HL incident on 2019-05-08 — TX

Operator
Bkep Pipeline, Llc
Cause
Natural Force Damage
Commodity
Crude Oil
Program
HL
Damage and Injuries
0 fatalities 0 injuries
Property damage (nominal)
$587
Incident datetime
2019-05-08 08:03
Report number
Location
TX
Narrative
During the night of wednesday may 8, 2019, the cushing area was inundated by a torrential rainfall event. This event produced over 5 inches of rainfall in a matter of hours. The roof drain system was unable to relieve the volume of water due to buildup of blast media in the check valve, preventing full actuation. This caused the roof to draft to oil level in tank, resulting in a manway failure, which released oil onto the roof exiting via the drain. At the time the release was discovered, the winds were steady at over 30 mph with gusts exceeding 45 mph. The high winds pushed the oil into one corner of the containment and gave the appearance of a smaller release. When the wind direction shifted, the oil circumvented the containment booms and covered the surface of the rainwater throughout the containment area. On thursday, once the amount of oil in the containment area became clear, bkep estimated the cost of the response to be below $50,000. On friday, may 10, remediation was nearly complete and the total estimated cost was $39,500. In the early hours of saturday, may 11, another large storm system hit the cushing area, causing an additional 4-5 inches of rainfall. That rain filled the containment berm and caused a sheen of oil on the rainwater within the containment. The second major storm lengthened the response beyond the scope of the initial estimate and caused the total cost of the response to exceed $50,000. That exceedance was not apparent until final invoices were received from the contractors the following week. Bkep did not call the nrc at the time of the second storm as it was several days after the initial release. Also, the part 195 criteria for immediate notification is based on estimates and not exact cost. Bkep's interpretation of the language of adb-02-04 supported the view that an nrc call was not required for a final cost which is a small amount over the estimated value of less than $50k. Adb-02-04 discusses when an additional call is required to the nrc to provide an update to initial estimates (which would be provided if those estimates are over 50k). It states that a damage cost estimate should be updated via an additional call if the cost is 10 times the estimated amount; for example, if the estimate had been $100,000, no update to the initial nrc call would be required unless the end cost exceeded $1 million. Bkep interpreted the same logic to apply if an initial cost estimate was less than $50k and therefore did not trigger a notification requirement and the cost at the end of the cleanup totaled slightly over $50k. Bkep's conclusion was that, based on the adb language, no nrc notification was required unless the end cost was significantly more than the initial estimates. For this report, bkep has marked question a6 as "required but not made" at the direction of regulatory personnel.
Detailed record list
Report Received Date
2019-05-23 00:00:00
Iyear
2019
Report Number
20190167
Supplemental Number
32366
Report Type
Supplemental Final
Operator Id
Name
Bkep Pipeline, Llc
Operator Street Address
2277 Plaza Drive Suite 500
Operator City Name
Sugar Land
Operator State Abbreviation
TX
Operator Postal Code
77479
Local Datetime
2019-05-08 00:00:00
Location Latitude
Location Longitude
Commodity Released Type
Crude Oil
Unintentional Release Bbls
140
Recovered Bbls
140
Fatality Ind
No
Fatal
0
Injury Ind
No
Injure
0
Accident Identifier
Local Operating Personnel, Including Contractors
Operator Type
Operator Employee
Incident Identified Datetime
2019-05-08 08:03:00
System Part Involved
Onshore Breakout Tank Or Storage Vessel, Including Attached Appurtenances
On Off Shore
Onshore
Shutdown Due Accident Ind
No
Shutdown Explain
Release Was From A Single Tank And Did Not Impact Other Operations
On Site Datetime
2019-05-08 08:15:00
Nrc Rpt Num
Nrc Notification Required But Not Made
Ignite Ind
No
Explode Ind
No
Num Pub Evacuated
0
Pipe Fac Name
Cushing Central Terminal
Segment Name
Tank 2504
Onshore State Abbreviation
Ok
Onshore Postal Code
74023
Onshore City Name
Not Within A Municipality
Onshore County Name
Payne
Designated Location
Milepost/valve Station
Designated Name
Tank 2504
Federal
No
Location Type
Totally Contained On Operator-Controlled Property
Incident Area Type
Tank, Including Attached Appurtenances
Crossing
No
Pipe Facility Type
Intrastate
Item Involved
Tank/vessel
Tank Vessel Subtype
Roof Drain System
Tank Type
Atmospheric
Installation Year
2004
Material Involved
Carbon Steel
Release Type
Overfill Or Overflow
Wildlife Impact Ind
No
Soil Contamination
Yes
Long Term Assessment
No
Remediation Ind
Yes
Soil Remed Ind
Yes
Water Contam Ind
No
Could Be Hca
Yes
Commodity Reached Hca
No
Est Cost Oper Paid
0
Est Cost Gas Released
0
Est Cost Prop Damage
587
Est Cost Emergency
55503
Est Cost Environmental
12259
Est Cost Other
0
Est Cost Other Details
0
Prpty
68349
Accident Psig
0
Mop Psig
0
Accident Pressure
Pressure Did Not Exceed Mop
Pressure Restriction Ind
No
Pipeline Function
> 20% Smys Regulated Transmission
Scada In Place Ind
Yes
Scada Operating Ind
Yes
Scada Functional Ind
Yes
Scada Detection Ind
No
Scada Conf Ind
No
Cpm In Place Ind
Yes
Cpm Operating Ind
Yes
Cpm Functional Ind
Yes
Cpm Detection Ind
No
Cpm Conf Ind
No
Investigation Status
No, the operator did not find that an investigation of the controller(s) actions or control room issues was necessary due to: (provide an explanation for why the operator did not investigate)
Investigation Status Details
Release from a tank. No controller actions were involved in the release.
Employee Drug Test Ind
No
Contractor Drug Test Ind
No
Cause
Natural Force Damage
Cause Details
Heavy Rains/floods
Natural Force Type
Heavy Rains/floods
Heavy Rains Subtype
Other
Nf Other Details
,,,,,,,,,,,rain Accumulation Was Rapid. (5 Inches Plus Overnight) Winds Were High During Severe Storms. The Drains Were Capable Of Handling The Rainfall By Design But The Drain Was Partially Blocked With Hardened Blast Media Which Prevented The Check Valve From Fully Actuating. ,,,,,,,,,,,,,,,,,,
Nf Extreme Weather Ind
Yes
Nf Other Ind
Yes
Nf Extreme Weather Details
Near Record Flooding, Multiple Storms, Extreme High Winds. Maximum Wind Gust Recorded At 90 Mph, With A Max Rainfall Rate Recorded Of Greater Than 1 Inch Per Hour (From The Nearest Mesonet Station)
Preparer Name
G*** M*****
Preparer Title
Manager Of Dot Compilance
Preparer Email
G******@b***.com
Preparer Telephone
405-590-2035
Prepared Date
2019-07-01 00:00:00
Authorizer Name
S**** R*********
Authorizer Telephone
903-576-3706
Authorizer Title
Operations Manager - Cushing Terminal
Authorizer Email
S***********@b***.com
Narrative
During the night of wednesday may 8, 2019, the cushing area was inundated by a torrential rainfall event. This event produced over 5 inches of rainfall in a matter of hours. The roof drain system was unable to relieve the volume of water due to buildup of blast media in the check valve, preventing full actuation. This caused the roof to draft to oil level in tank, resulting in a manway failure, which released oil onto the roof exiting via the drain. At the time the release was discovered, the winds were steady at over 30 mph with gusts exceeding 45 mph. The high winds pushed the oil into one corner of the containment and gave the appearance of a smaller release. When the wind direction shifted, the oil circumvented the containment booms and covered the surface of the rainwater throughout the containment area. On thursday, once the amount of oil in the containment area became clear, bkep estimated the cost of the response to be below $50,000. On friday, may 10, remediation was nearly complete and the total estimated cost was $39,500. In the early hours of saturday, may 11, another large storm system hit the cushing area, causing an additional 4-5 inches of rainfall. That rain filled the containment berm and caused a sheen of oil on the rainwater within the containment. The second major storm lengthened the response beyond the scope of the initial estimate and caused the total cost of the response to exceed $50,000. That exceedance was not apparent until final invoices were received from the contractors the following week. Bkep did not call the nrc at the time of the second storm as it was several days after the initial release. Also, the part 195 criteria for immediate notification is based on estimates and not exact cost. Bkep's interpretation of the language of adb-02-04 supported the view that an nrc call was not required for a final cost which is a small amount over the estimated value of less than $50k. Adb-02-04 discusses when an additional call is required to the nrc to provide an update to initial estimates (which would be provided if those estimates are over 50k). It states that a damage cost estimate should be updated via an additional call if the cost is 10 times the estimated amount; for example, if the estimate had been $100,000, no update to the initial nrc call would be required unless the end cost exceeded $1 million. Bkep interpreted the same logic to apply if an initial cost estimate was less than $50k and therefore did not trigger a notification requirement and the cost at the end of the cleanup totaled slightly over $50k. Bkep's conclusion was that, based on the adb language, no nrc notification was required unless the end cost was significantly more than the initial estimates. For this report, bkep has marked question a6 as "required but not made" at the direction of regulatory personnel.
Report Received Date 2019-05-23 00:00:00
Iyear 2019
Report Number 20190167
Supplemental Number 32366
Report Type Supplemental Final
Operator Id 32551 PHMSA Enforcement
Name Bkep Pipeline, Llc
Operator Street Address 2277 Plaza Drive Suite 500
Operator City Name Sugar Land
Operator State Abbreviation TX
Operator Postal Code 77479
Local Datetime 2019-05-08 00:00:00
Location Latitude 36.0054 Google Maps OpenStreetMap
Location Longitude -96.75046 Google Maps OpenStreetMap
Commodity Released Type Crude Oil
Unintentional Release Bbls 140
Recovered Bbls 140
Fatality Ind No
Fatal 0
Injury Ind No
Injure 0
Accident Identifier Local Operating Personnel, Including Contractors
Operator Type Operator Employee
Incident Identified Datetime 2019-05-08 08:03:00
System Part Involved Onshore Breakout Tank Or Storage Vessel, Including Attached Appurtenances
On Off Shore Onshore
Shutdown Due Accident Ind No
Shutdown Explain Release Was From A Single Tank And Did Not Impact Other Operations
On Site Datetime 2019-05-08 08:15:00
Nrc Rpt Num Nrc Notification Required But Not Made NRC Report How to search
Ignite Ind No
Explode Ind No
Num Pub Evacuated 0
Pipe Fac Name Cushing Central Terminal
Segment Name Tank 2504
Onshore State Abbreviation Ok
Onshore Postal Code 74023
Onshore City Name Not Within A Municipality
Onshore County Name Payne
Designated Location Milepost/valve Station
Designated Name Tank 2504
Federal No
Location Type Totally Contained On Operator-Controlled Property
Incident Area Type Tank, Including Attached Appurtenances
Crossing No
Pipe Facility Type Intrastate
Item Involved Tank/vessel
Tank Vessel Subtype Roof Drain System
Tank Type Atmospheric
Installation Year 2004
Material Involved Carbon Steel
Release Type Overfill Or Overflow
Wildlife Impact Ind No
Soil Contamination Yes
Long Term Assessment No
Remediation Ind Yes
Soil Remed Ind Yes
Water Contam Ind No
Could Be Hca Yes
Commodity Reached Hca No
Est Cost Oper Paid 0
Est Cost Gas Released 0
Est Cost Prop Damage 587
Est Cost Emergency 55503
Est Cost Environmental 12259
Est Cost Other 0
Est Cost Other Details 0
Prpty 68349
Accident Psig 0
Mop Psig 0
Accident Pressure Pressure Did Not Exceed Mop
Pressure Restriction Ind No
Pipeline Function > 20% Smys Regulated Transmission
Scada In Place Ind Yes
Scada Operating Ind Yes
Scada Functional Ind Yes
Scada Detection Ind No
Scada Conf Ind No
Cpm In Place Ind Yes
Cpm Operating Ind Yes
Cpm Functional Ind Yes
Cpm Detection Ind No
Cpm Conf Ind No
Investigation Status No, the operator did not find that an investigation of the controller(s) actions or control room issues was necessary due to: (provide an explanation for why the operator did not investigate)
Investigation Status Details Release from a tank. No controller actions were involved in the release.
Employee Drug Test Ind No
Contractor Drug Test Ind No
Cause Natural Force Damage
Cause Details Heavy Rains/floods
Natural Force Type Heavy Rains/floods
Heavy Rains Subtype Other
Nf Other Details ,,,,,,,,,,,rain Accumulation Was Rapid. (5 Inches Plus Overnight) Winds Were High During Severe Storms. The Drains Were Capable Of Handling The Rainfall By Design But The Drain Was Partially Blocked With Hardened Blast Media Which Prevented The Check Valve From Fully Actuating. ,,,,,,,,,,,,,,,,,,
Nf Extreme Weather Ind Yes
Nf Other Ind Yes
Nf Extreme Weather Details Near Record Flooding, Multiple Storms, Extreme High Winds. Maximum Wind Gust Recorded At 90 Mph, With A Max Rainfall Rate Recorded Of Greater Than 1 Inch Per Hour (From The Nearest Mesonet Station)
Preparer Name G*** M*****
Preparer Title Manager Of Dot Compilance
Preparer Email G******@b***.com
Preparer Telephone 405-590-2035
Prepared Date 2019-07-01 00:00:00
Authorizer Name S**** R*********
Authorizer Telephone 903-576-3706
Authorizer Title Operations Manager - Cushing Terminal
Authorizer Email S***********@b***.com
Narrative During the night of wednesday may 8, 2019, the cushing area was inundated by a torrential rainfall event. This event produced over 5 inches of rainfall in a matter of hours. The roof drain system was unable to relieve the volume of water due to buildup of blast media in the check valve, preventing full actuation. This caused the roof to draft to oil level in tank, resulting in a manway failure, which released oil onto the roof exiting via the drain. At the time the release was discovered, the winds were steady at over 30 mph with gusts exceeding 45 mph. The high winds pushed the oil into one corner of the containment and gave the appearance of a smaller release. When the wind direction shifted, the oil circumvented the containment booms and covered the surface of the rainwater throughout the containment area. On thursday, once the amount of oil in the containment area became clear, bkep estimated the cost of the response to be below $50,000. On friday, may 10, remediation was nearly complete and the total estimated cost was $39,500. In the early hours of saturday, may 11, another large storm system hit the cushing area, causing an additional 4-5 inches of rainfall. That rain filled the containment berm and caused a sheen of oil on the rainwater within the containment. The second major storm lengthened the response beyond the scope of the initial estimate and caused the total cost of the response to exceed $50,000. That exceedance was not apparent until final invoices were received from the contractors the following week. Bkep did not call the nrc at the time of the second storm as it was several days after the initial release. Also, the part 195 criteria for immediate notification is based on estimates and not exact cost. Bkep's interpretation of the language of adb-02-04 supported the view that an nrc call was not required for a final cost which is a small amount over the estimated value of less than $50k. Adb-02-04 discusses when an additional call is required to the nrc to provide an update to initial estimates (which would be provided if those estimates are over 50k). It states that a damage cost estimate should be updated via an additional call if the cost is 10 times the estimated amount; for example, if the estimate had been $100,000, no update to the initial nrc call would be required unless the end cost exceeded $1 million. Bkep interpreted the same logic to apply if an initial cost estimate was less than $50k and therefore did not trigger a notification requirement and the cost at the end of the cleanup totaled slightly over $50k. Bkep's conclusion was that, based on the adb language, no nrc notification was required unless the end cost was significantly more than the initial estimates. For this report, bkep has marked question a6 as "required but not made" at the direction of regulatory personnel.

All rights reserved. Copyright © by ClearPHMSA