KEYERA ENERGY, INC.

Incident Narrative

ON DECEMBER 25, 2021 AT APPROXIMATELY 1040 HRS. AN OPERATOR CONDUCTING HIS NORMAL ROUNDS DISCOVERED A SMALL LEAK (ESTIMATED 1 GAL (0.023 BBL RELEASED) ON AN IDLED ABOVEGROUND CRUDE OIL HEADER (IN-PLANT PIPING) AT A BLIND FLANGE GASKET. IMMEDIATE RESPONSE INCLUDED MEASURES TO REDUCE CRUDE OIL FROM FURTHER IMPACTING THE GROUND, OTHER PIPING, AND SUPPORT. CLEANUP WAS CONDUCTED BY SITE PERSONNEL AND ANY IMPACTED SOIL WAS REMOVED AND PROPERLY STAGED IN A ROLL OFF CONTAINER. NO OIL IMPACTED ANY WATER BODY AND WAS CONTAINED ON SITE. AN INVESTIGATION WAS INITIATED AND CONTINUES; HOWEVER, A PRELIMINARY DETERMINATION INDICATES THAT THE LEAK WAS CAUSED BY THERMAL EXPANSION OF THE CRUDE DUE TO THE LACK OF THERMAL PROTECTION ON THAT HEADER. IMMEDIATE SHORT-TERM MITIGATION WAS TO REALIGN VALVING TO ALLOW AN OPEN PATH TO TANKAGE AND ENSURING A THERMAL EVENT WILL NOT REOCCUR UNTIL A LONGER-TERM SOLUTION IS EVALUATED AND COMPLETED (MOC HAS BEEN INITIATED). ENGINEERING ANALYSIS IS ONGOING, BUT IT APPEARS THAT THE MOP OF 285 PSIG WAS EXCEEDED AND THE PRESSURE AT TIME OF RELEASE WILL BE PROVIDED IN A SUPPLEMENTAL REPORT. AN EXAMINATION OF THE GASKET WILL BE CONDUCTED TO DETERMINE IF THE GASKET FAILURE WAS THE PRIMARY CAUSE OF THE RELEASE. AN API 570 PIPING INSPECTION HAS BEEN CONDUCTED BY A THIRD PARTY INSPECTION FIRM TO FURTHER ACCESS MECHANICAL INTEGRITY OF THE PIPING AND APPURTENANCES AND NO VISIBLE DEFICIENCIES WERE FOUND. AN MOC HAS BEEN INITIATED TO INSTALL THERMAL RELIEF AND TAKE ANY OTHER STEPS TO PREVENT REOCCURRENCE. FURTHER DEVELOPMENTS ARE INCLUDED IN A SUPPLEMENTAL REPORT, WHICH FOLLOWS BELOW. INVESTIGATION DETAILS 1/4/22-PENDING THE IMPLEMENTATION OF A PERMANENT MANAGEMENT OF CHANGE (MOC), MOVS 20003 AND 20201 AND TANK VALVE 70204 WERE OPENED TO RE-ROUTE CRUDE TO TANK 202. 1/5/22-INITIAL ENGINEERING ASSESSMENT CONDUCTED TO DETERMINE PRESSURE AT TIME OF LEAK. TELEPHONICALLY NOTIFIED OKLAHOMA CORPORATION COMMISSION (OCC) INSPECTOR ON ISSUE. 1/10/22-MOC INITIATED TO IMPROVE THERMAL PROTECTION ON THE OH-1092 HEADER. 1/18/22-QUALIFIED THIRD-PARTY ASSET INTEGRITY FIRM (ACUREN) WAS ENGAGED TO PERFORM AN EXTERNAL VISUAL INSPECTION OF THE AFFECTED FLANGE AND ASSOCIATED PIPING. FINDINGS INDICATED THAT THE OH-1092 HEADER AND ASSOCIATED APPURTENANCES WERE NOT ADVERSELY AFFECTED. 1/24/22-PHMSA ACCIDENT REPORT FORM F 7000-1 WAS PREPARED AND ELECTRONICALLY SUBMITTED VIA THE PHMSA PORTAL. PDF COPY OF ACCIDENT REPORT PROVIDED TO THE OCC. 2/23/22-PROCESS HAZARD ASSESSMENT (PHA) COMPLETED FOR ADDITION OF THERMAL PSV AND UPSTREAM CSO VALVE 4/20/22-MANAGEMENT OF CHANGE (MOC) QA/QC VERIFICATION PERFORMED. 4/26/22-ACUREN PERFORMED A NON-DESTRUCTIVE EXAMINATION OF THE AFFECTED FLANGE AND GASKET; AND REPAIRS WERE COMPLETED TO CORRECT DEFICIENCIES. EXAMINATION IDENTIFIED GASKET PROTECTIVE PAPER WAS LEFT ON GASKET CAUSING AN INEFFICIENT SEAL. 4/27/22-OCC INSPECTORS ARRIVED ON SITE TO RECEIVE AN UPDATE, OBSERVE INSTALLATION OF NEW THERMAL RELIEF AND EXAMINE GASKET. 6/1/22-ALL MOC ACTIONS WERE COMPLETED AND CLOSED, MOC WAS CLOSED AND OH-1092 RETURNED TO NORMAL OPERATIONS. ROOT CAUSES (CAUSATION MAP TAPROOT METHODOLOGY WAS USED TO GENERATE 2 ROOT CAUSES) 1:EQUIPMENT DIFFICULTY > DESIGN > DESIGN SPECS > PROBLEM NOT ANTICIPATED -DURING ORIGINAL HAZOP, THE POTENTIAL FOR THERMAL OVER-PRESSURE WAS NOT ANTICIPATED. 2:INFERIOR CONSTRUCTION WORKMANSHIP>WORK DIRECTION>SELECTION>WORKER SELECTION OR OVERSIGHT NEEDS IMPROVEMENT. THE AFFECTED FLANGE AND GASKET WERE IMPROPERLY INSTALLED, CAUSING THE FLANGE AND THE GASKET TO NOT SEAL PROPERLY. - CORRECTIVE ACTION ITEMS HAVE BEEN ADDRESSED. - MANAGEMENT HAS REVIEWED AND APPROVED INVESTIGATION REPORT.