HOLLY ENERGY PARTNERS - OPERATING, L.P.

Incident Narrative

ON DECEMBER 1 AT APPX. 20:10 MST, HEP PERSONNEL WERE WALKING THE GROUNDS OF THE EL PASO TERMINAL WHEN THEY NOTICED SOIL THAT WAS SATURATED NEAR TANK 206. HEP PERSONNEL IMMEDIATELY NOTIFIED THE TERMINAL SUPERVISOR WHO THEN RECOMMENDED IMMEDIATE EXCAVATION OF WHERE THE SOIL WAS SATURATED TO IDENTIFY WHERE THE SOURCE OF THE OIL WAS COMING FROM. DUE TO BEING AT A TERMINAL FACILITY WITH VARIOUS IN-PLANT AND OTHER PIPING; THIS EXCAVATION HAD TO BE DONE BY HAND AND TOOK APPX. 2.5 HOURS. UPON IDENTIFICATION THAT THE SOURCE WAS A LEAK COMING FROM TANK 206 TRANSFER LINE (COMING OFF A MANIFOLD AND RUNNING INTO THE TANK); PERSONNEL IMMEDIATELY MADE ADDITIONAL NOTIFICATION TO THE HEP CONTROL CENTER (APPX. 23:47 MST), BLOCKED IN THE LINE AND DRAINED IT BY VAC TRUCK. A PLIDCO CLAMP WAS ALSO APPLIED. IN TOTAL APPX. 1.5 BBLS. OF DIESEL FUEL WAS RELEASED. THE FOLLOWING DAY, 12/2, THIS EVENT WAS BROUGHT TO THE ATTENTION OF THE HEP REGULATORY GROUP. ALTHOUGH THE TANK TRANSFER LINE IS NOT REGULATED AND CONSIDERED IN-PLANT PIPING: DUE TO THE FACT THAT TANK 206 IS A BREAKOUT TANK AND THE TANK TRANSFER LINE IS COMING OFF A MANIFOLD FED BY REGULATED, TRANSMISSION LINES (ONLY JURISDICTIONAL TO PHMSA), THE DETERMINATION WAS THEN MADE THAT THIS INCIDENT MET 195.50 CRITERIA AND WAS REPORTED TO NRC AT APPX. 15:49 CST. THE APPARENT CAUSE OF THIS INCIDENT WAS DUE TO EXTERNAL CORROSION. *A NOTE, THIS REPORT HAS BEEN COMPLETED (WHERE POSSIBLE) ADDRESSING SPECIFICATIONS AND OPERATIONS OF THE TANK TRANSFER LINE WHERE THE LEAK OCCURRED.* **UPDATE AS OF 2/3/2023** FOR ADDED CLARIFICATION ON THE TIME FOR SHUTDOWN OF THE LINE, ONCE THE TANK ASSOCIATED WITH THIS LINE WAS FILLED (AS PER NORMAL OPERATIONS), THE LINE WAS SHUTDOWN. SEVERAL HOURS AFTER THE LINE HAD BEEN SHUTDOWN, HEP PERSONNEL WERE WALKING THE GROUNDS WHEN THEY NOTICED SATURATED SOIL AND BEGAN TO INVESTIGATE THE SOURCE. THIS ULTIMATELY LED TO IDENTIFYING THE SOURCE AS THE TRANSFER LINE COMING FROM AN ONSITE BOT(TANK 206), BEING FED BY A REGULATED LINE (EPI LINE 740). ALSO, AS AN UPDATE TO THE APPARENT CAUSE, AS THE PIPE COULD NOT BE COMPLETELY REMOVED (DUE TO IMPACTING FACILITY OPERATIONS), A NDE WAS CONDUCTED. UTILIZING THE NDE REPORT, PICTURES FROM THE SITE AND OF THE FAILURE POINT, AND SUBSEQUENT TESTING, IT HAS BEEN DETERMINED THAT CATHODIC SHIELDING CAUSED THE FAILURE. THE PIPE WAS FOUND TO HAVE NO COATING OR POOR COATING. AS SUCH, THE LACK OF EXTERNAL COATING ALONG WITH A SIGNIFICANT AMOUNT OF TIME WITHOUT PROPER LEVELS A CATHODIC PROTECTION LIKELY CAUSED GENERAL CORROSION AND CONTRIBUTED TO THE FAILURE. TO NOTE, THE TANK TRANSFER LINE IS CONSIDERED FACILITY PIPING AND WAS PLACED INTO SERVICE IN 1972. AT THAT TIME, IT WAS COMMON TO INSTALL PIPE WITHOUT EXTERNAL COATING. WITH THAT, A REPLACEMENT PROJECT IS SCHEDULED FOR 2023 TO INSTALL COATED PIPE ADEQUATE FOR THE SERVICE REQUIREMENTS. ***UPDATE AS OF 4/12/2023*** UPDATE MADE TO CORRECT HCA INFORMATION (SEE PART D).