SUNOCO PARTNERS MARKETING & TERMINALS LP

Incident Narrative

A CONSTRUCTION PROJECT WAS UNDERWAY TO TIE IN NEW TANK LINES TO THE 30"" SEAWAY HEADER IN THE CENTRAL MANIFOLD OF THE NEDERLAND TERMINAL. THE 30"" SEAWAY HEADER HAD BEEN TAKEN OUT OF SERVICE, DRAINED OF PRODUCT, AND MECHANICALLY AND ELECTRICALLY LOCKED OUT / TAGGED OUT PRIOR TO THE CONTRACTORS COMMENCING THE WORK ACTIVITY WHICH WAS UNDERWAY AT THE TIME OF THE INCIDENT. A CONTRACTOR WAS PERFORMING WELDING IN CONNECTION WITH THE PROJECT WHEN THE INCIDENT OCCURRED. SPECIFICALLY, THE WELDING CONTRACTOR WAS WELDING FLANGES ONTO THE HEADER. A SUBCONTRACTOR OF THE WELDING CONTRACTOR WAS PROVIDING THE ISOLATION SERVICES IN CONNECTION WITH THE PROJECT, WHEREIN THE SUBCONTRACTOR INSTALLED SPECIALTY MECHANICAL ISOLATION TOOLS IN BOTH ENDS OF THE HEADER SECTION ON WHICH THE WELDING WAS BEING PERFORMED. A FLASH FIRE OCCURRED AS A RESULT OF HYDROCARBON VAPORS BEING IGNITED BY THE WELDING PERFORMED BY THE CONTRACTOR. A MINOR ENSUING RESIDUAL FIRE WAS OUT BEFORE THE FIRE DEPARTMENT ARRIVED. WHILE A COURTESY NOTICE OF THE INCIDENT WAS PROVIDED TO PHMSA, THE INCIDENT WAS NOT PREVIOUSLY REPORTED TO THE NRC NOR INITIALLY TO PHMSA VIA THE F 7000-1 WRITTEN REPORT BECAUSE AT THE TIME OF THE INCIDENT THIS PORTION OF THE FACILITY WAS NOT BELIEVED TO BE SUBJECT TO PHMSA JURISDICTION. AN INITIAL 7000-1 ACCIDENT WRITTEN REPORT WAS SUBMITTED ON SEPTEMBER 22, 2017. A 3RD PARTY INVESTIGATION REPORT CONCLUDED THAT THE IMMEDIATE CAUSE OF THE INCIDENT WAS THE FAILURE OF THE MECHANICAL ISOLATION TOOLS TO ISOLATE THE FLAMMABLE VAPORS WITHIN THE HEADER FROM THE WELDING HEAT AND ARCING. CONTRIBUTING CAUSES TO THE INCIDENT WERE THE CONTRACTORS AND SUBCONTRACTORS FAILURE TO FOLLOW SPECIFIC INSTALLATION AND MONITORING PROCEDURES ASSOCIATED WITH THE SPECIALTY MECHANICAL ISOLATION TOOLS IN ADDITION TO THE CONTRACTORS AND SUBCONTRACTORS LACK OF PROPER HAZARD RECOGNITION.