EXPRESS HOLDINGS (USA), LLC

Incident Narrative

ON MARCH 18, 2019 AT APPROXIMATELY 3:36 AM CDT, A MAINTENANCE TECHNICIAN WHILE RESPONDING TO AN ODOR COMPLAINT DISCOVERED OIL COMING OUT OF THE ROOF DRAIN VALVE OF TANK 805 AT SALISBURY TERMINAL. THE INITIAL RELEASE WAS ESTIMATED AT 1-2 BARRELS WITH ALL OIL CONTAINED IN TANK SECONDARY CONTAINMENT. THE SOURCE OF THE LEAK WAS IMMEDIATELY ISOLATED AND CREWS WERE DISPATCHED TO RESPOND AND CLEAN UP THE RELEASE. THE INITIAL DETERMINATION OF THE CAUSE WAS THE TANK ROOF DRAIN VALVE FAILED TO PROPERLY SEAL AND IT WAS UNKNOWN AT THE TIME HOW OIL GOT INTO THE DRAIN LINE. INITIAL COST ESTIMATE WAS LESS THAN $50,000 TO CLEANUP AND PERFORM AN IN-PLACE REPAIR OF THE VALVE BY REPACKING IT. NOTIFICATION WAS MADE TO MISSOURI DEPARTMENT OF NATURAL RESOURCES (CASE ID# 190318-0406-ADC) ON MARCH 18, 2019 AT 4:05 AM CDT AS THE QUANTITY RELEASE AMOUNT WAS CLOSE TO MISSOURI'S 50 GALLONS CRITERIA. AFTER COMPLETING PERMITS TO INSPECT THE TANK ROOF, PERSONNEL DISCOVERED ANOTHER ESTIMATED 25 BARRELS HAD BEEN RELEASED ONTO THE TANK ROOF AT 5:36 AM CDT, WHICH INCREASED THE COSTS OF REMEDIATION TO GREATER THAN $50,000. THE NRC NOTIFICATION WAS MADE ON MARCH 18, 2019 AT 5:56 AM CDT (REPORT #1240350). THE ESTIMATED RELEASE INTO SECONDARY CONTAINMENT WAS APPROXIMATELY 2 BARRELS AND THE ESTIMATED RELEASE ON THE TANK ROOF WAS APPROXIMATELY 25 BARRELS. THE 48-HOUR NRC NOTIFICATION WAS MADE ON MARCH 19, 2019 AT 7:00 PM CDT (REPORT #1240500) TO GIVE AN UPDATE ON RELEASE VOLUME. THE RELEASE HAS BEEN CLEANED UP IN THE SECONDARY CONTAINMENT AND ON THE TANK ROOF. AFTER FURTHER INVESTIGATION, THE CAUSE OF THE ROOF DRAIN FAILURE WAS DETERMINED TO BE FROM WATER THAT FROZE IN THE DRAIN LINE CAUSING A BREAK IN THE PIVOT MASTER CONNECTION. A PLUG WAS INSTALLED IN THE ROOF DRAIN ON THE TANK ROOF TO PREVENT FURTHER PRODUCT FROM COLLECTING ON THE ROOF. THE TANK WILL BE TAKEN OUT OF SERVICE TO REPAIR THE DAMAGED DRAIN COMPONENTS AT A LATER DATE TO BE DETERMINED. APPROXIMATELY 175 CUBIC YARDS OF CONTAMINATED SOIL WAS DISPOSED OF AT AN APPROVED SITE.