TYPE B FULL ENCIRCLEMENT PRESSURE CONTAINING SLEEVE AND THE PIPE REPAIR WAS COATED. IMPACTED SOIL WAS REMEDIATED IN ACCORDANCE WITH COMPANY AND STATE STANDARDS. NOTE: WHEN THE RELEASE WAS INITIALLY DISCOVERED, INDICATIONS WERE THAT APPROXIMATELY ONLY 4 GALLONS OF PRODUCT HAD BEEN RELEASED, WHICH IS BELOW THE MINIMUM RELEASE REPORTING THRESHOLD IN 49 CFR PART 195.50. HOWEVER, DURING THE ONGOING INVESTIGATION AND REPAIR OF THE RELEASE IT WAS LATER DETERMINED ON MAY 21, (3 DAYS AFTER THE INITIAL DISCOVERY OF THE RELEASE) THAT PERHAPS AS MANY AS 100 GALLONS OF PRODUCT MAY HAVE BEEN RELEASED. AT THAT POINT IN TIME, THE DECISION WAS MADE TO NOTIFY THE NATIONAL RESPONSE CENTER THAT THE RELEASE HAD OCCURRED, WHICH ACCOUNTS FOR THE LAPSE OF TIME NOTED IN PART A OF THIS REPORT BETWEEN THE OCCURRENCE OF THE RELEASE AND THE PHONE CALL TO THE NRC. HOWEVER, THE NOTIFICATION TO THE NRC WAS MADE TO COMPLY WITH ENVIRONMENTAL REGULATIONS WHEN IT WAS DETERMINED THAT THE ESTIMATED VOLUME OF ANHYDROUS AMMONIA RELEASED MAY HAVE HIT OR EXCEEDED THE MINIMUM REPORTING THRESHOLD IN APPLICABLE ENVIRONMENTAL REGULATIONS. THE CHARACTER AND NATURE OF THE RELEASE WAS NOT CONSIDERED TO BE SIGNIFICANT WITHIN THE CONTEXT OF PART 195.52, WHICH ALSO REQUIRES NOTIFYING THE NATIONAL RESPONSE CENTER. MAGELLAN DOES NOT THINK THE DELAY IN CONTACTING THE NRC CONSTITUTES A BREACH OF PART 195 REPORTING REQUIREMENTS, SINCE THE NATURE OF THE RELEASE DID NOT WARRANT CALLING THE NRC UNDER PART 195. IN FILING THIS UPDATED FINAL REPORT, THE REVISED TOTAL COST NOW EXCEEDS $50,000, WHICH MEETS PHMSA FILING REQUIREMENTS FOR A ""LARGE"" SPILL.