CRESCENT MIDSTREAM, LLC

Incident Narrative

TANK 2051 AT THE RACELAND FACILITY WAS TAKEN OUT OF SERVICE FOR INTEGRITY INSPECTIONS AND FOR MAINTENANCE. TWO FRAC TANKS (IDENTIFIED AS TANK/VESSEL IN PART C) WERE PUT INSIDE THE SECONDARY CONTAINMENT AREA WITH TANK 2051 TO FACILITATE THE CLEANING OF TANK 2051. AFTER CLEANING WAS CONCLUDED, THE FRAC TANKS WERE LEFT IN PLACE. HOSES AND A FLEX VALVE WERE CONNECTED BETWEEN THE PERMANENT PIPING AND THE FRAC TANKS TO ALLOW FOR PRESSURE CONTROL, KEEPING THE PIPELINE PRESSURE FROM REACHING THE MAXIMUM OPERATING PRESSURE (MOP) OF THE ASSOCIATED PERMANENT PIPING AND PIPELINES. THE FLEX VALVE WAS INSTALLED TO RELIEVE PRESSURE FROM THE PIPELINES AND THE TEMPORARY HOSES TO THE FRAC TANKS. THE PRESSURE RANGE THAT CAUSED THE FLEX VALVE TO OPERATE WAS BETWEEN 150 AND 160 PSIG. ON THE EVENING OF JULY 26, CRUDE OIL FROM EMPIRE AND GRAND ISLE WAS TO BE TRANSFERRED THROUGH THE RACELAND FACILITY DOWN THE SOUTH LINE TO ANCHORAGE. PUMP 1B WAS USED FOR THIS TRANSFER. PUMP 1B REPEATEDLY SHUTDOWN. SEVERAL TIMES DURING THE RESTARTS OF THE PUMP, THE FLEX VALVE OPERATED AND PUT OIL INTO THE FRAC TANKS. EVENTUALLY, THE FRAC TANKS OVERFILLED AND PUT OIL ON THE GROUND WITHIN THE SECONDARY CONTAINMENT AREA. THE SECONDARY CONTAINMENT AREA WAS DESIGNED TO BE DRAINED THROUGH SIX VALVES. ONE OF THESE VALVES WAS OPEN DURING THIS TIME PERIOD, ALLOWING FOR THE OIL IN THE CONTAINMENT AREA TO EXIT TO BAYOU LAFOURCHE. CRESCENT HAS NOT BE NOTIFIED BY THE EPA OF LONG TERM ENVIRONMENTAL IMPACT ASSESSMENT REQUIREMENTS.