EPIC CONSOLIDATED OPERATIONS, LLC

Incident Narrative

ON 8/18/2019, THE CUSTOMER DELIVERY POINT DOWNSTREAM OF THE ROBSTOWN TO INGLESIDE 20"" VALVE/METER SITE LOCATED INSIDE THE ROBSTOWN TERMINAL UNEXPECTEDLY SHUT IN WITH NO NOTICE GIVEN TO EPIC OPERATIONS PRIOR TO THE SHUT IN. WHEN THE DELIVERY POINT SHUT IN IT CAUSED A BACK-PRESSURE ON THE PIPELINE SYSTEM THAT PRESSURED THE PIPELINE SYSTEM ABOVE 1000 PSIG (BUT DID NOT EXCEED THE MOP OF 1440) AND A THERMAL RELIEF ON THE SYSTEM SET AT 1000 PSIG ACTUATED AND VENTED INTO A SUMP AT THE SITE, AND THE SUMP REACHED CAPACITY AND OVERFLOWED INTO A CONSTRUCTION DITCH SURROUNDING THE SUMP. THE THERMAL RELIEF FAILED TO CLOSE AFTER THE PRESSURE FELL BELOW THE 1000 PSIG SET-POINT. THE ACCIDENT TOOK PLACE IN THE EARLY MORNING HOURS ON A SUNDAY AND NO OPERATIONS PERSONNEL WERE ON SITE AT THE TIME. ONE OF THE PROJECT MANAGERS WAS PERFORMING A STATION CHECK ON HIS UNRELATED PROJECT, AND FOUND THE SUMP OVERFLOWING AND NOTIFIED OPERATIONS AND THE THERMAL RELIEF WAS SHUT-IN TO STOP THE FLOW INTO THE SUMP. NO FURTHER INVESTIGATION CAN BE PERFORMED AS THE CUSTOMER DELIVERY POINT SHUT-IN OCCURRED ON ANOTHER OPERATOR'S FACILITY. TO MITIGATE SIMILAR RE-OCCURRENCES THE THERMAL RELIEF WAS LOCKED OUT AS IT IS NOT A REQUIRED COMPONENT AND WILL BE REPLACED WITH A THERMAL RELIEF SET CLOSER TO THE 1440 PSIG MOP OR DELETED FROM THE CONFIGURATION. IN ADDITION THE SUMP WAS PIPED TO RETURN TO THE SUCTION SIDE OF THE MAINLINE PUMPS TO PREVENT AN OVERFLOW EVENT FROM RE-OCCURRING. AND ALL OTHER SIMILAR CONFIGURATIONS WILL BE EVALUATED.