EXPRESS HOLDINGS (USA), LLC

Incident Narrative

ON DECEMBER 1, 2021 AT APPROXIMATELY 1:30 PM MST A RELEASE WAS DISCOVERED AT THE GURLEY TERMINAL INSIDE THE TANK 603 CONTAINMENT. THE EDMONTON CONTROL CENTER WAS NOTIFIED, AND LINE 41 WAS SHUT DOWN AND GURLEY TERMINAL WAS ISOLATED UNTIL THE SOURCE OF THE RELEASE COULD BE DETERMINED. APPROXIMATELY 0.5 BARRELS OF CRUDE OIL WAS RELEASED. THE NRC WAS NOTIFIED ON DECEMBER 1, 2021 AT 2:23 PM MST (NRC# 1323357). A 48-HOUR UPDATE TO THE NRC WAS MADE ON DECEMBER 2, 2021 AT 3:31 PM MST (NRC# 1323479). THE SOURCE OF THE RELEASE WAS IDENTIFIED AS AN OUT OF SERVICE 8"" RECIRCULATION LINE ON TANK 603. THE SECTION OF PIPE WAS CUT OUT AND THE LINE WAS ISOLATED BY INSTALLING BLIND FLANGES. APPROXIMATELY 17.5 TONS OF CONTAMINATED SOIL WAS REMOVED FROM THE RELEASE SITE. AFTER FURTHER INVESTIGATION THE CAUSE OF THE RELEASE WAS DETERMINED TO BE DUE TO LOCALIZED INTERNAL CORROSION PITTING THAT ORIGINATED FROM THE BOTTOM SIDE OF A MITERED BEND ON THE RECIRCULATION LINE. A THIRD-PARTY METALLURGICAL ANALYSIS FOUND EXCESS WELD MATERIAL ON THE INTERIOR SURFACE THAT FORMED A CREVICE WITH THE PIPE WALL CAUSING CREVICE CORROSION. THE PRESENCE OF A RELATIVELY LARGE, ROUND PIT INDICATED THAT A MOUND/TUBERCLE MAY HAVE BEEN PRESENT PRIOR TO THE RELEASE SUGGESTIVE OF UNDER-DEPOSIT CORROSION. WHEN THE LINE WAS TAKEN OUT OF SERVICE IT COULD NOT BE PIGGED DUE TO THE PIPING CONFIGURATION AND THE CLEANING METHOD USED DID NOT ADEQUATELY REMOVE ALL RESIDUAL PRODUCT. SEVERAL ACTION PLANS HAVE BEEN CREATED THAT AIM TO LOWER THE RISK ON THE REMAINING GURLEY TANK RECIRCULATION LINES IN SERVICE AND THOSE OUT OF SERVICE. ANOTHER ACTION PLAN IS PUT FORTH TO IMPROVE PROCESSES AROUND IDENTIFYING AND MANAGING HAZARDS RELATED TO CLEANING PLANS.