Failure Report- Sunoco Inc R&M 3/25/10

Page 1Official PDFDOT US Department of Transportation PHMSA Pipelines and Hazardous Materials Safety Administration OPS Office of Pipeline Safety Eastern Region Principal Investigator Al Schoen Region Director Byron Coy Date of Report 04/28/2011 Subject Failure Investigation Report – Sunoco R&M Flange Gasket Operator, Location, & Consequences Date of Failure 03/25/2010 Commodity Released Vacuum Gas Oil and Light Cycle Oil City/County & State Philadelphia, PA OpID & Operator Name 18779 Sunoco Inc, R&M Unit # & Unit Name 65981 Northeast Refinery Complex, PA SMART Activity # 129572 Milepost / Location Latitude 39.91934, Longitude -75.20447 Type of Failure Flange Leak caused by deteriorated gasket. The loss of pipe support and leakage through a closed valve contributed to the failure. Fatalities None Injuries None Description of area impacted Area designated as High Population Area in proximity to a Commercially Navigable Waterway ( Schuylkill River, Philadelphia). The area was under the control of the Operator in a fenced off area that is off-limits to the public. Property Damage $100,000 Page 1 of 3#

Page 2Failure Investigation Report – Sunoco R&M Flange Gasket 03/25/2010 Executive Summary On March 25, 2010, there was a release of 1700 barrels of Vacuum Gas Oil (VGO) from the FM-1 pipeline into an open in-ground valve pit and the surrounding area in the West Yard of the Sunoco, R&M Philadelphia refinery in Philadelphia, PA. The cause of the release was a failure of a flange gasket downstream of a main line valve in a dead leg of pipe leading to the FM-1 pig trap. Loss of pipe support and leakage through a closed valve contributed to the failure. There were no fatalities or injuries, and the incident did not result in a fire, explosion or evacuation. The flange gasket failed during a shipment of VGO between the Schuylkill River Tank Farm (SRTF) and the North Yard (NYOM) of the Refinery. The flange and pipe headers were located in a holding pit which overflowed during the release but was contained within the West Yard facility. System Details The FM-1 pipeline is approximately 2 miles long and connects two Sunoco Inc, R&M (Sunoco) tank farms. Appendix C is a schematic of the flow path at the West Yard. Product flows through the FM-1 MOV against the Mainline Valve to the FM-1 trap through C Header and down to the N-8 piping in the pit, through valve 1-22 and on to the North Yard. The Mainline Valve to the FM-1 trap is normally closed. The MOP of the pipeline system was 250 psig based on the ASME Class 150 valve and flanges operating at 200 degrees Fahreinheit. The pipe was 16” OD ASTM A53 Grade B Carbon Steel Seamless pipe, 0.312” wall thickness with Somastic coating. The pipeline was constructed in 1941. There is no reported history of failures on this line. There were no supply impacts as a new bypass piping was installed on 3/28/2010 and Sunoco was able to resume shipments three days after the incident. Events Leading up to the Failure (Appendix D) 3/18/2010: A Hydrochem (contract vacuum truck) employee who routinely monitored and managed residual oil accumulation in refinery sumps and the West Yard manifold pit reported heavy oil accumulation in the West Yard pit. This was believed to have been caused by ground water seepage into the valve pit. 03/21/2010, at 23:20 hrs: A shipment of VGO was started at 1000 bph from the Schuylkill River Tank Farm (SRTF) to the North Yard (NYOM) area of Sunoco’s Philadelphia Refinery (Appendix A) displacing Light Cycle Oil (LCO) from the pipeline. 3/22/2010 at 03:30 hrs: The LCO was totally displaced from the line and the pressure at NYOM climbed to 58 psig. All pressure readings referred to in this report were recorded at NYOM which is 2500 feet downstream of the valve pit at the West Yard (Appendix A). 3/24/2010 08:00 hrs: Pressure stayed constant till 08:00 hrs when the flow was cut back to 1000 BPH. At this point the pressure dropped to about 35 psi. 3/24/2010 at 20:25 hrs: The flow rate was increased to 2000 BPH and pressure rose to 80 psig. 3/25/2010 At 13:45 hrs: A contractor employee entered the West Yard and discovered a release of heavy oil in the valve pit. The pressure was noted at 35 psig. 3/25/2010 14:00 hrs: The pressure rose slightly to 38 psig and the pipeline was shutdown to change the valve lineup to allow flushing of the line with LCO. 3/25/2010 18:00 hrs: Flush was complete and the line was shut down and the piping manifold was isolated using the FM1 MOV and N-8 main line valves. Page 2 of 3#

Page 3Failure Investigation Report – Sunoco R&M Flange Gasket 03/25/2010 Emergency Response The leak was discovered at 13:45 and the line was shut down at 18:00 hrs, after the heavier VGO had been removed from the pipeline. Sunoco used a response contractor and its own resources to control and mitigate the leak. The area immediately around the valve pit was boomed off to contain the leaked product and prevent it from entering the surrounding water logged ground (Appendix B). The area was under the control of Sunoco in a fenced off area that is off-limits to the public. Summary of initial start-up plan and return-to-service, including preliminary safety measures The failed section of pipe was isolated. New piping was installed. The pipe was returned to service on 03/28/2010. Investigation Findings & Contributing Factors Sunoco conducted a pressure integrity test on the failed piping to determine source of the leak. This test identified the flange as the source. The loss of pipe support and leakage through a closed valve contributed to the failure (Appendix B). The mechanical failure of the Mainline valve seat and gate allowed product to pass into the section of piping including the failed flange. Failure of the paper gasket in the flange caused the flange to leak. Appendices A Sunoco Facility Maps B Photos C Flow Diagrams D Event Log Plot E PHMSA F7000-1 Report - Supplemental F NRC Report 935112 Page 3 of 3#

Page 4Appendix A – Sunoco Facility Maps Sunoco Facility West Yard Piping Page 1 of 2#

Page 5Appendix A – Sunoco Facility Maps Sunoco Facility Page 2 of 2#

Page 6Appendix B - Photos Photo 1 - Valve Pit Piping Page 1 of 9#

Page 7Appendix B - Photos Photo 2 - Bypass piping Page 2 of 9#

Page 8Appendix B - Photos Photo 3 – Flange Gasket Page 3 of 9#

Page 9Appendix B - Photos Photo 4 – Flange Face Page 4 of 9#

Page 10Appendix B - Photos Photo 5 – New Bypass Piping Page 5 of 9#

Page 11Appendix B - Photos Photo 6 – Spool Piece Support Page 6 of 9#

Page 12Appendix B - Photos Photo 7 – Trap Valves Page 7 of 9#

Page 13Appendix B - Photos Photo 8 – Trap Valve Test Page 8 of 9#

Page 14Appendix B - Photos Photo 9 – Spill Area 03272010 Photo 10– Spill Area 05192010 Page 9 of 9#

Page 15Appendix C – Flow Diagrams Existing Flow Diagram Page 1 of 2#

Page 16Appendix C – Flow Diagrams New Flow Diagram Page 2 of 2#

Page 17129572 Appendix D - Event Log Plot Date Time Event 3/21/2010 11:20 PM Started North Tank Field (NTF) Pump P-226 from GP TK284 VGO, pushing FM-1 / N-8 line fill of LCO to North Yard Oil Movements (NYOM) TK668. 3/22/2010 3:30 AM Opened VGO from GP TK284 into NYOM TK672 and cut away from TK668. 3/24/2010 8:25 PM Opened P-226 discharge valve, increased rate from 1000 bph (min) to 2200 bph (max). 3/25/2010 8:00 AM Adjusted (closed) P-226 discharge valve, decreased rate from 2200 bph (max) to 1000 bph (min). 3/25/2010 1:45 PM Discovered release from FM-1 / N-8 Manifold in West Yard. 3/25/2010 2:00 PM Shutdown P-226, manifold wash to ONT Line to GP TK284, started P-201A/B from GP South Tank Field (STF) TK219 LCO, to complete VGO flush of FM-1 /N-8 to NYOM TK672 at 1700 bph. 3/25/2010 4:25 PM Line wash rate reduced. 3/25/2010 6:00 PM P-201A/B shutdown. FM-1 / N-8 Lines displaced with LCO. FM-1 / N-8 Main Line Valve isolated. Page 1 of 5 1 of 1#

Page 18129572 Appendix E - PHMSA F 7000-1 Report Supplemental NOTICE: This report is required by 49 CFR Part 195. Failure to report can result in a civil penalty not to exceed $100,000 for each violation for each day that such violation persists except that the maximum civil penalty shall not exceed $1,000,000 as provided in 49 USC 60122. OMB NO: 2137-0047 EXPIRATION DATE: 01/31/2013 Report Date: 05/24/2010 U.S Department of Transportation Pipeline and Hazardous Materials Safety Administration No. 20100054 - 15114 -------------------------- (DOT Use Only) ACCIDENT REPORT - HAZARDOUS LIQUID PIPELINE SYSTEMS A federal agency may not conduct or sponsor, and a person is not required to respond to, nor shall a person be subject to a penalty for failure to comply with a collection of information subject to the requirements of the Paperwork Reduction Act unless that collection of information displays a current valid OMB Control Number. The OMB Control Number for this information collection is 2137-0047. Public reporting for this collection of information is estimated to be approximately 10 hours per response (5 hours for a small release), including the time for reviewing instructions, gathering the data needed, and completing and reviewing the collection of information. All responses to this collection of information are mandatory. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden to: Information Collection Clearance Officer, PHMSA, Office of Pipeline Safety (PHP-30) 1200 New Jersey Avenue, SE, Washington, D.C. 20590. INSTRUCTIONS Important: Please read the separate instructions for completing this form before you begin. They clarify the information requested and provide specific examples. If you do not have a copy of the instructions, you can obtain one from the PHMSA Pipeline Safety Community Web Page at http://www.phmsa.dot.gov/pipeline. PART A - KEY REPORT INFORMATION Report Type: (select all that apply) Original: Supplemental: Final: Yes Report Status Submitted Create Date 05/24/2010 Operator Name and Address 1. Operator's OPS-issued Operator Identification Number (OPID): 18779 2. Name of Operator SUNOCO, INC (R&M) 3. Address of Operator: 3a. Street Address BOX 426 3b. City MARCUS HOOK 3c. State Pennslyvania 3d. Zip Code 19061 4. Local time (24-hr clock) and date of the Accident: Date/Time 03/25/2010 13:42 5. Location of Accident: Latitude: 39.91934 Longitude: -75.20447 6. National Response Center Report Number (if applicable): 935112 7. Local time (24-hr clock) and date of initial telephonic report to the National Response Center (if applicable): Date/Time 03/25/2010 15:20 8. Commodity released: (select only one, based on predominant volume released) Refined and/or Petroleum Product (non-HVL) which is a Liquid at Ambient Conditions Specify Commodity Subtype: Other If "Other" Subtype, Describe: Vacuum Gas Oil (VGO) - If Biofuel/Alternative Fuel and Commodity Subtype is Ethanol Blend, then % Ethanol Blend: % - If Biofuel/Alternative Fuel and Commodity Subtype is Biodiesel, then Biodiesel Blend (e.g. B2, B20, B100): B 9. Estimated volume of commodity released unintentionally: Barrels: 1,700.00 10. Estimated volume of intentional and/or controlled release/blowdown: Barrels: 11. Estimated volume of commodity recovered: Barrels: 1,699.00 12. Were there fatalities? No - If Yes, specify the number in each category: 12a. Operator employees 12b. Contractor employees working for the Operator 12c. Non-Operator emergency responders 12d. Workers working on the right-of-way, but NOT associated with this Operator 12e. General public 12f. Total fatalities (sum of above) 13. Were there injuries requiring inpatient hospitalization? No - If Yes, specify the number in each category: Page 1 of 14 1 of 14#

Page 19129572 Appendix E - PHMSA F 7000-1 Report Supplemental 13a. Operator employees 13b. Contractor employees working for the Operator 13c. Non-Operator emergency responders 13d. Workers working on the right-of-way, but NOT associated with this Operator 13e. General public 13f. Total injuries (sum of above) 14. Was the pipeline/facility shut down due to the Accident? Yes If No, Explain: - If Yes, complete Questions 14a and 14b: (use local time, 24-hr clock) 14a. Local time and date of shutdown: Date/Time 03/25/2010 18:00 14b. Local time pipeline/facility restarted: Date/Time 03/28/2010 16:00 - Still shut down? (* Supplemental Report Required) 15. Did the commodity ignite? No 16. Did the commodity explode? No 17. Number of general public evacuated: 0 18. Time sequence (use local time, 24-hour clock): 18a. Local time Operator identified Accident: Date/Time 03/25/2010 13:42 18b. Local time Operator resources arrived on site: Date/Time 03/25/2010 13:49 PART B - ADDITIONAL LOCATION INFORMATION 1. Was the origin of Accident onshore? Yes If Yes, Complete Questions (2-12) If No, Complete Questions (13-15) - If Onshore: 2. State: Pennslyvania 3. Zip Code: 19145 4. City Philadelphia 5. County or Parish Philadelphia 6. Operator-designated location: (select only one) Milepost/Valve Station Specify: Philadelphia 7. Pipeline/Facility name: Philadelphia Refinery - West Yard 8. Segment name/ID: FM-1 Pipeline, ID# 11181 9. Was Accident on Federal land, other than the Outer Continental Shelf (OCS)? No 10. Location of Accident: (select only one) Totally contained on Operator-controlled property 11. Area of Accident (as found): (select only one) Aboveground If Underground, Aboveground or Transition Area, specify: Other - If Other, Describe: Inside an open vault below grade If Underground specify, Depth-of-Cover (in): 12. Did Accident occur in a crossing? No If Yes, specify below: - If "Bridge crossing" - Specify - If "Railroad crossing" - Specify - If "Road crossing" - Specify - If "Water crossing" - Specify - Name of body of water, if commonly known: - Approx. water depth (ft) at the point of the Accident: - Select: - If Offshore: 13. Approximate water depth (ft) at the point of the Accident: 14. Origin of Accident: - In State waters - Specify: State: Area: Block/Tract #: Nearest County/Parish: - On the Outer Continental Shelf (OCS) - Specify: Area: Block #: 15. Area of Accident: (select only one) PART C - ADDITIONAL FACILITY INFORMATION Page 2 of 14 2 of 14#

Page 20129572 Appendix E - PHMSA F 7000-1 Report Supplemental 1. Is the pipeline or facility: Intrastate 2. Part of system involved in Accident: (select only one) Onshore Pipeline, Including Valve Sites - If Onshore Breakout Tank or Storage Vessel, Including Attached Appurtenances, specify: 3. Item involved in Accident: (select only one) Flange - If Pipe, specify: 3a. Nominal diameter of pipe (in): 3b. Wall thickness (in): 3c. SMYS (Specified Minimum Yield Strength) of pipe (psi): 3d. Pipe specification: 3e. Pipe Seam , specify: - If Other, Describe: 3f. Pipe manufacturer: 3g. Year of manufacture: 3h. Pipeline coating type at point of Accident, specify: - If Other, Describe: - If Weld, including heat-affected zone, specify: - If Other, Describe: - If Valve, specify: - If Mainline, specify: - If Other, Describe: 3i. Manufactured by: 3j. Year of manufacture: - If Tank/Vessel, specify: - If Other - Describe: - If Other, describe: 4. Year item involved in Accident was installed: 5. Material involved in Accident: Carbon Steel - If Material other than Carbon Steel, specify: 6. Type of Accident Involved: (select only one) Leak - If Mechanical Puncture, Approx. size: in. (axial) by in. (circumferential) - If Leak - Select Type Seal or Packing - If Other, Describe: - If Rupture - Select Orientation Other/Describe: Approx. size: in. (widest opening) by in. (length circumferentially or axially) - If Other, Describe: PART D - ADDITIONAL CONSEQUENCE INFORMATION 1. Wildlife impact: Yes 1a. If Yes, specify all that apply: - Fish/aquatic Yes - Birds - Terrestrial 2. Soil contamination: Yes 3. Long term impact assessment performed or planned: Yes 4. Anticipated remediation: Yes 4a. If Yes, specify all that apply: - Surface water - Groundwater - Soil Yes - Vegetation Yes - Wildlife 5. Water contamination: No 5a. If Yes, specify all that apply: - Ocean/Seawater - Surface - Groundwater - Drinking water: (Select one or both) - Private Well - Public Water Intake 5b. Estimated amount released in or reaching water: Barrels: 5c. Name of body of water, if commonly known: 6. At the location of this Accident, had the pipeline segment or facility Yes Page 3 of 14 3 of 14#

Page 21129572 Appendix E - PHMSA F 7000-1 Report Supplemental been identified as one that "could affect" a High Consequence Area (HCA) as determined in the Operator's Integrity Management Program? 7. Did the released commodity reach or occur in one or more High Consequence Area (HCA)? Yes 7a. If Yes, specify HCA type(s): (Select all that apply) - Commercially Navigable Waterway: Was this HCA identified in the "could affect" determination for this Accident site in the Operator's Integrity Management Program? - High Population Area: Yes Was this HCA identified in the "could affect" determination for this Accident site in the Operator's Integrity Management Program? Yes - Other Populated Area Was this HCA identified in the "could affect" determination for this Accident site in the Operator's Integrity Management Program? - Unusually Sensitive Area (USA) - Drinking Water Yes Was this HCA identified in the "could affect" determination for this Accident site in the Operator's Integrity Management Program? No - Unusually Sensitive Area (USA) - Ecological Was this HCA identified in the "could affect" determination for this Accident site in the Operator's Integrity Management Program? 8. Estimated cost to Operator : 8a. Estimated cost of public and non-Operator private property damage paid/reimbursed by the Operator $ 0 8b. Estimated cost of commodity lost $ 0 8c. Estimated cost of Operator's property damage & repairs $ 0 8d. Estimated cost of Operator's emergency response $ 0 8e. Estimated cost of Operator's environmental remediation $ 100,000 8f. Estimated other costs $ 0 Describe: 8g. Estimated total costs (sum of above) $ PART E - ADDITIONAL OPERATING INFORMATION 1. Estimated pressure at the point and time of the Accident (psig): 80.00 2. Maximum Operating Pressure (MOP) at the point and time of the Accident: 250.00 (psig): 3. Describe the pressure on the system or facility relating to the Accident: (select only one) Pressure did not exceed MOP (psig): 4. Not including pressure reductions required by PHMSA regulations (such as for repairs and pipe movement), was the system or facility relating to the Accident operating under an established pressure restriction with pressure limits below those normally allowed by the MOP? No - If Yes, Complete 4.a and 4.b below: 4a. Did the pressure exceed this established pressure restriction? 4b. Was this pressure restriction mandated by PHMSA or the State? 5. Was "Onshore Pipeline, Including Valve Sites" OR "Offshore Pipeline, Including Riser and Riser Bend" selected in PART C, Question 2? Yes - If Yes - (Complete 5a. – 5f. below) 5a. Type of upstream valve used to initially isolate release source: Manual 5b. Type of downstream valve used to initially isolate release source: Manual 5c. Length of segment isolated between valves (ft): 2,340 5d. Is the pipeline configured to accommodate internal inspection tools? Yes - If No, Which physical features limit tool accommodation? (select all that apply) - Changes in line pipe diameter - Presence of unsuitable mainline valves - Tight or mitered pipe bends - Other passage restrictions (i.e. unbarred tee's, projecting instrumentation, etc.) Page 4 of 14 4 of 14#

Page 22129572 Appendix E - PHMSA F 7000-1 Report Supplemental - Extra thick pipe wall (applicable only for magnetic flux leakage internal inspection tools) - Other - - If Other, Describe: 5e. For this pipeline, are there operational factors which significantly complicate the execution of an internal inspection tool run? No - If Yes, Which operational factors complicate execution? (select all that apply) - Excessive debris or scale, wax, or other wall buildup - Low operating pressure(s) - Low flow or absence of flow - Incompatible commodity - Other - - If Other, Describe: 5f. Function of pipeline system: (select only one) =< 20% SMYS Regulated Trunkline/Transmission 6. Was a Supervisory Control and Data Acquisition (SCADA)-based system in place on the pipeline or facility involved in the Accident? No If Yes - 6a. Was it operating at the time of the Accident? 6b. Was it fully functional at the time of the Accident? 6c. Did SCADA-based information (such as alarm(s), alert(s), event(s), and/or volume calculations) assist with the detection of the Accident? 6d. Did SCADA-based information (such as alarm(s), alert(s), event(s), and/or volume calculations) assist with the confirmation of the Accident? 7. Was a CPM leak detection system in place on the pipeline or facility involved in the Accident? No - If Yes: 7a. Was it operating at the time of the Accident? 7b. Was it fully functional at the time of the Accident? 7c. Did CPM leak detection system information (such as alarm(s), alert(s), event(s), and/or volume calculations) assist with the detection of the Accident? 7d. Did CPM leak detection system information (such as alarm(s), alert(s), event(s), and/or volume calculations) assist with the confirmation of the Accident? 8. How was the Accident initially identified for the Operator? (select only one) Local Operating Personnel, including contractors - If Other, Specify: 8a. If "Controller", "Local Operating Personnel", including contractors", "Air Patrol", or "Guard Patrol by Operator or its contractor" is selected in Question 8, specify the following: (select only one) Contractor working for the Operator 9. Was an investigation initiated into whether or not the controller(s) or control room issues were the cause of or a contributing factor to the Accident? (Select only one) 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) - If 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) Review of operating data did not indicate an Abnormal Operating Condition (AOC) existed and was apparent to the controller prior to discovery of the release. - If Yes, specify investigation result(s): (select all that apply) - Investigation reviewed work schedule rotations, continuous hours of service (while working for the Operator), and other factors associated with fatigue - Investigation did NOT review work schedule rotations, continuous hours of service (while working for the Operator), and other factors associated with fatigue (provide an explanation for why not) (provide an explanation for why not) - Investigation identified no control room issues - Investigation identified no controller issues - Investigation identified incorrect controller action or controller error - Investigation identified that fatigue may have affected the controller(s) involved or impacted the involved controller(s) response - Investigation identified incorrect procedures - Investigation identified incorrect control room equipment operation Page 5 of 14 5 of 14#

Page 23129572 Appendix E - PHMSA F 7000-1 Report Supplemental - Investigation identified maintenance activities that affected control room operations, procedures, and/or controller response - Investigation identified areas other than those above: Describe: PART F - DRUG & ALCOHOL TESTING INFORMATION 1. As a result of this Accident, were any Operator employees tested under the post-accident drug and alcohol testing requirements of DOT's Drug & Alcohol Testing regulations? No - If Yes: 1a. Specify how many were tested: 1b. Specify how many failed: 2. As a result of this Accident, were any Operator contractor employees tested under the post-accident drug and alcohol testing requirements of DOT's Drug & Alcohol Testing regulations? No - If Yes: 2a. Specify how many were tested: 2b. Specify how many failed: PART G – APPARENT CAUSE Select only one box from PART G in shaded column on left representing the APPARENT Cause of the Accident, and answer the questions on the right. Describe secondary, contributing or root causes of the Accident in the narrative (PART H). Apparent Cause: G6 - Equipment Failure G1 - Corrosion Failure - only one sub-cause can be picked from shaded left-hand column Corrosion Failure – Sub Cause: - If External Corrosion: 1. Results of visual examination: - If Other, Describe: 2. Type of corrosion: (select all that apply) - Galvanic - Atmospheric - Stray Current - Microbiological - Selective Seam - Other: - If Other, Describe: 3. The type(s) of corrosion selected in Question 2 is based on the following: (select all that apply) - Field examination - Determined by metallurgical analysis - Other: - If Other, Describe: 4. Was the failed item buried under the ground? - If Yes : 4a. Was failed item considered to be under cathodic protection at the time of the Accident? If Yes - Year protection started: 4b. Was shielding, tenting, or disbonding of coating evident at the point of the Accident? 4c. Has one or more Cathodic Protection Survey been conducted at the point of the Accident? - If Yes, CP Annual Survey ---> Most recent year conducted: - If Yes, Close Interval Survey ---> Most recent year conducted: - If Yes, Other CP Survey ---> Most recent year conducted: - If No: 4d. Was the failed item externally coated or painted? 5. Was there observable damage to the coating or paint in the vicinity of the corrosion? - If Internal Corrosion: 6. Results of visual examination: - Other: 7. Type of corrosion (select all that apply): - Page 6 of 14 6 of 14#

Page 24129572 Appendix E - PHMSA F 7000-1 Report Supplemental - Corrosive Commodity - Water drop-out/Acid - Microbiological - Erosion - Other: - If Other, Describe: 8. The cause(s) of corrosion selected in Question 7 is based on the following (select all that apply): - - Field examination - Determined by metallurgical analysis - Other: - If Other, Describe: 9. Location of corrosion (select all that apply): - - Low point in pipe - Elbow - Other: - If Other, Describe: 10. Was the commodity treated with corrosion inhibitors or biocides? 11. Was the interior coated or lined with protective coating? 12. Were cleaning/dewatering pigs (or other operations) routinely utilized? 13. Were corrosion coupons routinely utilized? Complete the following if any Corrosion Failure sub-cause is selected AND the "Item Involved in Accident" (from PART C, Question 3) is Tank/Vessel. 14. List the year of the most recent inspections: 14a. API Std 653 Out-of-Service Inspection - No Out-of-Service Inspection completed 14b. API Std 653 In-Service Inspection - No In-Service Inspection completed Complete the following if any Corrosion Failure sub-cause is selected AND the "Item Involved in Accident" (from PART C, Question 3) is Pipe or Weld. 15. Has one or more internal inspection tool collected data at the point of the Accident? 15a. If Yes, for each tool used, select type of internal inspection tool and indicate most recent year run: - - Magnetic Flux Leakage Tool Most recent year: - Ultrasonic Most recent year: - Geometry Most recent year: - Caliper Most recent year: - Crack Most recent year: - Hard Spot Most recent year: - Combination Tool Most recent year: - Transverse Field/Triaxial Most recent year: - Other Most recent year: Describe: 16. Has one or more hydrotest or other pressure test been conducted since original construction at the point of the Accident? If Yes - Most recent year tested: Test pressure: 17. Has one or more Direct Assessment been conducted on this segment? - If Yes, and an investigative dig was conducted at the point of the Accident:: Most recent year conducted: - If Yes, but the point of the Accident was not identified as a dig site: Most recent year conducted: 18. Has one or more non-destructive examination been conducted at the point of the Accident since January 1, 2002? 18a. If Yes, for each examination conducted since January 1, 2002, select type of non-destructive examination and indicate most recent year the examination was conducted: - Radiography Most recent year conducted: - Guided Wave Ultrasonic Most recent year conducted: Page 7 of 14 7 of 14#

Page 25129572 Appendix E - PHMSA F 7000-1 Report Supplemental - Handheld Ultrasonic Tool Most recent year conducted: - Wet Magnetic Particle Test Most recent year conducted: - Dry Magnetic Particle Test Most recent year conducted: - Other Most recent year conducted: Describe: G2 - Natural Force Damage - only one sub-cause can be picked from shaded left-handed column Natural Force Damage – Sub-Cause: - If Earth Movement, NOT due to Heavy Rains/Floods: 1. Specify: - If Other, Describe: - If Heavy Rains/Floods: 2. Specify: - If Other, Describe: - If Lightning: 3. Specify: - If Temperature: 4. Specify: - If Other, Describe: - If Other Natural Force Damage: 5. Describe: Complete the following if any Natural Force Damage sub-cause is selected. 6. Were the natural forces causing the Accident generated in conjunction with an extreme weather event? 6a. If Yes, specify: (select all that apply) - - Hurricane - Tropical Storm - Tornado - Other - If Other, Describe: G3 - Excavation Damage - only one sub-cause can be picked from shaded left-hand column Excavation Damage – Sub-Cause: - If Previous Damage due to Excavation Activity: Complete Questions 1-5 ONLY IF the "Item Involved in Accident" (from PART C, Question 3) is Pipe or Weld. 1. Has one or more internal inspection tool collected data at the point of the Accident? 1a. If Yes, for each tool used, select type of internal inspection tool and indicate most recent year run: - - Magnetic Flux Leakage Most recent year conducted: - Ultrasonic Most recent year conducted: - Geometry Most recent year conducted: - Caliper Most recent year conducted: - Crack Most recent year conducted: - Hard Spot Most recent year conducted: - Combination Tool Most recent year conducted: - Transverse Field/Triaxial Most recent year conducted: - Other Most recent year conducted: Describe: 2. Do you have reason to believe that the internal inspection was completed BEFORE the damage was sustained? 3. Has one or more hydrotest or other pressure test been conducted since original construction at the point of the Accident? - If Yes: Page 8 of 14 8 of 14#

Page 26129572 Appendix E - PHMSA F 7000-1 Report Supplemental Most recent year tested: Test pressure (psig): 4. Has one or more Direct Assessment been conducted on the pipeline segment? - If Yes, and an investigative dig was conducted at the point of the Accident: Most recent year conducted: - If Yes, but the point of the Accident was not identified as a dig site: Most recent year conducted: 5. Has one or more non-destructive examination been conducted at the point of the Accident since January 1, 2002? 5a. If Yes, for each examination, conducted since January 1, 2002, select type of non-destructive examination and indicate most recent year the examination was conducted: - Radiography Most recent year conducted: - Guided Wave Ultrasonic Most recent year conducted: - Handheld Ultrasonic Tool Most recent year conducted: - Wet Magnetic Particle Test Most recent year conducted: - Dry Magnetic Particle Test Most recent year conducted: - Other Most recent year conducted: Describe: Complete the following if Excavation Damage by Third Party is selected as the sub-cause. 6. Did the operator get prior notification of the excavation activity? 6a. If Yes, Notification received from: (select all that apply) - - One-Call System - Excavator - Contractor - Landowner Complete the following mandatory CGA-DIRT Program questions if any Excavation Damage sub-cause is selected. 7. Do you want PHMSA to upload the following information to CGA-DIRT (www.cga-dirt.com)? 8. Right-of-Way where event occurred: (select all that apply) - - Public - If "Public", Specify: - Private - If "Private", Specify: - Pipeline Property/Easement - Power/Transmission Line - Railroad - Dedicated Public Utility Easement - Federal Land - Data not collected - Unknown/Other 9. Type of excavator: (select only one) 10. Type of excavation equipment: (select only one) 11. Type of work performed: (select only one) 12. Was the One-Call Center notified? 12a. If Yes, specify ticket number: 12b. If this is a State where more than a single One-Call Center exists, list the name of the One-Call Center notified: 13. Type of Locator: 14. Were facility locate marks visible in the area of excavation? 15. Were facilities marked correctly? 16. Did the damage cause an interruption in service? 16a. If Yes, specify duration of the interruption (hours) 17. Description of the CGA-DIRT Root Cause (select only the one predominant first level CGA-DIRT Root Cause and then, where available as a choice, the one predominant second level CGA-DIRT Root Cause as well): Root Cause: - If One-Call Notification Practices Not Sufficient, specify: - If Locating Practices Not Sufficient, specify: - If Excavation Practices Not Sufficient, specify: - If Other/None of the Above, explain: G4 - Other Outside Force Damage - only one sub-cause can be selected from the shaded left-hand column Page 9 of 14 9 of 14#

Page 27129572 Appendix E - PHMSA F 7000-1 Report Supplemental Other Outside Force Damage – Sub-Cause: - If Damage by Car, Truck, or Other Motorized Vehicle/Equipment NOT Engaged in Excavation: 1. Vehicle/Equipment operated by: (select only one) - If Damage by Boats, Barges, Drilling Rigs, or Other Maritime Equipment or Vessels Set Adrift or Which Have Otherwise Lost Their Mooring: 2. Select one or more of the following IF an extreme weather event was a factor: - Hurricane - Tropical Storm - Tornado - Heavy Rains/Flood - Other Describe: - If Previous Mechanical Damage NOT Related to Excavation: Complete Questions 3-7 ONLY IF the "Item Involved in Accident" (from PART C, Question 3) is Pipe or Weld. 3. Has one or more internal inspection tool collected data at the point of the Accident? 3a. If Yes, for each tool used, select type of internal inspection tool and indicate most recent year run: - Magnetic Flux Leakage Most recent year conducted: - Ultrasonic Most recent year conducted: - Geometry Most recent year conducted: - Caliper Most recent year conducted: - Crack Most recent year conducted: - Hard Spot Most recent year conducted: - Combination Tool Most recent year conducted: - Transverse Field/Triaxial Most recent year conducted: - Other Most recent year conducted: Describe: 4. Do you have reason to believe that the internal inspection was completed BEFORE the damage was sustained? 5. Has one or more hydrotest or other pressure test been conducted since original construction at the point of the Accident? - If Yes: Most recent year tested: Test pressure (psig): 6. Has one or more Direct Assessment been conducted on the pipeline segment? - If Yes, and an investigative dig was conducted at the point of the Accident: Most recent year conducted: - If Yes, but the point of the Accident was not identified as a dig site: Most recent year conducted: 7. Has one or more non-destructive examination been conducted at the point of the Accident since January 1, 2002? 7a. If Yes, for each examination conducted since January 1, 2002, select type of non-destructive examination and indicate most recent year the examination was conducted: - Radiography Most recent year conducted: - Guided Wave Ultrasonic Most recent year conducted: - Handheld Ultrasonic Tool Most recent year conducted: - Wet Magnetic Particle Test Most recent year conducted: - Dry Magnetic Particle Test Most recent year conducted: - Other Most recent year conducted: Describe: - If Intentional Damage: 8. Specify: - Other/Describe: Page 10 of 14 10 of 14#

Page 28129572 Appendix E - PHMSA F 7000-1 Report Supplemental - If Other Outside Force Damage: 9. Describe: G5 - Material Failure of Pipe or Weld - only one sub-cause can be selected from the shaded left-hand column Use this section to report material failures ONLY IF the "Item Involved in Accident" (from PART C, Question 3) is "Pipe" or " Weld." Material Failure of Pipe or Weld – Sub-Cause: 1. The sub-cause selected below is based on the following: (select all that apply) - Field Examination - Determined by Metallurgical Analysis - Other Analysis - If "Other Analysis", Describe: - Sub-cause is Tentative or Suspected; Still Under Investigation (Supplemental Report required) - If Construction, Installation, or Fabrication-related: 2. List contributing factors: (select all that apply) - Fatigue or Vibration-related Specify: - If Other, Describe: - Mechanical Stress: - Other - If Other, Describe: - If Original Manufacturing-related (NOT girth weld or other welds formed in the field): 2. List contributing factors: (select all that apply) - Fatigue or Vibration-related: Specify: - If Other, Describe: - Mechanical Stress: - Other - If Other, Describe: - If Environmental Cracking-related: 3. Specify: - Other - Describe: Complete the following if any Material Failure of Pipe or Weld sub-cause is selected. 4. Additional factors: (select all that apply): - Dent - Gouge - Pipe Bend - Arc Burn - Crack - Lack of Fusion - Lamination - Buckle - Wrinkle - Misalignment - Burnt Steel - Other: - If Other, Describe: 5. Has one or more internal inspection tool collected data at the point of the Accident? 5a. If Yes, for each tool used, select type of internal inspection tool and indicate most recent year run: - Magnetic Flux Leakage Most recent year run: - Ultrasonic Most recent year run: - Geometry Most recent year run: - Caliper Most recent year run: - Crack Most recent year run: - Hard Spot Most recent year run: - Combination Tool Most recent year run: - Transverse Field/Triaxial Most recent year run: Page 11 of 14 11 of 14#

Page 29129572 Appendix E - PHMSA F 7000-1 Report Supplemental - Other Most recent year run: Describe: 6. Has one or more hydrotest or other pressure test been conducted since original construction at the point of the Accident? - If Yes: Most recent year tested: Test pressure (psig): 7. Has one or more Direct Assessment been conducted on the pipeline segment? - If Yes, and an investigative dig was conducted at the point of the Accident - Most recent year conducted: - If Yes, but the point of the Accident was not identified as a dig site - Most recent year conducted: 8. Has one or more non-destructive examination(s) been conducted at the point of the Accident since January 1, 2002? 8a. If Yes, for each examination conducted since January 1, 2002, select type of non-destructive examination and indicate most recent year the examination was conducted: - - Radiography Most recent year conducted: - Guided Wave Ultrasonic Most recent year conducted: - Handheld Ultrasonic Tool Most recent year conducted: - Wet Magnetic Particle Test Most recent year conducted: - Dry Magnetic Particle Test Most recent year conducted: - Other Most recent year conducted: Describe: G6 – Equipment Failure - only one sub-cause can be selected from the shaded left-hand column Equipment Failure – Sub-Cause: Non-threaded Connection Failure - If Malfunction of Control/Relief Equipment: 1. Specify: (select all that apply) - - Control Valve - Instrumentation - SCADA - Communications - Block Valve - Check Valve - Relief Valve - Power Failure - Stopple/Control Fitting - ESD System Failure - Other - If Other – Describe: - If Pump or Pump-related Equipment: 2. Specify: - If Other – Describe: - If Threaded Connection/Coupling Failure: 3. Specify: - If Other – Describe: - If Non-threaded Connection Failure: 4. Specify: Gasket - If Other – Describe: - Other Equipment Failure: 5. Describe: Complete the following if any Equipment Failure sub-cause is selected. 6. Additional factors that contributed to the equipment failure: (select all that apply) - Excessive vibration - Overpressurization - No support or loss of support Yes - Manufacturing defect - Loss of electricity Page 12 of 14 12 of 14#

Page 30129572 Appendix E - PHMSA F 7000-1 Report Supplemental - Improper installation - Mismatched items (different manufacturer for tubing and tubing fittings) - Dissimilar metals - Breakdown of soft goods due to compatibility issues with transported commodity - Valve vault or valve can contributed to the release - Alarm/status failure - Misalignment - Thermal stress - Other - If Other, Describe: G7 - Incorrect Operation - only one sub-cause can be selected from the shaded left-hand column Incorrect Operation – Sub-Cause: - If Tank, Vessel, or Sump/Separator Allowed or Caused to Overfill or Overflow: 1. Specify: - If Other, Describe: - If Other Incorrect Operation: 2. Describe: Complete the following if any Incorrect Operation sub-cause is selected. 3. Was this Accident related to (select all that apply): - - Inadequate procedure - No procedure established - Failure to follow procedure - Other: - If Other, Describe: 4. What category type was the activity that caused the Accident? 5. Was the task(s) that led to the Accident identified as a covered task in your Operator Qualification Program? 5a. If Yes, were the individuals performing the task(s) qualified for the task(s)? G8 - Other Accident Cause - only one sub-cause can be selected from the shaded left-hand column Other Accident Cause – Sub-Cause: - If Miscellaneous: 1. Describe: - If Unknown: 2. Specify: PART H - NARRATIVE DESCRIPTION OF THE ACCIDENT 4/23/2010 Narrative Description (Partial): On 3/25/2010 at 13:45 hours, a contractor employee working for Sunoco, Inc. (R&M) entered the West Yard section of the Philadelphia Refinery and discovered a release of heavy oil around a valve manifold which connects the FM-1 Pipeline to the N-8 Pipeline. The contractor employee notified Sunoco personnel and a response was initiated. The Vacuum Gas Oil (VGO) transfer was shutdown at 14:00 hours and, due to the high viscosity of the product, the heavy material was immediately displaced from the pipeline with Light Cycle Oil (LCO) and isolated by 18:00 hours. On 4/5/2010, the source of the release was determined to have been a flanged connection on the FM-1 pig trap, normally isolated, except during pigging activity. The pig trap was last used during an in-line inspection conducted on June 23, 2008. A more thorough evaluation will be performed to identify the failure mechanism that resulted in the release from the flanged connection. A Hydrochem (vacuum truck) employee, who routinely monitored and managed residual oil that accumulated in refinery sumps, including the West Yard valve manifold vault, reported that oil accumulation appeared to intensify and was found outside the vault beginning about 3/15/2010. This was believed to be caused by typical residual ground seepage exacerbated by excessive rainfall and snow thaw. Operations turnover reports from 3/15/10 to 3/25/10 have only one report of heavy oil on water (3/18/10). This again was removed by Hydrochem vacuum trucks. On the morning of 3/16/2010 , two Sunoco employees were in the West Yard for training purposes and did not notice a leak or heavy oil at that time. On 3/24/2010 at 11:00 hours, another Sunoco employee was in the West Yard and did not report a release at that time. In addition, on 3/24 at 13:37 hours, a Hydrochem employee entered the West Yard to vacuum residual oil from the valve manifold vault. The release is believed to have started in the 24 hours prior to discovery. A total of 1,700 barrels was released and nearly all of the material has been recovered. 5/19/2010 Update: The FM-1 pig trap was about 39 1/2¿ in length, measured from the flange at the inlet/outlet valve to the flange at the closure. The trap was initially supported at three locations. The trap was supported at the containment wall around the manifold, 9¿-4¿ from the flange at the closure. The trap was also supported by its flanged connection to the inlet/outlet valve. Due to its length, it was also supported, adjacent to the failed center flange. The center flange was 5¿-0¿ from the inlet/outlet valve. The center support is believed to have been located in the 5¿ spool, within 12¿ from the center flange. The support consisted of a structural column, a base plate at the bottom that rested on the floor of the manifold containment, and a two-part clamp-style fitting at the top which secured the support to the outside diameter of the carrier pipe. Once the FM-1 trap was removed, the center support was found in the containment, detached and separated from the FM-1 trap piping. Page 13 of 14 13 of 14#

Page 31129572 Appendix E - PHMSA F 7000-1 Report Supplemental It is concluded that the lack of support at the center flange, allowed pipe movement over time, including movement caused by thermal cycling, which applied a differential stress on the flange bolts and eventually caused the flange to open at the 8:00 o¿clock position. The FM-1 trap inlet/outlet valve was found to have a mechanical defect which prevented a tight shut-off, which allowed product from the FM-1 pipeline transfer to pass through the valve, into the pig trap, causing the release from the center flange. No corrosion of the flange faces or other mechanical damage was observed. PART I - PREPARER AND AUTHORIZED SIGNATURE Preparer's Name Brian D. Mc Tiernan Preparer's Title Pipeline Safety Specialist Preparer's Telephone Number 610-833-3430 Preparer's E-mail Address bdmctiernan@sunocoinc.com Preparer's Facsimile Number 877-588-8590 Authorized Signature's Name Brian D. Mc Tiernan Authorized Signature Title Pipeline Safety Specialist Authorized Signature Telephone Number 610-833-3430 Authorized Signature Email bdmctiernan@sunocoinc.com Prepare Date 05/24/2010 Page 14 of 14 14 of 14#

Page 32Page 1 of 2 129572 Appendix F - NRC Report NATIONAL RESPONSE CENTER 1-800-424-8802 *** For Public Use *** Information released to a third party shall comply with any applicable federal and/or state Freedom of Information and Privacy Laws Incident Report # 935112 INCIDENT DESCRIPTION *Report taken at 15:30 on 25-MAR-10 Incident Type: FIXED Incident Cause: UNKNOWN Affected Area: The incident occurred on 25-MAR-10 at 15:20 local time. Affected Medium: LAND SOIL ____________________________________________________________________________ SUSPECTED RESPONSIBLE PARTY Organization: SUNOCO PHILADELPHIA, PA Type of Organization: PRIVATE ENTERPRISE ____________________________________________________________________________ INCIDENT LOCATION 3144 PASSYUNK County: PHILADELPHIA City: PHILADELPHIA State: PA REFINERY ____________________________________________________________________________ RELEASED MATERIAL(S) CHRIS Code: OTH Official Material Name: OTHER OIL Also Known As: VGO (A HEAVY GAS OIL) Qty Released: 0 UNKNOWN AMOUNT ____________________________________________________________________________ DESCRIPTION OF INCIDENT CALLER STATED THAT THERE WAS A DISCHARGE OF VGO (A HEAVY GAS OIL) FROM A PIPE AT A REFINERY. CALLER STATED THAT THE AMOUNT IS ESTIMATED TO BE A COUPLE OF HUNDRED GALLONS, NO WATERWAYS AFFECTED. THE CAUSE IS UNDER INVESTIGATION. ____________________________________________________________________________ INCIDENT DETAILS Package: N/A Building ID: Type of Fixed Object: REFINERY Power Generating Facility: NO Generating Capacity: Type of Fuel: NPDES: NPDES Compliance: UNKNOWN ____________________________________________________________________________ DAMAGES Fire Involved: NO Fire Extinguished: UNKNOWN INJURIES: NO Hospitalized: Empl/Crew: Passenger: FATALITIES: NO Empl/Crew: Passenger: Occupant: EVACUATIONS: NO Who Evacuated: Radius/Area: Damages: NO Length of Direction of Closure Type Description of Closure Closure Closure Air: N Road: N Waterway: N Track: N Major Artery: N 1 of 2 http://www.nrc.uscg.mil/reports/rwservlet?standard web+inc _ _ seq=935112 4/27/2011#

Page 33Page 2 of 2 129572 Appendix F - NRC Report Passengers Transferred: NO Environmental Impact: UNKNOWN Media Interest: NONE Community Impact due to Material: ____________________________________________________________________________ REMEDIAL ACTIONS CLEANUP UNDERWAY WITH VACUUM TRUCKS AND SORBENTS. Release Secured: YES Release Rate: Estimated Release Duration: ____________________________________________________________________________ WEATHER Weather: OVERCAST, ºF ____________________________________________________________________________ ADDITIONAL AGENCIES NOTIFIED Federal: NONE State/Local: PA DEP State/Local On Scene: NONE State Agency Number: NONE ____________________________________________________________________________ NOTIFICATIONS BY NRC ATLANTIC STRIKE TEAM (MAIN OFFICE) 25-MAR-10 15:40 DOT CRISIS MANAGEMENT CENTER (MAIN OFFICE) 25-MAR-10 15:40 U.S. EPA III (MAIN OFFICE) 25-MAR-10 15:41 FLD INTEL SUPPORT TEAM PHILADELPHIA (MAIN OFFICE) 25-MAR-10 15:40 NATIONAL INFRASTRUCTURE COORD CTR (MAIN OFFICE) 25-MAR-10 15:40 NJ STATE POLICE (MARINE SERVICES BUREAU) 25-MAR-10 15:40 NOAA RPTS FOR PA (MAIN OFFICE) 25-MAR-10 15:40 SECTOR DELAWARE BAY (COMMAND CENTER) 25-MAR-10 15:42 NJ DEP POC: DUTY OFFICER (MAIN OFFICE) 25-MAR-10 15:40 PA EMERG MGMT AGCY (MAIN OFFICE) 25-MAR-10 15:40 ____________________________________________________________________________ ADDITIONAL INFORMATION CALLER HAD NO ADDITIONAL INFORMATION. ___________________________________________________________________________ *** END INCIDENT REPORT # 935112 *** 2 of 2 http://www.nrc.uscg.mil/reports/rwservlet?standard web+inc _ _ seq=935112 4/27/2011#