SINCLAIR TRANSPORTATION COMPANY

Incident Narrative

ON OCTOBER 25, 2023, AT APPROXIMATELY 11:00 AM MST, PERSONNEL AT THE DENVER PRODUCTS TERMINAL OBSERVED A DRIP FROM A THERMAL RELIEF VALVE SITUATED ON A RECEIPT LINE BETWEEN TWO REGULATED BREAKOUT TANKS. THEY PROMPTLY STOPPED THE LEAK BY PRESSING ON THE QUICK-CONNECT FITTING AT THE BASE OF THE VALVE AND NOTIFIED TERMINAL SUPERVISION AND THE HEP CONTROL CENTER. INITIALLY, PERSONNEL ESTIMATED A RELEASE OF APPROXIMATELY 1-2 GALLONS, BELIEVED TO BE WITHIN CONTAINMENT (AND NOT REPORTABLE). HOWEVER, DURING THE PROCESS OF REMOVING CONTAMINATED SOIL FOR PERMANENT DISPOSAL, PERSONNEL REALIZED THERE MIGHT HAVE BEEN MORE PRODUCT LEAKED THAN INITIALLY ESTIMATED. AT AROUND 3:23 PM MST, TERMINAL PERSONNEL CONTACTED HEP'S ENVIRONMENTAL TEAM TO CONSULT ON THE ESTIMATED RELEASE AMOUNT AND PROPER DISPOSAL OF THE CONTAMINATED SOIL. BY 4:21 PM MST, A DETERMINATION WAS MADE THAT APPROXIMATELY 1 BARREL OF DIESEL PRODUCT HAD BEEN RELEASED. HOWEVER, TERMINAL PERSONNEL STILL CONSIDERED THE AFFECTED SOIL TO BE WITHIN CONTAINMENT AND THEREFORE NOT REPORTABLE. ON OCTOBER 26, HEP'S ENVIRONMENTAL TEAM RECEIVED CLARIFYING INFORMATION, WHICH WAS THEN TRANSFERRED TO HEP'S REGULATORY TEAM, WHO SUBSEQUENTLY IDENTIFIED THE EVENT AS REPORTABLE TO PHMSA. NOTIFICATIONS WERE THEN MADE TO NRC AND THE CDPHE. IT'S IMPORTANT TO NOTE THAT AT THE TIME OF THE LEAK IDENTIFICATION ON OCTOBER 25, THE TERMINAL WAS NOT RECEIVING ANY BATCHES, SO THE REGULATED MAINLINE WAS NOT SHUT DOWN. ADDITIONALLY, WHILE SCADA AND CPM ARE OPERATIONAL FOR THE REGULATED MAINLINE, THEY ARE NOT FOR THE RECEIPT LINE. FURTHERMORE, CERTAIN INFORMATION AND EVENT-RELATED COSTS, SPECIFICALLY ENVIRONMENTAL ITEMS, ARE CURRENTLY PENDING (INCLUDING THE FINAL RECOVERED VOLUME AND WHY ""0"" HAS BEEN ENTERED AT THIS TIME). THE APPARENT CAUSE OF THE LEAK IS DUE TO A FAILURE OF THE SPRING-LOADED SEAL WITHIN THE QUICK-CONNECT FITTING AT THE BASE OF THE THERMAL RELIEF VALVE. FOR CLARIFICATION, THE QUICK-CONNECT FITTING IS A PERMANENT FIXTURE AT THE BASE OF THE VALVE, DESIGNED FOR EASILY CONNECTING TESTING EQUIPMENT DURING ROUTINE MAINTENANCE INSPECTIONS. OVER TIME, LINGERING RESIDUAL WITHIN THE VALVE CAN CAUSE THE SEAL TO SLOWLY DEPRESS, ALLOWING PRODUCT TO LEAK OUT. FOLLOWING THE EVENT, PERSONNEL REMOVED THE VALVE AND, UPON DISASSEMBLY, IDENTIFIED THE RESIDUAL BUILDUP. THIS HAS BEEN DOCUMENTED IN THE COMPANY'S INCIDENT MANAGEMENT SYSTEM TO BRING VISIBILITY TO THE EVENT (AND TYPE OF FAILURE) AS WELL AS FOR TRACKING PURPOSES (AS A MEANS TO IDENTIFY POTENTIAL TRENDS AND PREVENT REOCCURRENCE).