COUNTRYMARK REFINING AND LOGISTICS, LLC

Incident Narrative

AT APPROXIMATELY 10:15 ON MAY 4TH 2020 TWO CORROSION TECHS WERE AT JOHNSONVILLE STATION PERFORMING ROUTINE MAINTENANCE TASKS. ONE OF THE TECHS NOTICED CRUDE OIL AROUND THE SUMP FOR THE RECEIVER ON THE INCOMING CLAY CITY MAINLINE. THE TECH IMMEDIATELY NOTICED THAT THE SUMP HAD OVERFILLED AND CRUDE OIL HAD RAN INTO A SMALL DITCH NEXT TO THE FACILITY. HE NOTIFIED HIS IMMEDIATE SUPERVISOR OF THE INCIDENT AND THAT ADDITIONAL RESPONSE RESOURCES WOULD BE REQUIRED. THE TECH THEN PUMPED OUT THE CRUDE OIL IN THE SUMP AND SENT THE OTHER TECH TO DETERMINE THE EXTENT OF THE SPILL. AFTER THE SUMP WAS EMPTIED AND THE EXTENT OF THE SPILL IDENTIFIED, BOTH TECHS PLACED BOOMS IN THE DITCH TO CONTAIN THE RELEASED CRUDE OIL. AFTER THE OIL WAS CONTAINED THE TECHS BEGAN USING ABSORBENT PADS TO CLEAN UP THE OIL IN THE DITCH. ADDITIONAL RESOURCES ARRIVED APPROXIMATELY TWO HOURS LATER TO ASSIST IN THE CLEANUP EFFORTS. INVESTIGATION DETERMINED THAT THE BALL VALVE SHOULD BE CLOSED AND IS ONLY OPENED WHEN PUMPING OUT THE SUMP WAS LEFT OPEN. HOWEVER, HAD THE CHECK VALVE BEEN FUNCTIONING PROPERLY, IT WOULD HAVE PREVENTED OIL FROM FLOWING INTO THE SUMP. OUR INITIAL ASSUMPTION IS THAT THE BALL VALVE WAS LEFT OPEN ON APRIL 17TH WHEN A CORROSION TECH RETRIEVED A CLEANING PIG FROM THE RECEIVER. THIS LED TO OIL SLOWLY FLOWING INTO THE SUMP AND EVENTUALLY OVERFILLING. A FIELD MECHANIC WAS PERFORMING PSV INSPECTIONS ON APRIL 30TH AND STATED THAT THE SUMP WAS APPROXIMATELY HALF FULL. IT IS THEN ESTIMATED THAT THE ACCIDENT REPORTING CRITERIA WAS MET SOMETIME ON SATURDAY MAY 2ND. THE RELEASE WAS ESTIMATED TO BE .5 BBL TO 1 BBL. THIS ESTIMATE WAS BASED OFF INITIAL VISUAL INSPECTION OF THE RELEASE AND FROM THE AMOUNT OF MATERIAL USED TO RECOVER THE OIL. A FOLLOWUP TO THE NRC (#1276646) WAS COMPLETED ON MAY 4TH, 2020 AT 17:57 CST. AFTER INITIAL CLEANUP, MAINTENANCE CREWS PERFORMED ROUTINE INSPECTIONS AND CLEANUP AS NEEDED UNTIL MAY 22ND WHEN THE RESPONSE WAS CONSIDERED COMPLETE. A ROOT CAUSE ANALYSIS HAS BEEN INITIATED FOR THIS INCIDENT. THE ROOT CAUSE ANALYSIS IDENTIFIED 5 ACTION ITEMS. THEY WERE CAR-SEAL SUMP DISCHARGE VALVES IN THE CLOSED POSITION, UPDATE PIGGING PROCEDURE TO INCLUDE SITE-SPECIFIC SUMP OPERATIONS, PROVIDE ADDITIONAL TRAINING ON EMERGENCY NOTIFICATION PROCEDURE, ADD A ROLES & RESPONSIBILITIES CHART FOR NOTIFICATIONS TO THE EMERGENCY PLAN, AND DEVELOP PERIODIC INSPECTION CHECKLIST TO INCLUDE VALVE ALIGNMENT AND SUMP VOLUMES. THESE ACTION ITEMS HAVE A COMPLETION TARGET DATE OF BY THE END OF THE THIRD QUARTER 2020.