ENERFIN GATHERING LLC

Incident Narrative

DURING ROUTINE PIGGING OPERATION TO REMOVE HYDROCARBON LIQUIDS AND WATER FROM A 60-PSIG GAS GATHERING PIPELINE, THE FLUIDS WERE DECANTED IN A CONTROLLED MANNER INTO A TEMPORARY ATMOSPHERIC STORAGE (FRAC) TANK. OPERATING PROCEDURES DID NOT ADDRESS THE NEED TO ESTABLISH A SAFETY ZONE (VISUAL WARNINGS AND WINDSOCKS) AROUND THE PIPELINE PIGGING OPERATION AREA TO HELP TO ELIMINATE RANDOM IGNITION SOURCES IN AN AREA EXPECTED TO HAVE TEMPORARY EXPOSURE TO HYDROCARBON VAPORS. ULTIMATELY, IT WAS A VEHICLE WHICH WAS PARKED TOO CLOSE TO THE WORK AREA WHICH PROVIDED THE IGNITION SOURCE WHEN AN EMPLOYEE ENTERED THE VEHICLE AND TURNED THE IGNITION KEY. THE RELEASE OF HYDROCARBON VAPORS WAS THE EXPECTED RESULT OF THE CONTROLLED DEPRESSURIZING OF A STREAM OF HYDROCARBON LIQUIDS INTO AN ATMOSPHERIC STORAGE VESSEL. THE ROOT CAUSE OF THE FIRE WAS A FAILURE OF OPERATING PROCEDURES IN ALLOWING A POTENTIAL SOURCE OF IGNITION (A VEHICLE) TO BE LOCATED WITHIN AN AREA EXPECTED TO BE TEMPORARILY EXPOSED TO EVOLVED HYDROCARBON VAPORS. THIS INCIDENT WAS NOT THE RESULT OF ANY PIPELINE MATERIAL FAILURE, ABNORMAL OPERATING CONDITIONS (I.E., OVERPRESSURE CONDITION), OR INCIDENTAL THIRD-PARTY DAMAGE TO THE PIPELINE FACILITIES.