FLINT HILLS RESOURCES, LC

Incident Narrative

AT APPROXIMATELY 07:15 ON JANUARY 16, FHR OPERATIONS RECEIVED A CALL FROM MARTIN GAS OPERATIONS NOTIFYING US OF A SUSPECTED RELEASE NEAR OUR EQUIPMENT INSIDE THEIR FACILITY. AT THE TIME OF THE NOTIFICATION, THE PIPELINE WAS ISOLATED AND BLOCKED IN FOR SCHEDULED MAINTENANCE. THE RELEASE WAS CALLED INTO THE NRC AT APPROXIMATELY 08:08. A NOTIFICATION TO THE TEXAS RAILROAD COMMISSION IMMEDIATELY FOLLOWED. FHR PERSONNEL ARRIVED ON SITE AT APPROXIMATELY 08:15 AND CONFIRMED AN ACTIVE RELEASE ON FHR ASSETS. MARTIN GAS OPERATIONS EVACUATED THEIR FACILITY OF NON-ESSENTIAL PERSONNEL AND BEGAN TO SPRAY WATER ON THE SITE TO MITIGATE THE ANHYDROUS AMMONIA VAPOR CLOUD. FHR CALLED 911 TO INFORM LOCAL EMERGENCY RESPONDERS AT APPROXIMATELY 09:15. A SUPPRESSION BLANKET WAS PLACED OVER THE RELEASE LOCATION TO FURTHER SUPPRESS VAPORS. NITROGEN WAS INJECTED INTO THE PIPELINE TRAP AT APPROXIMATELY 21:00 ON JANUARY 17. AT APPROXIMATELY 00:26 ON JANUARY 18, THE NITROGEN PRESSURE WAS INCREASED, WHICH FURTHER REDUCED THE VAPOR RELEASE; AT APPROXIMATELY 00:52 ON JANUARY 18, THE VAPOR WAS NO LONGER VISUALLY DETECTABLE. THE REPAIR ON THE TRAP LOCATION (ENGINEERED CLAMP) WAS INSTALLED AT 21:45 ON JANUARY 18 AND THE INJECTION MATERIAL ON THE CLAMP WAS FINISHED AT 14:15 ON JANUARY 19. THE EQUIPMENT INVOLVED IN THE RELEASE IS BEING SHIPPED TO AN INDEPENDENT LAB FOR IMMEDIATE CAUSE ANALYSIS. THROUGHOUT THE DURATION OF THE EMERGENCY RESPONSE, FHR CONDUCTED LOCAL AIR MONITORING AROUND THE SITE AND SURROUNDING NEIGHBORHOODS TO ESTABLISH EMERGENCY RESPONSE ZONES. NO DETECTABLE RELEASE AMOUNTS WERE FOUND AROUND THE SURROUNDING NEIGHBORHOODS AT ANY TIME DURING THE EMERGENCY RESPONSE. IMPACTED FISH WERE OBSERVED IN THE BARGE SLIP. STATE AND FEDERAL AGENCIES WERE SUBSEQUENTLY NOTIFIED OF THE OBSERVATION AT 09:10 ON JANUARY 18. UPDATE TO PART H - THE IMMEDIATE CAUSE ANALYSIS DETERMINED THAT THE CLOSURE LEAKED DUE TO FAILURE OF THE CLOSURE DOOR O-RING, COUPLED WITH EXCESSIVE GLAND DEPTH AT THE 6:00 ORIENTATION. HOWEVER, AFTER FURTHER INVESTIGATION, THE GLAND DEPTH HAS BEEN DETERMINED TO MEET THE MANUFACTURER'S DESIGN SPECIFICATION AT THE 6:00 ORIENTATION, AND THE ROOT CAUSE IS TIED TO THE O-RING PERFORMANCE. THE INSTALLED O-RING WAS SIZED CORRECTLY AND OF A MATERIAL COMPATIBLE WITH THE ANHYDROUS AMMONIA PRODUCT IN THE PIPELINE. ACCORDING TO THE OEM SUPPLIER, THE REDUCED NON-OEM O-RING DIMENSIONS RESULTING FROM COMPRESSION SET AND SHRINKAGE IS LIKELY FROM DIFFERENCES IN THE PROPRIETARY MANUFACTURING PROCESSES. THE FOLLOWING CORRECTIVE ACTIONS ARE BEING PURSUED: 1) ADJUSTING COMPANY PROCUREMENT EXPECTATIONS REGARDING O-RINGS AND SOFT GOODS ON TDW D2000 CLOSURE DOORS AND 2) WORKING WITH THE CLOSURE DOOR MANUFACTURER TO ENSURE FUTURE O-RING DELIVERIES CONSISTENTLY MEET DIMENSIONAL AND CHEMICAL COMPATIBILITY REQUIREMENTS.