SFPP, LP

Incident Narrative

KINDER MORGAN OPERATOR DISCOVERED WHAT APPEARED TO BE AN OLD STAIN UNDERNEATH THE STAIRWAY, APPROX. 6-8 FEET FROM THE SHELL AND NEAR THE APRON OF BREAKOUT TANK W-14 AT 1500 ON SATURDAY, 2/21. THE TANK WAS PUMPING OUT GASOLINE AT DISCOVERY AND EMPTIED. ON MONDAY, THE 23RD, FURTHER INVESTIGATION BY SNIFFING THE LEAK DETECTION TUBES RESULTED IN HIGH LEL READINGS FROM THE ACCESS POINTS ON EITHER SIDE OF THE STAINED AREA. THREATENED RELEASE NOTIFICATIONS WERE PERFORMED AND THE OSRO RESPONDED TO CONDUCT EXPLORATORY EXCAVATION. THE EXCAVATION TRENCH BOTTOM CLEARED UP AND THE SIDE WALL TOWARD THE TANK SHOWED EVIDENCE OF STAINING COMING FROM THE DIRECTION OF THE TANK. NO FREE PRODUCT WAS OBSERVED, ONLY STAINED SOIL. SUBSEQUENT INVESTIGATION DETERMINED RELEASE VOLUME ESTIMATED TO BE 4.7 GALLONS BASED UPON DIMENSIONS OF THE TRENCH. ON 2/24, IT WAS DECIDED TO UPDATE THE THREATENED RELEASE NOTIFICATIONS TO A RELEASE NOTIFICATION DUE TO THE LIKELIHOOD THAT THE ESTIMATED COSTS WOULD EXCEED THE $50,000 REPORTING THRESHOLD. LATER, FIELD EXAMINATION AND THIRD PARTY ENGINEERING FIRM ANALYSES DETERMINED THAT FLEXING IN THE HEAT-AFFECTED ZONE CAUSED A 1 3/4-INCH CRACK IN THE FLOOR PLATE. THE AREA OF FAILURE WAS IMMEDIATELY ADJACENT TO THE VERTICAL LADDER CONNECTION. NOTE: PART A, #4 ORIGINALLY CALLED IN AS THREATENED RELEASE, RE-NOTIFIED WHEN DETERMINED TO MEET THE $50,000 CRITERIA. NOTE: PART E, #1 PRESSURE ESTIMATED TO BE LESS THAN 5 PSIG WHEN STAIN DISCOVERED; TANK WAS BEING EMPTIED AT THE TIME.