Ant CO 104583554 CO 20150915 Investigation Report Texas Commission on Environmental Quality Investigation'Report The TCEQ is committed to accessibility. If you need assistance in accessing this document, please contact oce@tceq.texas.gov Customer: ETC Texas Pipeline, Ltd. Customer Number: CN601587652 Regulated Entity Name: ETC TEXAS PL PIPELINE DEWITT COUNTY Regulated Entity Number: RN104583554 Investigation 1280561 Incident Numbers 215804 Investigator: Site Classi?catiorl Conducted: 0.9/ 02/ 2015 09/15/2015 No Industry Code Assigneb Progra1n(s): AIR QUALITY NON PERMITTED Investiga?on Type: Compliance Invest File Review Additional ID Address: Activity Type(s): Principal! 1: Role Name RESPONDENT ETC TEXAS PIPELINE LTD Contact! 5 Role Title Name REGULATED SENIOR BART HUSKY ENTITY ENVIRONMENTAL CONTACT SPECIALIST Other Staff Member(s): Role Name Supervisor GUADALUPE LOPEZ Supervisor KELLY RUBLE Associated Check List Checklist Name Unit Name AIR EMISSIONS EVENT REVIEW (ON OR AFTER 215804 01/05/2006) Investigation Comments: Emissions Event Rich Eagle Ford Mainline 42 Inch Pipeline I. INTRODUCTION Location: COUNTY PIPELINE SEGMENT Local Unit: REGION 14 - CORPUS CHRISTI 0G Oil and Gas AIR QUALITY High Level UML3IH AIR UML3IH - IN HOUSE UPSETMAINTENAN CE LEVEL 3 OTOA Phone Work (361) 876-9648 ETC TEXAS PL PIPELINE COUNTY - 9/2/2015 to 9/15/2015 Inv. 1280561 Page 2 0f4 Introduction On September 9, 2015, Ms. Susan Hoelscher, Environmental Investigator (E1) for the Texas Commission on Environmental Quality (TCEQ) Corpus Christi Region 14 (R14) Of?ce, initiated an Upset/ Maintenance Level 3 In?House (UML3IH) investigation regarding an emissions event (EE), Incident No. 215804, that occurred on the ETC Texas Pipeline, Eagle Ford Mainline 42 inch Pipeline located in DeWitt County, Texas. contact during the investigation was Mr. Bart Husky-Senior Environmental Specialist. The EE began on June 14, 2015 at 2000 hours and occurred for 3 hours and 15 minutes. The initial noti?cation (IN) was submitted by Mr. Husky and received via the State of Texas Environmental Electronic Reporting System (STEERS) on June 15, 2015 at 1746 hours. On June 27, 2015, the ?nal- report (FR) was submitted by Mr. Husky via STEERS. The reportable quantity (RQ) was exceeded for multiple components. See Attachment 1 for Incident No. 215804 IN and FR. Daily Narrative IN and FR, additional information was requested on September 9, 2015 and received on Septembef?15, ""2015 via email. See Attachment 2 for the additional information. Upon submittal of the additional information, the El conducted a ?nal review of the IN and FR. The event was Caused by a breach in the 42 inch natural gas pipeline which immediately ignited all gas vapors. ETC immediately responded by blocking in and isolating the affected pipeline segment curtailing the emissions. Subsequent to discovery of the incident, ETC collaborated with local of?cials to secure the area and ensure the safety of the public. All of the damaged pipe was removed and replaced. See Attachment 1 for Incident No. 2158 04 IN and FR and Attachment 2 for the additional information submitted. The demonstrations criteria provided in 30 TAC ?101.222(a) and were applied to the event. It was determined that the BE met all of the applicable demonstrations criteria and is therefore subject to an af?rmative defense. Exit Interview Since n0n~compliance issues were not determined during the course of this investigation, the TCEQ Exit Interview Protocol was not utilized. II. GENERAL FACILITYAND PROCESS INFORMATION Process Description The affected pipeline is ETC Texas Pipeline, Ltd?s Rich Eagle F0rd Mainline 42 inch pipeline located in DeWitt County, Texas. BACKGROUND Customer Number (CN): CN601587652 Classi?cation: Satisfactory I Rating: 0.72 Regulated Entity Number (RN): RN104583554 Classi?cation: Unclassi?ed Rating: NA Note: 30 TAC ?6o.2 - Compliance History Classi?cation (Point Ranges): High Performer (above?satisfactory compliance record) fewer than 0.10 points; Satisfactory Performer (generally complies with environmental regulations) 0.10 to 55 points; Unsatisfactory Performer (performs below minimal acceptable performance standards established by the commission) more than 55 points . ETC TEXAS PL PIPELINE COUNTY - 9/2/2015 to 9/15/2015 Inv. 1280561 Page 3 of 4 Current Enforcement Actions There is no current enforcement action since no de?ciency or areas of concern were noted during this investigation. Agreed Orders, Court Orders, and Other Compliance Agreements ETC has not received any air related agreed orders, court orders, or other compliance agreements in the previous ?ve years of operation. Prior Enforcement Issues ETC has not been the subject any air related enforcement issues in the previous ?ve years of operation. Complaints ETC has not been the subject of any complaints during the previous ?ve years of operation. IV. ADDITIONAL INFORMATION Conclusions and Recommendations Based on the current assessment of information submitted by ETC, the EB satis?ed the criteria of 30 TAC ?101.222(a) and and is therefore subject to an af?rmative defense as all applicable demonstrations criteria were met for Incident No. 215804. V. ATTACHMENTS 1. Incident No. 215804 Initial Noti?cation and Final Report 2. Additional Information No Violations Associated to this Investigation q. Signed Date Environmental Investigator Signed Date 0 VIC I Supervisor ETC TEXAS PL PIPELINE DEWI. COUNTY 9/2/2015 to 9/15/2015 Inv. - 1280561 Page 4 of 4 Attachments: (in order of ?nal report submittal) Enforcement Action Request (EAR) P161118, Sketches Letter to Facility (specify type) __Ph0t031' aPhS Investigation Report iCorrespondence from the facility Sample Analysis Results Other 1 __Manifests Notice of Registration TCEQ ATTACHMENT 1 - Incident No. 215804 Initial Noti?cation and Final Report Total Pages: 7 Investigation No. 1280561 RN104583554 ETC Texas PL Pipeline DeWitt County CN601587652 ETC Texas Pipeline, Ltd. September 9, 2015 September 15, 2015 Texas Commission on Environmental Quality Reportable Event Report Submittal Type Incident Incident Status Investigation Investigation Status FINAL 215804 OPEN Customer Name CN ETC TEXAS PIPELINE LTD CN601587652 Name of Owner or Operator Acct Physical Location ETC TEXAS PL PIPELINE COUNTY RN104583554 Event/Activity Type Date I Time Event Discovered or Scheduled Activity Start/End Duration EMISSIONS EVENT 6/14/2015 6/14/2015 3 hours 15 minutes Emission Point Common Name Emission Point Number (EPN) 42" Pipeline Estimated Total Authorized List of Compound Descriptive type(s) of Quailtity for Air Units Emissions Units Individually Listed or Mixtures of Air COMammanf-S for Limitl Authorization Contaminant Compounds Released, EmiSSionS I Opacity (rule or permit Including opacity Value for Limit Butane, N- pgegom 6,133.00 POUNDS 5,000.00 POUNDS ?101.201 CO ?9333?) {hr 46,858.00 POUNDS 5,000.00 POUNDS ?101.201 Hexanes 737.00 POUNDS 5,000.00 POUNDS ?101.201 Isobutane 4,384.00 POUNDS 5,000.00 POUNDS ?101.201 NOX measly) b: 23,475.00 POUNDS 5,000.00 POUNDS ?101.201 pentane, iso? 2,036.00 POUNDS 5,000.00 POUNDS ?101.201 Pentane, N- 1,529.00 POUNDS 5,000.00 POUNDS ?101.201 Propane, N- {10.55060le 17,206.00 POUNDS 5,000.00 POUNDS ?101.201 unspeciated) 32,020.00 POUNDS 5,000.00 POUNDS ?101.201 155 Facility Common Name Facility Identification Number (FIN) REM 42" Process Unit or Area Common Name Rich Eagle Ford Mainline Cause of Emissions Event, Excess Opacity Event, or Reason for Scheduled Activity: ETC experienced a breach on a 42" natural gas pipeline which was immediately ignited causing all gas vapors to be combusted. At this time the root cause remains under investigation. Actions Taken, of Being Taken, to Minimize Emissions and/or Correct the Situation: ETC immediately responded by blocking in and isolating the affected pipeline segment curtailing the emissions. Subsequent to discovery of the incident, ETC collaborated with local of?cials to secure the area and ensure the safety of the public. Equipment and materials were dispatched to the location to complete repairs. All the damaged pipe was removed and replaced. Basis Used to Determine Quantities and Any additional Information Necessary to Evaluate the Event: Engineering calculations, process knowledge and incident description. The gas loss volume of 134,171 has been derivec from modeling and real?time data tracking on the pipeline system. ETC utilized the most recent speciated gas analysis with a heating value of 1269.4 and the following Mol%>> N2 0.07730, C02 1.15960, Methane 76.56400, Ethane 13.20520, Propane 5.51800, ISO-Butane 1.06650, N?Butane 1.49220, lso-Pentane 0.39900, N-Pentane 0.29960, Hexanes 0.104. Attachment I luv. No. 1280561 Dang at Texas Ct .imission on Environmental Q. Aiity Reportable Event Report Bart Husky (361) 876-9648 2015-6-15 17:46 - STEERS Bart Husky (361) 876?9648 REGION 14 - CORPUS CHRISTI Assigned Staff Member: Susan Hoelscher Person Making Initial Notification Initial Noti?cation DatelTime Method Incident Primary Contact Jurisdiction(s) Notified Agency Comments Attachment I luv. No. 1280561 Susan Hoelscher From: Upset14 Sent: Saturday, June 27, 2015 8:47 PM To: Upset14 Subject: Incidents for Con?rmation 122091 were entered today" DO NOT REPLY TO THIS E-MAIL TCEQ Incident #215804 (AEME ID 128399), with a Discovery Date of 06/14/2015 08:00 PM, Type of EMISSIONS EVENT was entered today for Regulated Entity: RN104583554 ETC TEXAS PL PIPELINE COUNTY This email is sent whenever an incident is submitted through STEERS. if this incident was submitted via STEERS using a probationary account, or if this incident was entered/modified by TCEQ staff, you will have until midnight 06/30/2015 to verify the information on the Incident(s). Otherwise, you may disregard this email. to verify the information on the lncident(s). You may review the information on this incident online at: WARNING: As we either enter or correct data for your incident report form, the database is updated immediately. If you try to review this incident before our data entry is complete, you may see only part of the data from your incident example, our database may show that the incident occurred but show no data on contaminants. If this happens, please do not repudiate the information. Instead, cancel the process and review the incident again later. Attachment 1' Inv. 1280561 Susan Hoelscher From: Sent: To: Cc: Subject: STEERS Saturday, June 27, 2015 6:48 PM Upset14 STEERS Air Emissions Submitted - Incident 215804 This con?rms the submittal of your incident information to the TCEQ. You submitted a final report for incident 215804, regulated entity RN104583554. Your submittal was received at 06/27/2015 06:47 PM. The confirmation number for this submittal is 122091? You may access the copy of record from the submit log which is available from the Home page of STEERS Internet Version 5.9. if you have any questions please contact the STEERS Help Line at 512-239-6925 or by e?mail at Attachment 1 Nn 1290561 Texas COmmission on Environmental Quality Reportable Event Notification Submittal Type Incident Incident Status Investigation Investigation Status INITIAL 215804 OPEN Customer Name CN ETC TEXAS PIPELINE LTD CN601587652 Name of Owner or Operator Acct Physical Location ETC TEXAS PL PIPELINE COUNTY RN104583554 Event/Activity Type Date I Time Event Discovered or Scheduled Activity Start/End Duration EMISSIONS EVENT 6/14/2015 6/14/2015 2 hours 30 minutes Emission Point Common Name Emission Point Number (EPN) 42" Pipeline Estimated Total Authorized List of Compound Descriptive type(s) of Quantity for Air Units Emissions Units Individually Listed or Mixtures of Air Comammants fof Limitl Authorization Contaminant Compounds Released. EmiSSions I Opacity (rule or permit Including opacity Value for OPaCity Limit unspecialed) 165.732.00 POUNDS 5,000.00 POUNDS ?101.201 Facility Common Name Facility Identi?cation Number (FIN) REM 42" Process Unit or Area Common Name Rich Eagle Ford Mainline Cause of Emissions Event, Excess Opacity Event, or Reason for Scheduled Activity: ETC experienced a rupture on a 42" natural gas pipeline which was immediately ignited causing all gas vapors to be combusted. At this time the root cause remains under investigation. Actions Taken, of Being Taken, to Minimize Emissions and/or Correct the Situation: ETC immediately responded by blocking in and isolating the affected pipeline segment and so mitigated the emissions. Furthermore, upon discovery of the incident, ETC collaborated with local of?cials to secure the area and ensure the safety of the public. Equipment and materials have been dispatched to the location to complete the necessary repairs. Basis Used to Determine Quantities and Any additional Information Necessary to Evaluate the Event: Gas quality. process knowledge and incident description. ETC is still gathering data and is therefore reporting a conservative estimate of gas loss. ETC anticipates an actual volume loss to be much lower which will be reflected in the Final Report. Person Making Initial Notification Bart Husky (361) 876-9648 Initial Notification Date/Time 2015-6-15 17:46 Method STEERS Incident Primary Contact Bart Husky (361) 876-9648 Jurisdiction(s) Notified REGION 14 CORPUS CHRISTI Agency Comments Assigned Staff Member: Susan Hoelscher Attachmentl Inv. No. 1280561 Page 5 of Susan Hoelscher From: Upset14 Sent: Monday, June 15, 2015 7:46 PM To: Upset14 Subject: Incidents for Confirmation 121591 were entered today" DO NOT REPLY TO THIS EMAIL TCEO. incident #215804 (AEME ID 127948), with a Discovery Date of 06/14/2015 08:30 PM, Type of EMISSIONS EVENT was entered today for Regulated Entity: RN104583554 ETC TEXAS PL PIPELINE COUNTY This email is sent whenever an incident is submitted through STEERS. If this incident was submitted via STEERS using a probationary account, or if this incident was entered/modi?ed by TCEQ staff, you will have until midnight 06/18/2015 to verify the information on the lncident(s). Otherwise, you may disregard this email. to verify the information on the lncident(s). You may review the information on this incident online at: WARNING: As we either enter or correct data for your incident report form, the database is updated immediately. If you try to review this incident before our data entry is complete, you may see only part of the data from your incident report??for example, our database may show that the incident occurred but show no data on contaminants. If this happens, please do not repudiate the information. Instead, cancel the process and review the incident again later. Attachment 1 Inv. No. 1280561 Susan Hoelscher From: STEERS Sent: Monday, June 15, 2015 5:47 PM To: Upsetl4 Subject: AEME Initial Notification The following AEME initial notification was submitted via STEERS: Regulated Entity: RN104583554 Name of Owner/Operator: ETC TEXAS PIPELINE LTD Incident Type: EMISSIONS EVENT Incident Status: VERIFIED Physical Location: COUNTY PIPELINE SEGMENT Event Start Date and time: 06/14/2015 20:30 Contact Name: Bart Husky Contact Phone: 361 8769648 ext: Confirmation Number: 121591 Cause (first 1000 characters): ETC experienced a rupture on a 42" natural gas pipeline which was immediately ignited causing all gas vapors to be combusted. At this time the root cause remains under investigation. This initial notification has NOT YET been entered into the of?cial TCEQ CCEDS database. Once it has been entered, you will receive another email containing the incident tracking number. If you have any questions please-contact the STEERS Help Line at 512-239?6925 or by e-mail at steers@tceq.texas.gov. Attachment 1 Inv. No. 1280561 ?1 0?1 A TCEQ ATTACHMENT 2 Additional Information Total Pages: 2 Investigation No. 1280561 RN104583554 ETC Texas PL Pipeline DeWitt County CN601587652 ETC Texas Pipeline, Ltd. September 9, 2015 September 15, 2015 Susan Hoelscher From: Husky, Bart Sent: Tuesday, September 15, 2015 12:03 PM To: Susan Hoelscher Subject: RE: ETC Texas Pipeline Dewitt County-Emissions Event Incident No. 215804 Mrs. Hoelscher, With regard to your inquiries for incident No.215804, please see the responses below. 1. What was determined to be the root cause of the pipeline breach? Because the investigation is still ongoing, ETC will refrain from providing a root cause. When was the affected segment of pipeline installed and/or last replaced? This is essentially a new pipeline installed in approximately September of 2012. Provide maintenance records for the last two years on the affected segment of pipeline. Because the pipeline was installed in approximately September of 2012, and therefore, essentially new, there has been no maintenance or repair requirement and no indication that maintenance or repair was necessary. Further, this line is classi?ed as non?jurisdictional so does not require a routine maintenance schedule. However, consistent with conservative operating culture, ETC practices proactive maintenance activities to include the following: - Annually valve maintenance - - aerial surveys Pigging is conducted on an as needed basis depending on operating conditions of the pipeline. Continuously - monitoring via Gas Control Additional unscheduled activities include but are not limited to ROW inspections, line crossing inspections, and erosion mitigation. If you have additional questions, please let me know. Thank you. Bart Husky Energy Transfer Senior Environmental Specialist 2900 South Hwy 16, 4-miles Tilden, Texas 78072 361.876.9648 From: Susan Hoelscher Sent: Wednesday, September 09, 2015 10:55 AM To: Husky, Bart Subject: ETC Texas Pipeline Dewitt County-Emissions Event Incident No. 215804 Good Morning Mr. Husky, I have reviewed the final report for the emissions event, incident No. 215804, which occurred on June 14, 2015 on the Rich Eagle Ford Mainline, 42" natural gas pipeline, located in Dewitt County. Additional information is required to 1 Attachment 2 an. NO. 1280561 P909. of complete the review. Please provide responses/documentation to the items below by next week, Wednesday, September 16, 2015 or sooner, if. possible. If you have any additional information regarding this event, please provide it at this time. 1. What was determined to be the root cause ofthe pipeline breach? 2. When was the affected segment of pipeline installed and/or last replaced? 3. Provide maintenance records for the last two years on the affected segment of pipeline. I appreciate your assistance with this matter. If you have any questions, feel free to contact me. Thank you, Susan Hoelscher Air Investigator TCEQ Region 14-Corpus Christi (P) 361-825-3118 (F) 361-825?3101 susan.hoelscher@tceq.texas.gov Private and con?dential as detailed here. If you cannot access hyperlink, please e-mail sender. Attachment 2 Inv. No. 128057761