KOCH PIPELINE COMPANY, L.P.

Incident Narrative

ON MAY 16,2016 AT APPROXIMATELY 2:35 A.M. AN EMPLOYEE OF THE OPERATOR IDENTIFIED A CRUDE OIL RELEASE AT THE FHR INGLESIDE TANK. THE HEAVY RAIN PRODUCED APPROXIMATELY 12 INCHES OF RAIN IN A 4 TO 5 HOUR PERIOD. A LOW SPOT ON THE TANK ROOF BEGAN PONDING WATER DURING THE HEAVY RAINFALL. THE PONDING OCCURRED ON THE ROOF IN AN AREA AWAY FROM THE ROOF DRAIN. THEREFORE, ALTHOUGH THE ROOF DRAIN WAS IN THE CORRECT OPEN POSITION, THE RAIN WATER ACCUMULATED ON THE ROOF COULD NOT DRAIN. FURTHER THE LEVEL OF THE ROOF WAS APPROXIMATELY 1 FOOT ABOVE THE POINT AT WHICH THE VACUUM BREAKER WOULD OPEN. THUS, THE TANK LEVEL PROVIDED FOR LESS HEAD PRESSURE TO DRIVE WATER OUT OF THE ROOF DRAIN, AND THE VACUUM BREAKERS ARE NOT DESIGNED TO OPEN WHEN THE FLOATING ROOF LANDS. WHEN THE VACUUM BREAKERS OPEN THEY PROVIDE A PATHWAY BETWEEN THE FLOATING ROOF AND THE PRODUCT BELOW. THE PONDING OF RAINWATER CAUSED THE ROOF TO TILT WHICH ALLOWED THE VACUUM BREAKERS/LEGS ON THE SIDE TO OPEN. APPROXIMATELY 5 BARRELS OF CRUDE OIL WAS RELEASED THROUGH THE VACUUM BREAKER ON TO THE ROOF. THE CRUDE OIL AND RAINWATER WAS THEN TO A LEVEL THAT IT DRAINED INTO THE EARTHEN SECONDARY CONTAINMENT DIKE WALL THROUGH THE ROOF DRAIN. THE SURFACE WATER WAS NOT IMPACTED BECAUSE THE RELEASE WAS FULLY CONTAINED WITHIN THE SECONDARY CONTAINMENT. THE OPERATOR WAS ABLE TO RECOVER THE CRUDE OIL THAT HAD BEEN RELEASED BY PUMPING IT OUT OF THE SECONDARY CONTAINMENT VIA VACUUM TRUCKS AND INTO ANOTHER TANK.