EPIC CONSOLIDATED OPERATIONS, LLC

Incident Narrative

ON MAY 11, 2020 AT APPROXIMATELY 7:00 PM, THERE WAS A PRESSURE INCREASE IN EXCESS OF THE METER'S RELIEF DEVICES AND CRUDE WAS DISPLACED INTO THE SUMP, AT NO TIME DID THE PIPELINE PRESSURE EXCEED THE MOP OF THE LINE OR EQUIPMENT. DURING THE RELIEF EVENT THE SUMP WAS OVERFILLED BY APPROXIMATELY 3 BBLS OF CRUDE. THE SYSTEM WAS NEWLY COMMISSIONED PIPELINE SYSTEM PRIOR TO THE RELEASE AND NOT ALL SCADA ELEMENTS WERE ACTIVE AT THE TIME AND THE CONTROLLERS WERE NOT AWARE OF THE SYSTEM CHANGES AS ALL THE CHANGES HAD HAD NOT BEEN CONVEYED TO THEM PRIOR TO THE RELEASE. THERE WERE SEVERAL ALARMS THAT WERE NOT AUDIBLE OR ACTIVATED TO CHANGE COLORS ON THE SCADA SCREEN. PRE-COMMISSIONING THE PSSR WAS NOT SIGNED OFF ON BY THE CONTROL ROOM MANAGER AND THE POINT TO POINT EVALUATIONS WERE DONE IN THE FIELD WITHOUT CONTROL ROOM INPUT. IT WAS FOUND THAT THE PSSR PROCESS FOR THIS STARTUP WAS INSUFFICIENT, AS THE CONTROL ROOM HAD NOT SIGNED OFF ON THE FINAL PSSR AND ALL ALARMS WERE NOT ACTIVE PRIOR TO COMMISSIONING. THE ENVIRONMENTAL REMEDIATION BEGAN ON MAY 11, 2011 HAS BEEN COMPLETED. TO MITIGATE FUTURE RE-OCCURRENCE ONE PERSON FROM OPERATIONS MANAGEMENT WILL BE ASSIGNED TO ENSURE ALL REQUIRED SIGNATURES AND ACTION ITEMS HAVE BEEN GIVEN AND COMPLETED PRIOR TO COMMISSIONING. A PUNCH LIST WILL BE WRITTEN FOR EACH SPECIFIC ACTION REQUIRED FOR COMMISSIONING AND ALL ITEMS WILL BE CLEARED BY THE ASSIGNED POINT PERSON PRIOR TO COMMISSIONING. ADDITIONAL COMMUNICATION MEETINGS WILL BE ESTABLISHED LEADING UP TO COMMISSIONING ALLOWING ALL STAKEHOLDERS AN OPPORTUNITY TO HAVE INPUT PRIOR TO COMMISSIONING.