PHMSA FIR, Enterprise Products Operating LLC, 2009-08-04
PHMSA FIR, Enterprise Products Operating LLC, 2009-08-04
Page 1Official PDFDOT US Department of Transportation PHMSA Pipeline and Hazardous Materials Safety Administration OPS Office of Pipeline Safety Southwest Region Principal Investigator Jon Manning Region Director R.M. Seeley Date of Report 10/20/2011 Subject Failure Investigation Report – Enterprise Offshore Gas Platform Fire Operator, Location, & Consequences Date of Failure 8/4/2009 Commodity Released Natural Gas City/County & State Gulf of Mexico – Offshore OpID & Operator Name 31618 Enterprise Products Operating, LLC Unit # & Unit Name 12174 High Island Pipeline System Offshore Gas SMART Activity # 125757 Milepost / Location High Island Off-Shore Platform 264B Type of Failure Platform fire caused by Incorrect Operation Fatalities 0 Injuries 0 Description of area impacted Offshore gas transportation platform Property Damage $7,061#
Page 2Failure Investigation Report – Enterprise Offshore Gas Platform Fire 8/4/2009 Executive Summary On August 4, 2009, Enterprise Products Operating, LLC (Enterprise, the Operator) reported to the NRC (No. 913841) a fire and explosion on their High Island Off-Shore (HIOS) 264B platform in the Gulf of Mexico (GOM). There were no reported injuries but the incident required the platform to be evacuated. The fire occurred just after Enterprise and contract personnel started a turbine/compressor set designated as the Number 2 Unit. This unit had been overhauled in March 2009 but operational conditions had not required the unit to be operated since that time. Several unsuccessful attempts were made to start the unit and personnel bypassed some of the interlocks during this process. Enterprise personnel reported that the sixth attempt to start the Number 2 unit was successful. Just after the Number 2 Unit was started, Enterprise personnel noted a gas smell in the control room and observed that the hydrocarbon detectors were indicating readings of approximately 34% of the Lower Explosive Limit (LEL) in the engine room. An Enterprise operations employee on the upper deck of the platform observed the 6-inch lubrication oil vent on the roof was discharging a stream of hydrocarbon vapors. The employee then went to the control room and ordered the Number 2 Unit shut down. Heat from the exhaust stack is believed to have been the ignition source for the hydrocarbon vapors coming from the lubrication oil vent. Enterprise personnel reported that they attempted to extinguish the fire but migrating hydrocarbon vapors ignited and flames quickly engulfed the upper deck of the platform. Personnel were ordered to activate the Emergency Shutdown (ESD) system and evacuate the platform. The next series of events are not as certain, but the most probable scenario is that when the ESD system was activated high pressure gas back-flowed into the Number 1 Unit starter turbine through a malfunctioning check valve. The check valve was intended to isolate piping and equipment with a lower pressure rating from the high pressure ESD gas. The high pressure gas ruptured the starter case allowing gas to flow into the engine room. An explosion and second fire then occurred on the main deck. The explosion and fires on the main and upper decks resulted in extensive damage to the equipment and piping on the platform. Enterprise has decided to neither repair nor replace the damaged pipeline facilities. The reported $7,061 property damage represents only the cost of lost gas since the pipeline facilities were fully depreciated and had no value. System Details The Enterprise High Island pipeline system consists of approximately 233 miles of offshore natural gas pipelines and eight platforms in the Gulf of Mexico (GOM) that include PHMSA regulated equipment. The incident occurred on the Enterprise High Island Off-Shore (HIOS) 264B platform. The HIOS 264 facility is located in approximately 150 feet of water approximately 87 miles off the coast of Sabine Pass, TX, and consists of three platforms designated as A, B, and C, interconnected with bridges. The 264A platform receives gas and separates liquids from three upstream HIOS pipelines at approximately 800 psig. The gas then flows to the 264B platform where it can be compressed to approximately 950 psig when operational conditions warrant. The compressed gas then is returned to the 264A platform where the liquids are re-injected into the stream and transported downstream to the West Cameron 167 platform through a single 42-inch pipeline. The 264B platform includes two engine room buildings, metering facilities, a warehouse, a control room, a communications shed, and a clerk’s office. The 264C platform includes living quarters, a helicopter landing deck, and a survival craft. A partial map of the HIOS system is included in Appendix A. Page 2 of 5#
Page 3Failure Investigation Report – Enterprise Offshore Gas Platform Fire 8/4/2009 The HIOS 264B platform includes two compressor buildings. One compressor building houses unit Numbers 1 and 2, the second houses unit Number 3. Numbers 1 and 2 are identical General Electric 22,000 horsepower Frame 3 units, and Number 3 is a 33,000 horsepower General Electric Frame 5. Each unit consists of the basic components of a starter turbine, centrifugal compressor, and power turbine. The incident involved unit Number 2. The incident occurred on the HIOS 264B platform located at Latitude 28.4115 degrees; Longitude 93.7393 degrees. Photographs showing the HIOS 264 platforms and incident damage on the HIOS 264B platform are included in Appendix A. Events Leading up to the Failure Enterprise personnel report that the platform was operating normally prior to the incident. The platform normally receives approximately 250,000 – 300,000 Mcfd from three upstream pipelines and operates in a pressure range of approximately 800 psig – 950 psig. Accounts from Enterprise personnel indicate that Enterprise personnel and technicians from NAES Turbine Services had just started the Number 2 turbine unit when the incident occurred. Emergency Response On August 4, 2009, Enterprise Products Operating, LLC (Enterprise, the Operator) reported to the NRC (No. 913841) a fire and explosion on their High Island Off-Shore (HIOS) 264B platform in the Gulf of Mexico (GOM) at approximately 11:00 PM (Appendix B). There were no reported injuries but the incident required the platform to be evacuated. A copy of the Enterprise incident report to PHMSA is Appendix C. The fire occurred just after Enterprise and contract personnel from NAES Turbine Services started a turbine/compressor set designated as the Number 2 Unit. This unit had been overhauled in March 2009 but the unit had not operated since that time. Several unsuccessful attempts were made to start the unit and personnel bypassed some of the interlocks during this process. Enterprise personnel reported that the sixth attempt to start the Number 2 unit was successful. Just after the Number 2 Unit was started, Enterprise personnel noted a gas smell in the control room and observed that the hydrocarbon detectors were indicating readings of approximately 34% of the Lower Explosive Limit (LEL) in the engine room. An Enterprise operations employee on the upper deck of the platform observed the 6-inch lubrication oil vent on the roof was discharging a stream of hydrocarbon vapors. The employee then went to the control room and ordered the Number 2 Unit shut down. The venting hydrocarbon vapors ignited and the fire quickly spread over the upper deck of the platform. Enterprise operations personnel attempted to fight the fire using a wheeled fire extinguisher but were not successful. There was initially no fire water pressure as the pump failed to start in automatic mode. The fire quickly engulfed the upper deck and Enterprise operations personnel activated the ESD system and ordered the platform to be evacuated. The ESD system is designed to shut down the compressor units and vent the gas to the flare located on a structure off of Platform B. Failure of a check valve after the ESD system was activated is believed to have allowed high pressure gas to backflow into the low pressure starter turbine piping and ruptured the starter turbine case. The escaping gas resulted in an explosion and second fire on the main deck of the platform. The fire water pump did not initially start in automatic mode and had to be manually started. Enterprise personnel initially mustered on Platform C, but were not able to start the escape craft. The personnel then moved to Platform A and were evacuated by a nearby work boat, the Gulf Endeavor. Page 3 of 5#
Page 4Failure Investigation Report – Enterprise Offshore Gas Platform Fire 8/4/2009 Summary of Return-to-Service Enterprise has decided to neither repair nor replace the damaged pipeline facilities. The reported $7,061 property damage represents only the cost of lost gas since the pipeline facilities were fully depreciated and had no value. Investigation Details According to responses provided by Enterprise personnel and the incident investigation performed by BakerRisk, a compressor drain valve was found to be in the open position. Enterprise personnel and contractor accounts of the actions taken during the startup attempts for unit Number 2 indicate liquid was drained from the compressor case using the drain valve. The open compressor case drain valve allowed high pressure gas to enter the condensate drain piping. The condensate drain piping is interconnected with the lubrication oil/seal vent piping that terminates above the turbine exhaust stacks. It is likely that gas flowed through the interconnected piping to the vent above the turbine exhaust stack and was ignited, resulting in the fire on the upper deck. The next series of events are not as certain and the determination is made more difficult as the piping associated with various systems on the platform is complex, interconnected, and has several potential flow-paths depending on the specific operational mode. Based on the investigation performed by BakerRisk and responses provided by Enterprise personnel, the most probable scenario is that when personnel activated the ESD system high pressure gas (>800 psig – 950 psig) from the discharge piping back-flowed into the Number 1 Unit starter turbine through a failed check valve. The starter gas piping is vented into the ESD flare system and a check valve designed to prevent the high pressure ESD gas from back-flowing into the lower pressure starter gas piping on unit Number 1 was determined to have failed. The case of the starter turbine, which was rated for an operating pressure of 125 psig, was ruptured by the high pressure ESD gas, causing gas to flow into the engine room. Ignition of this gas resulted in an explosion and second fire on the main deck of the platform. BakerRisk performed a forensic analysis of the major components that are suspected to have been involved in the failure, including the unit Number 2 case drain valve unit, the unit Number 1 pressure safety valve (PSV, M838), and the Wheatley ANSI 600 check valve (M805). The unit Number 2 case drain valve was found to be in the open position during the post incident investigation allowing high pressure gas to discharge through the lubrication oil vent piping that terminates above the turbine exhaust stack on the upper deck. The pressure relief valve PSV M838 was determined to have been functional but was apparently not sized adequately to relieve the unintended backflow of gas due to activation of the ESD system. The Wheatley check valve M805 was determined to have failed, allowing high pressure gas to backflow into lower pressure starter turbine piping, rupturing the case. A photograph of the case drain valve, photographs of the pressure relief valve, and photographs of the Wheatley check valve are included in Appendix D, E, and F respectively. A copy of the PHMSA question matrix submitted to Enterprise is included in Appendix G, and a complete copy of the BakerRisk Incident Investigation Report is included in Appendix H. The forensic analysis concluded that rupture of the starter turbine case was caused by internal pressure rather than an external explosion. The starter piping is protected by a relief valve (PSV M838) that was tested and torn down after the incident. BakerRisk determined the relief valve was functioning properly. Analysis of the check valve (M805) found the check valve clapper had dislodged from its normal operating position and that the retainer pin had failed. The BakerRisk analysis determined that Page 4 of 5#
Page 5Failure Investigation Report – Enterprise Offshore Gas Platform Fire 8/4/2009 the retainer pin was partially cracked prior to the incident and the sudden high pressure gas surge resulting from the ESD caused the remaining ligament to fail. According to accounts from Enterprise personnel and the BakerRisk report, Enterprise personnel gathered at the designated muster location on Platform C to evacuate the platform using the escape watercraft but could not start the engine. Personnel abandoned the escape craft and mustered on Platform A where they were evacuated by a nearby workboat, the Gulf Endeavor. A copy of the operator’s PHMSA 7100.2 Report is included in Appendix C. Findings and Contributing Factors The incident was likely initiated when Enterprise and NAES Turbine Services personnel left a turbine casing drain valve open during repeated restart attempts. This allowed gas to be vented through the lubricating oil vent on the roof. The initial fire on the top deck of the platform resulted from ignition of the vented gas. The probable cause of the explosion and fire that occurred on the main deck of the platform was failure of a check valve designed to prevent the backflow of high pressure ESD gas into low pressure starter turbine piping. High pressure gas is believed to have ruptured the starter turbine case allowing gas to enter the engine room. Contributing Factors include 1. Tests performed by BakerRisk determined that the check valve clapper retaining pin was cracked prior to the incident and that the ESD event caused the remaining ligament to fail. 2. The fire water pump did not automatically start as designed so there was no fire water pressure on the upper deck during the initial fire. Appendices A System Map B NRC Report # 913841 C Enterprise Incident Report to PHMSA D Case Drain Valve Photographs E Pressure Relief Valve Photographs F Check Valve Photographs H BakerRisk Report Page 5 of 5#
Page 6Appendix A System Map This document is on file at PHMSA#
Page 7Page 1 of 3 NATIONAL RESPONSE CENTER 1-800-424-8802 Information released to a third party shall comply with any *** For Public Use *** applicable federal and/or state Freedom of Information and Privacy Laws Incident Report # 913841 INCIDENT DESCRIPTION **** THIS IS A POTENTIAL RELEASE **** Incident Type: PLATFORM *Report taken at 00:20 on 05-AUG-09 Affected Area: Incident Cause: EXPLOSION The incident occurred on 04-AUG-09 at 22:30 local time. Affected Medium: NON-RELEASE (N/A) PLATFORM FIRE SUSPECTED RESPONSIBLE PARTY Organization: HIGH ISLAND SYSTEMS HOUMA, LA 70301 Type of Organization: PRIVATE ENTERPRISE INCIDENT LOCATION BLOCK 64 County: HIGH ISLAND State: LA Latitude: 28° 28' 16" N Longitude: 093° 44' 21" W PLATFORM INCIDENT POTENTIALLY RELEASED MATERIAL (S) CHRIS Code: OIL 1so Known As Official Material Name: OIL: CRUDE ty Released: 0 UNKNOWN AMOUN DESCRIPTION OF INCIDENT CALLER IS REPORTING A FIRE ON A PLATFORM DUE TO UNKNOWN CAUSES. INCIDENT DETAILS Platform Letter: B Platform Rig Name: Location Area ID: HIGH ISLAND Berth Slip Number: ier Dock Number tate Lease Number INJURIES: Fire Involved: YES DAMAGES FATALITIES: NO Fire Extinguished: NO EVACUATIONS: NO Hospitalized: Passenger: Emp1/Crew: Passenger: YES Who Evacuated: EMPLOYEES Radius/Area: Occupant: Damages: YES $ Length of Direction of Closure Type Air: N Description of Closure Closure Closure Road: N Artery: N Major http://www.nrc.uscg.mil/reports/rwservlet?standard web+inc seg=913841 4/26/2011#
Page 8Page 2 of 3 Waterway: Track: N Passengers Transferred: NO Environmental Impact: UNKNOWN Media Interest: NONE Community Impact due to Material: ____________________________________________________________________________ REMEDIAL ACTIONS ALL PERSONNEL WERE EVACUATED AND ACCOUNTED FOR, EMERGENCY SYSTEM ACTIVATED. Release Secured: UNKNOWN Release Rate: Estimated Release Duration: ____________________________________________________________________________ WEATHER Weather: CLEAR, ºF Wind speed: 15 MPH Wind direction: SW ____________________________________________________________________________ ADDITIONAL AGENCIES NOTIFIED Federal: USCG, MMS State/Local: NONE State/Local On Scene: NONE State Agency Number: NONE ____________________________________________________________________________ NOTIFICATIONS BY NRC USCG HSOC AT DHS (USCG HSOC DESK) 05-AUG-09 00:29 USCG ICC (ICC ONI) 05-AUG-09 00:29 DOT CRISIS MANAGEMENT CENTER (MAIN OFFICE) 05-AUG-09 00:29 FBI LOUISIANA ATN: HILLARY ROSSMAN (MAIN OFFICE) 05-AUG-09 00:29 FBI NEW ORLEANS FIELD OFC (MAIN OFFICE) 05-AUG-09 00:29 FBI STRATEGIC INFO OPERATIONS CNTR (MAIN OFFICE) 05-AUG-09 00:33 FLD INTEL SUPPORT TEAM NEW ORLEANS (SUPERVISOR, FIST NEW ORLEANS) 05-AUG-09 00:29 USCG COMMAND CENTER (MAIN OFFICE) 05-AUG-09 00:33 JFO-LA (COMMAND CENTER) 05-AUG-09 00:29 JFO-LA (FEMA JFO LA) 05-AUG-09 00:29 LA DEPT OF ENV QUAL (MAIN OFFICE) 05-AUG-09 00:29 LA DEPT OF WILDLIFE AND FISHERIES (ATTN: VAUGHAN MCDONALD) 05-AUG-09 00:29 LA OFFICE OF EMERGENCY PREPAREDNESS (MAIN OFFICE) 05-AUG-09 00:29 LA OFFICE OF GOV (MAIN OFFICE) 05-AUG-09 00:29 LA OFFICE OF PUBLIC HEALTH (MAIN OFFICE) 05-AUG-09 00:29 NATIONAL INFRASTRUCTURE COORD CTR (MAIN OFFICE) 05-AUG-09 00:29 NOAA RPTS FOR LA (MAIN OFFICE) 05-AUG-09 00:29 NATIONAL RESPONSE CENTER HQ (MAIN OFFICE) 05-AUG-09 00:33 NTSB PIPELINE (MAIN OFFICE) 05-AUG-09 00:29 HOMELAND SEC COORDINATION CENTER (MAIN OFFICE) 05-AUG-09 00:29 MSU PORT ARTHUR (MAIN OFFICE) http://www.nrc.uscg.mil/reports/rwservlet?standard web+inc _ _ seq=913841 4/26/2011#
Page 9Page 3 of 3 05-AUG-09 00:35 PIPELINE & HAZMAT SAFETY ADMIN (OFFICE OF PIPELINE SAFETY (AUTO)) 05-AUG-09 00:29 PIPELINE & HAZMAT SAFETY ADMIN (OFFICE OF PIPELINE SAFETY WEEKDAYS (VERBAL)) 05-AUG-09 00:36 LA STATE POLICE (MAIN OFFICE) 05-AUG-09 00:29 ____________________________________________________________________________ ADDITIONAL INFORMATION CALLER HAD NO ADDITIONAL INFORMATION. ___________________________________________________________________________ *** END INCIDENT REPORT # 913841 *** http://www.nrc.uscg.mil/reports/rwservlet?standard web+inc _ _ seq=913841 4/26/2011#
Page 10U.S Department of Transportation Pipeline and Hazardous Materials Safety Administration INCIDENT REPORT – GAS TRANSMISSION AND GATHERING SYSTEMS Report format corresponds to Form PHMSA F 7100.2 (01-2002) Report Date September 8, 2009 No. 20090097 - 8541 PART A – GENERAL INFORMATION N Original Report Y Supplemental Report Y Final Report 1. Operator Name and Address a. Operator's 5-digit Identification Number 31618 b. If Operator does not own the pipeline, enter Owner's 5-digit Identification Number (when known) c. Name of Operator ENTERPRISE PRODUCTS OPERATING LLC d. Operator street address 1100 LOUISIANA e. Operator address City HOUSTON County or Parish HARRIS State TX Zip code 77002 2. Time and date of the incident Hour 22:00 Date of the incident 8/4/2009 3. Location of incident a. Street or nearest street or road b. City County or Parish c. State Zip Code d. Mile Post/Valve Station e. Survey Station No f. Latitude 28.4115 Longitude 93.7393 g. Class location description Onshore (Class Location) Offshore Y Area HIGH ISLAND Block # 264B State Outer Continental Shelf Y h. Accident on Federal Land other than Outer Continental Shelf N i. Is pipeline Interstate Y 4. Type of leak or rupture Leak or Rupture OTHER Type of Leak - Puncture, diameter (inches) Type of Rupture - Tear/Crack, length (inches) - Propagation Length, total, both sides (feet) Other (specify) PLATFORM EXPLOSION AND FIRE 5. Consequences a. Fatality No Total number of people 0 Employees 0 General Public 0 Non-employee Contractors 0 b. Injury requiring inpatient hospitalization No Total number of people 0 Employees 0 1#
Page 11General Public 0 Non-employee Contractors 0 c. Property damage/loss (estimated) Yes Total $ 7,061 Gas loss $ 7,061 Operator damage $ 0 Public/private property damage $ 0 d. Release Occurred in a 'High Consequence Area' N e. Gas Ignited / Gas did not ignite Gas did not Ignite f. Explosion / No Explosion EXPLOSION g. Evacuation (general public only) Y Number of people 39 Evacuation Reason COMPANY POLICY 6. Elapsed time until area was made safe Hours 38 Minutes 50 7. Telephone Report NRC Report Number 913841 Date 8/4/2009 8. Pressure a. Estimated pressure at point and time of incident (PSIG) 0.00 b. Max. allowable operating pressure (MAOP) (PSIG) c. MAOP established by 49 CFR section d. Did an over pressurization occur relating to the incident? N PART B – PREPARER AND AUTHORIZED SIGNATURE Preparer's Name JOEL E. KOHLER Preparer's Title Area Code and Telephone Number 7133814830 Preparer's E-mail Address JKOHLER@EPROD.COM Area Code and Facsimile Number 7133816660 PART C – ORIGIN OF THE INCIDENT 1. Incident occurred on GATHERING 2. Failure occurred on OTHER Other (specify) PLATFORM 3. Material involved (pipe, fitting, or other component) STEEL Plastic failure was a. ductile N b. brittle N c. joint failure N Material other than plastic or steel 4. Part of the system involved in incident COMPRESSOR Other (specify) 5. Year the pipe or component which failed was installed 1978 PART D – MATERIAL SPECIFICATION 1.Nominal pipe size (NPS) (inches) 2. Wall thickness inches 3. Specification SMYS 4. Seam type 5. Valve type 6. Pipe or valve manufactured by in year PART E - ENVIRONMENT 1. Area of incident INSIDE/UNDER BUILDING Other (specify) Depth of cover (inches) 2#
Page 12PART F – APPARENT CAUSE F1 – CORROSION 1. External Corrosion 2. Internal Corrosion Complete items a-e where applicable a. Pipe Coating b. Visual Examination Other (specify) c. Cause of Corrosion Other (specify) d. Was corroded part of pipeline considered to be under cathodic protection prior to discovering incident? Year Protection Started e. Was pipe previously damaged in the area of corrosion? How long prior to incident? Years Months F2 – NATURAL FORCES 3. Earth Movement Description Other (specify) 4. Lightning 5. Heavy Rains/Floods Description Other (specify) 6. Temperature Description Other (specify) 7. High Winds F3 - EXCAVATION 8. Operator Excavation Damage (including their contractors) / Not Third Party 9. Third Party Excavation Damage a. Excavator group b. Type Other (specify) c. Did operator get prior notification of excavation activity? Date received mo. day yr. Notification received from d. Was pipeline marked? Temporary markings Permanent markings Marks were Were marks made within required time? F4 – OTHER OUTSIDE FORCE DAMAGE 10. Fire/Explosion as primary cause of failure Description 11. Car, truck or other vehicle not relating to excavation activity damaging pipe 12. Rupture of Previously Damaged Pipe 13. Vandalism F5 – MATERIAL AND WELDS Material 14. Body of Pipe Description Other (specify) 15. Component Description Other (specify) 16. Joint 3#
Page 13Description Other (specify) Weld 17. Butt Description Other (specify) 18. Fillet Description Other (specify) 19. Pipe Seam Description Other (specify) Complete a-g if you indicate any cause in part F5 a. Type of failure Construction Defect NO DATA Description Material Defect NO DATA b. Was failure due to pipe damage sustained in transportation to the construction or fabrication site? c. Was part which leaked pressure tested before incident occurred? d. Date of test Month Day Year e. Test medium Other (specify) f. Time held at test pressure hr g. Estimated test pressure at point of incident (PSIG) F6 – EQUIPMENT AND OPERATIONS 20. Malfunction of Control/Relief Equipment Description Other (specify) 21. Threads Stripped, Broken Pipe Coupling Description Other (specify) 22. Ruptured or Leaking Seal/Pump Packing 23. Incorrect Operation Yes a. Type FAILURE TO FOLLOW PROPER PROCEDURES Other (specify) b. Number of employees involved who failed post-incident test Drug test 0 Alcohol test 0 c. Were most senior employee(s) involved qualified? Y d. Hours on duty 14 F7 – OTHER 24. Miscellaneous Description 25. Unknown Description PART G – NARRATIVE DESCRIPTION OF FACTORS CONTRIBUTING TO THE EVENT AN EXPLOSION AND FIRE OCCURRED ON HIGH ISLAND BLOCK 264 PLATFORM B (HI 264B) IN AND AROUND THE COMPRESSOR BUILDING. ACCORDING TO THE RECENTLY RECEIVED BAKERRISK REPORT, THE CAUSE OF THE INCIDENT IS AS FOLLOWS: A) THE MOST PROBABLE SCENARIO SUGGESTS THE INITIAL FIRE RESULTED FROM A GAS RELEASE WHILE ATTEMPTING TO START THE NO. 2 TURBINE/COMPRESSOR SET. B) THE NO. 2 COMPRESSOR OUTBOARD CASE DRAIN WAS LEFT OPEN DURING STARTUP AND EVENTUAL LOADING OF THE COMPRESSOR. REPLACEMENT COST FOR THE COMPRESSOR PLATFORM AND EQUIPMENT IS ESTIMATED TO BE IN THE RANGE OF $35 - $70 MILLION, HOWEVER ENTERPRISE HAS ELECTED TO NOT REPAIR OR 4#
Page 14REPLACE AT THIS TIME.#
Page 15Appendix D – HIOS 264 Platform Photographs Page 12 of 17#
Page 23Appendix F – Check Valve Photographs Page 14 of 17#
Page 28Appendix G – Starter Turbine, Piping, and Pressure Relief Valve Photos Page 15 of 17#
Page 31S-235 PSV M838 on Site #2634 Description + Location Startor BakerRisk Identification Tag Item # МИНИКАМИ Name Dilet ute /on 2404/11:40 AN E - O15: Wust side of renf ,t „.ll of CE Sit », (85 pig) turbine 4-t#
Page 32Appendix H BakerRisk Report This document is on file at PHMSA#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.