MAGELLAN TERMINALS HOLDINGS, LP

Incident Narrative

ON 11/6/2019, WHILE PERFORMING A FACILITY INSPECTION, LOCAL OPERATOR DISCOVERED A WET SPOT ON THE CONCRETE RING WALL AT TANK 391. THE TANK WAS IDLE AT THE TIME OF DISCOVERY. VALVES WERE CLOSED TO ISOLATE THE TANK FROM FACILITY OPERATIONS. ABSORBENT PADS WERE USED TO CLEAN UP THE WET SPOT. PRODUCT WAS TRANSFERRED OUT OF THE TANK IN PREPARATION FOR CLEANING AND INSPECTION. VOLUME RELEASED FOR THIS INCIDENT WAS 0.25 GALLONS, HOWEVER, LIMITATIONS WITHIN THE 7000-1 REPORTING STRUCTURE ONLY ALLOWS 0.1 BBLS AS THE SMALLEST REPORTABLE VOLUME. ON 11/14/2019, IT WAS DETERMINED COSTS ASSOCIATED WITH TANK CLEANING AND INSPECTION WAS ANTICIPATED TO EXCEED $50,000. NOTIFICATION WAS MADE TO APPROPRIATE REPORTING AGENCIES BASED ON THIS REPORTING CRITERIA. NRC #1263899, 11/14/2019 10:02 NRD 48-HR UPDATE, #1264017, 11/15/2019 10:53 MAGELLAN'S PREDECESSOR ACQUIRED THIS FACILITY FROM A PREVIOUS OPERATOR IN 1999. SINCE THE ACQUISITION IN 1999, THIS FACILITY AND TANK HAVE BEEN UNDER CONTINUOUS CATHODIC PROTECTION. RESULTS OF THE TANK INSPECTION REVEALED A CRACK DUE TO EXCESSIVE EXTERNAL THINNING OF THE FLOOR PLATE NEAR THE SHELL. EXCESSIVE EXTERNAL THINNING WAS A RESULT OF GROUT FAILURE ON TOP OF THE CONCRETE RING WALL. THIS PERMITTED A 1"" GAP BETWEEN THE TANK FLOOR AND CONCRETE RING WALL WHERE CORROSION COULD NOT BE MITIGATED WITH CATHODIC PROTECTION OR COATINGS. THIS COUPLED WITH THE MARINE ENVIRONMENT RESULTED IN CORROSION IN THIS AREA. PROCEDURES WILL BE UPDATED TO CONSIDER THE PRESENCE AND CONDITION OF GROUT ON TOP OF RING WALLS. INTERNAL DISCUSSIONS ARE ON-GOING TO DETERMINE THE VIABILITY OF REPAIRING THE TANK AND PLACING BACK INTO SERVICE. THE TANK SHALL REMAIN OUT OF SERVICE UNTIL SUCH TIME AS THAT DECISION IS MADE AND APPROPRIATE REPAIRS HAVE TAKEN PLACE. SUPPLEMENTAL/FINAL 2/7/2020: UPDATED C3, C6, G1 1-5, G1 14, H