EPIC CONSOLIDATED OPERATIONS, LLC

Incident Narrative

ON APRIL 24, 2020 AT 5:00AM, EPIC WAS IN THE PROCESS OF COMMISSIONING A NEW TANK. DURING THE INITIAL FILL WITH CRUDE THE MANWAY GASKET ON TANK 3002 BEGAN TO LEAK. OPERATIONS PERSONNEL ON-SITE INSPECTING THE TANK WHILE FILLING FOUND THE LEAK AND TOOK IMMEDIATE ACTION AND SEALED THE LEAK BY TIGHTENING SEVERAL FLANGE BOLTS AT THE LEAK LOCATION. TANK IS OPERATED AT ATMOSPHERIC PRESSURE AND THERE WAS NO OVER-PRESSURE OF THE TANK. THE SITE WAS MADE SAFE AND THE TERMINAL OPERATION PERSONNEL CONTACTED THE TERMINAL OPERATIONS SUPERVISOR AND EPIC OPERATIONS MANAGEMENT WAS NOTIFIED OF THE RELEASE. EHS PERSONNEL WERE SENT TO THE SITE AND EPIC'S POST-ACCIDENT PROCEDURE WAS USED TO DETERMINE THE ESTIMATED RELEASE VOLUME AND DAMAGES. DURING THIS TIME RELEASE VOLUME CALCULATIONS WERE BEING PERFORMED PER THE O&M PROCEDURE AND CONFIRMED BY EPIC OPERATIONS. THE DISCOVERY TIME WAS 9:30 AM AND WAS BASED ON THE ESTIMATED RELEASE VOLUME OF 3.551 BBLS. EPIC DISPATCHED AN ENVIRONMENTAL CLEANUP CREW TO THE SITE TO ASSIST WITH THE CLEANUP OF THE SITE. CLEANUP WAS COMPLETED THE SAME DAY AND NO FURTHER REMEDIATION IS NEEDED. AFTER THE CLEANUP WAS COMPLETED TERMINAL OPERATIONS ENSURED ALL OTHER FLANGE BOLTS IN THE FACILITY WERE TORQUED CORRECTLY AND DID NOT FIND ADDITIONAL ISSUES. INSPECTION RECORDS WERE REVIEWED AND AT THE TIME OF THE MANWAY COVER INSTALLATION NEW BOLTS, NUTS, AND GASKETS WERE INSTALLED. IT WAS DISCOVERED THAT AN INCORRECT TORQUE VALUE WAS USED BY THE TORQUE CREW POTENTIALLY CAUSING THE LEAK. DURING INSTALLATION 3/4-INCH FLANGE BOLTS WITH A TORQUE VALUE OF 315 FT POUNDS WERE USED, THE TOQUE VALUE USED WAS FOR AN ANSI/ASME-RATED FLANGE FOR 'FIELD CONDITION NON-LUBRICATED' BOLTS PER THE CHART IN EPIC'S TORQUING PROCEDURES. THE FIELD RECORD SHOWS THAT THE BOLTS WERE NEW NOT FIELD CONDITION(USED), AND THE CORRECT VALUE FOR A NEW BOLT WITH LUBRICATION IS 150 FT POUNDS PER THE TORQUING PROCEDURE USING THE ANSI/ASME TORQUE VALUES. EPIC'S TORQUE VALUE FOR THE SHELL MANWAYS IS 250 FT POUNDS, HOWEVER THIS SPECIFICATION CANNOT BE FOUND IN THE PROCEDURE OR RECORDS. THE 250 FT POUND TORQUE VALUE WAS VERBALLY GIVEN BY FACILITY CONSTRUCTION PERSONNEL. TO MITIGATE RE-OCCURRENCE OF A SIMILAR ACCIDENT EPIC WILL REVISE THE TORQUING PROCEDURE TO INCLUDE TORQUING GUIDANCE FOR BREAK TANK MANWAY FLANGES. IN ADDITION, ALL BOLTS IN THE TERMINAL WERE INSPECTED AND NO ISSUES WERE FOUND DURING THE INSPECTIONS.