COUNTRYMARK REFINING AND LOGISTICS, LLC

Incident Narrative

ON DECEMBER 12TH AT APPROXIMATELY 15:00 THE AREA ROW TECH RECEIVED A CALL FROM THE TIPTON COUNTY FIRE DEPT. REGARDING A POSSIBLE LEAK. THE ROW TECH REPORTED THE ISSUE AND ASKED TO CHECK ON ANY POSSIBLE PRESSURE DROPS INDICATING A LEAK. NO INDICATION WAS IDENTIFIED. THE ROW TECH THEN INSPECTED THE PIPELINE IN THE AREA THE LEAK WAS REPORTED AND FOUND DIESEL IN AND AROUND THE VALVE BOX. THE ROW TECH THEN HAD THE PIPELINE SHUTDOWN AND WENT TO CLOSE THE UPSTREAM AND DOWNSTREAM VALVES. INTERNAL NOTIFICATIONS WERE MADE AND THE AREA OSRO WAS PUT ON STANDBY. NOTIFICATIONS WERE MADE TO THE NRC, IURC (INDIANA UTILITY REGULATORY COMMISSION), AND IDEM (INDIANA DEPT. OF ENVIRONMENTAL MANAGEMENT). ADDITIONAL INTERNAL RESOURCES AND THE AREA OSRO ARRIVED ON SITE THAT EVENING TO ESTABLISH INCIDENT COMMAND AND BEGIN EMERGENCY RESPONSE OPERATIONS. ON DECEMBER 12TH IT WAS IDENTIFIED THAT THE LEAK WAS COMING FROM A FLANGED CONNECTION INSIDE THE VALVE BOX. THE FLANGED CONNECTION UTILIZED AN INSULATOR KIT THAT WAS ALSO USED IN SEVEN ADDITIONAL VALVE CONNECTIONS. ALL 8 INSULATOR KITS WERE REMOVED AND NEW GASKETS WERE INSTALLED. THE PIPELINE WAS RESTARTED ON DECEMBER 12TH AT 15:45. NO ISSUES WERE IDENTIFIED AND THE VALVES WERE ROUTINELY MONITORED. EMERGENCY RESPONSE ACTIVITIES CONTINUED UNDER THE SUPERVISION AND DIRECTION OF IDEM. IDEM RELEASED THE SITE ON DECEMBER 28TH. A ROOT-CAUSE-ANALYSIS IS CURRENTLY UNDERWAY FOR THIS INCIDENT. THE REPORT WILL BE UPDATED WITH THE FINDINGS FROM THIS INVESTIGATION. THE ROOT-CAUSE WAS DETERMINED TO BE A LOSS OF SUPPORT THAT LED TO THE FLANGE BOLTS BECOMING LOOSE. THE TIME THE ACCIDENT REACHED REPORTING CRITERIA IS A CALCULATED ESTIMATE. A CONTROLLED STARTUP OF THE PIPELINE WAS CONDUCTED TO DETERMINE WHICH SIDE OF THE VALVE WAS LEAKING. THE RATE OF THE LEAKING PRODUCT WAS APPROXIMATED AFTER THE CONTROLLED STARTUP. WE USED THIS LEAK RATE ALONG WITH THE SCADA DATA OF WHEN THE PIPELINE OPERATED TO APPROXIMATE THE TIME THE ACCIDENT REACHED REPORTING CRITERIA. INCORRECT MATERIALS LIKELY CONTRIBUTED TO THIS ACCIDENT. AN INSULATOR KIT WITH A PHENOLIC GASKET WAS INSTALLED BETWEEN THE FLANGE AND VALVE. THIS INSULATOR KIT WAS NOT A PART OF THE ORIGINAL BILL OF MATERIALS FOR THE PROJECT. IT WAS ADDED BY THE PROJECT PLANNER AND APPROVED BY THE CORROSION SUPERVISOR, BUT THE PROJECT ENGINEER NEVER APPROVED IT. THE PHENOLIC GASKET IN THE INSULATOR KIT FAILED. A FLEXITALLIC GASKET SHOULD HAVE BEEN INSTALLED INSTEAD OF THE INSULATOR KIT.