KOCH PIPELINE COMPANY, L.P.

Incident Narrative

SCHEDULED MAINTENANCE WORK WAS BEING PERFORMED TO REPLACE THE PUMP 2 DISCHARGE FLANGE GASKET AT THE INTERMEDIATE HUGO PUMP STATION ON MINNESOTA PIPE LINE (MPL). MPL LINES 1, 2 & 3 WERE ISOLATED FROM THE HUGO PUMP STATION BY CLOSING MANUAL SUCTION & DISCHARGE 16"" STATION GATE VALVES, ALLOWING THE STATION TO BE DRAINED UP. THE MECHANICAL FIELD TECHNICIAN (""MFT"") PERFORMED STATION LOCKOUT, THEN OPENED DRAIN VALVE ON THE PUMP HEADER TO BLEED PRESSURE AND CRUDE OIL TO THE SUMP. THERE WAS A TEMPORARY OBSTRUCTION LOCATED AT THE BOTTOM OF MPL 1, ABOVE THE GROUND SUCTION 16"" STATION GATE VALVE, WHICH STOPPED THE VALVE FROM FULLY CLOSING. THE ABOVE GROUND HEADER DRAIN VALVE ALSO HAD AN OBSTRUCTION, WHICH RELEASED AFTER BEING FULLY OPENED, SENDING A SURGE THROUGH THE DRAIN LINE. THIS RESULTED IN A BACKUP OF CRUDE OIL IN CONNECTING DRAIN LINES WHICH SPRAYED OUT FROM UNDER THE 4 PUMP INBOARD AND OUTBOARD SEAL BOX COVERS ONTO THE PUMP BASE AND GROUND. THE MFT, RESPONSIBLE FOR THE WORK ACTIVITY, WAS FIRST OPERATOR QUALIFIED FOR TASK 63.4, MANUALLY OR REMOTELY OPEN OR CLOSE VALVES OR OTHER EQUIPMENT, THROUGH KPL'S OPERATOR QUALIFICATION (""OQ"") PROGRAM IN 2006. OQ REQUIRES PASSING THREE TESTS: A WRITTEN KNOWLEDGE TEST, A PERFORMANCE TEST AND A WRITTEN ABNORMAL OPERATING CONDITIONS (AOC) TEST. THE MFT RE-QUALIFIED ON ALL 3 TESTS IN 2009. HE RE-QUALIFIED ON THE AOC TEST AND WRITTEN KNOWLEDGE TEST ON JUNE 14 AND JULY 12, 2012, RESPECTIVELY. THE MFT DID NOT TAKE THE PERFORMANCE TEST BY THE 3 YEAR RE-QUALIFICATION DATE OF JULY 16, 2012. THEREFORE, THE MFT DID NOT POSSESS ALL REQUIRED OQ CREDENTIALS FOR TASK 63.4 AT THE TIME OF THE RELEASE ON JANUARY 2, 2013. THIS INFORMATION ABOUT THE OQ STATUS OF THE MFT WAS DISCOVERED DURING THE POST-INCIDENT REVIEW OF THE ACCIDENT. THE MFT RE-QUALIFIED HIS FULL OQ CREDENTIALS BY TAKING AND SUCCESSFULLY PASSING THE PERFORMANCE TEST FOR TASK 63.4, ON JANUARY 28, 2013. THE TOTAL AMOUNT OF SOIL REMEDIATED WAS 35.66 TONS. ONCE CLEAN UP FROM THE RELEASE WAS COMPLETED, A PLAN WAS PUT IN PLACE AND HEAT WAS APPLIED TO THE MPL LINE 1 ABOVE THE GROUND SUCTION 16"" STATION GATE VALVE TO ADDRESS THE TEMPORARY OBSTRUCTION. THIS MANUAL VALVE WAS ABLE TO FULLY CLOSE WITHOUT MUCH EFFORT AND LIKELY HAD ICE IN THE VALVE. REPLACEMENT OF THE PUMP 2 DISCHARGE FLANGE GASKET WAS PERFORMED WITHOUT ISSUE.