PLAINS PIPELINE, L.P. — Hazardous liquid — incident on 2018-08-28

Hazardous liquid incident in WICHITA FALLS, WICHITA County, TX. Reported cause: INCORRECT OPERATION. Reported consequences: 0 fatalities, 0 injuries, 0 CRUDE OIL released, $1,622,949 reported property damage. Operator-reported incident data submitted to PHMSA, generally within 30 days. Records may be supplemented or corrected and do not represent final agency causal findings.

Report number: 20190021.

Operator ID: 300.

Reported incident date: 8/28/2018 7:40.

Location detail: 0+00

Cause detail: DAMAGE BY OPERATOR OR OPERATOR'S CONTRACTOR NOT RELATED TO EXCAVATION AND NOT DUE TO MOTORIZED VEHICLE/EQUIPMENT DAMAGE

Cause detail: ON 08/28/2018 AT ~7:40 A.M., THE PRIMARY AND SECONDARY ROOF (RIM) SEALS ON A TANK AT PLAINS (PAA) WICHITA FALLS (WF) FACILITY WERE IN THE PROCESS OF BEING CHANGED AS PART OF ROUTINE MAINTENANCE WHEN VAPORS FROM THE TANK RIM CAUGHT FIRE. NO LIQUID WAS RELEASED. PAA INITIATED ITS STANDARD INTERNAL AND EXTERNAL NOTIFICATION PROTOCOLS. PAA CRISIS MANAGEMENT TEAM (CMT), INCLUDING THE CORPORATE CMT, WERE ACTIVATED. THE FIRE WAS EXTINGUISHED BY PAA PERSONNEL, TANK FIREFIGHTING EXPERIENCED EMERGENCY RESPONSE CONTRACTORS, AND LOCAL FIREFIGHTERS/RESPONDERS, AND THE TANK LATER REMOVED FROM SERVICE. TO PREVENT FUTURE INCIDENTS, PAA WILL REQUIRE A COMPANY REPRESENTATIVE TO REMAIN WITHIN LINE OF SIGHT DURING ALL IN-SERVICE SEAL REPLACEMENTS ON TANKS TO ENSURE ONLY SPARK RESISTANT TOOLS ARE USED. SINCE THE FIRE RESULTED IN AN EMISSIONS EVENT, TEXAS COMMISSION ON ENVIRONMENTAL QUALITY WAS NOTIFIED PER 30 TEX. ADMIN. CODE �101.201. PAA MADE A COURTESY CALL AT 8:41 A.M. TO PHMSA SOUTHWEST REGION STAFF WHO REQUESTED PAA MAKE A COURTESY NOTIFICATION TO THE NATIONAL RESPONSE CENTER (NRC). PAA PLACED A CALL TO NRC AT 9:00 A.M. & MADE A 48-HR FOLLOW UP CALL (REPORT #'S 1222913 & 1223012). PAA DID NOT INITIALLY COMPLETE A FORM 7000-1 REPORT AS IT DOES NOT BELIEVE ONE IS REQUIRED FOR AN EMISSIONS EVENT. BOTH 49 C.F.R. �195.54 AND �195.50 REQUIRE REPORTING OF ACCIDENTS THAT RESULT IN A RELEASE OF HAZARDOUS LIQUIDS, DEFINED IN �195.2 AS "PETROLEUM, PETROLEUM PRODUCTS, OR ANHYDROUS AMMONIA." PETROLEUM IS DEFINED AS "CRUDE OIL, CONDENSATE, NATURAL GASOLINE, NATURAL GAS LIQUID, AND LIQUEFIED PETROLEUM GAS." THE TANKS AT WF STORE CRUDE OIL. THE CAUSE OF THE RIM FIRE WAS IGNITION OF FLAMMABLE VAPORS DURING ROUTINE MAINTENANCE. A CONTRACTOR FAILED TO FOLLOW PAA'S JOB SAFETY ANALYSIS AND THEIR OWN PROCEDURE TO USE SPARK RESISTANT TOOLS. NOWHERE IN THE DEFINITIONS PROVIDED IN �195.2 IS "VAPOR", OR "FLAMMABLE VAPORS", DEFINED. FURTHER, NOR ARE THEY INCLUDED IN THE DEFINITION OF HAZARDOUS LIQUID, PETROLEUM, OR PETROLEUM PRODUCTS. ELSEWHERE �195.438 EXPRESSLY USES THE TERMS "FLAMMABLE HAZARDOUS LIQUID" AND "FLAMMABLE VAPORS" TO IDENTIFY TWO DISTINCT AND DIFFERENT PHYSICAL STATES. THE REPORTING REQUIREMENTS OF �195.52, AND �195.54 BY REFERENCE, APPLY TO THE RELEASE OF HAZARDOUS LIQUIDS; NEITHER MENTIONS, "FLAMMABLE VAPOR" OR "VAPORS". BASED ON THE CONSTRUCTION OF ITS REGULATIONS, PHMSA INTENDED THERE TO BE A DIFFERENCE BETWEEN HAZARDOUS LIQUIDS AND VAPORS; USING THEM ACCORDINGLY TO CREATE COMPLIANCE REQUIREMENTS FOR EACH CIRCUMSTANCE. FURTHER, PHMSA DOES NOT CURRENTLY EQUATE EXCESS VAPOR LOSSES FROM AROUND BREAKOUT TANK SEALS AS A LIQUID RELEASE. MODIFYING THE REGULATIONS TO DO SO WOULD REQUIRE OPERATORS TO REPORT SUCH VAPOR LOSSES TO BOTH THE EPA (AS IS CURRENTLY REQUIRED) AND TO PHMSA. WHILE PAA DOES NOT BELIEVE THAT SUBMISSION OF A 7000-1 REPORT IS REQUIRED FOR THIS SPECIFIC INCIDENT, PAA IS IN GOOD FAITH SUBMITTING THE ATTACHED REPORT AT THE REQUEST OF PHMSA. IN DOING SO, PAA RESERVES THE RIGHT TO CONTEST THE NECESSITY OF THE REPORT IN LATER PROCEEDINGS. �195.52 AND �195.54 ONLY APPLY IF �195.50 APPLIES. �195.50 IS SOLELY APPLICABLE TO RELEASES OF HAZARDOUS LIQUIDS OR CARBON DIOXIDE. INSTRUCTIONS FOR COMPLETING THE SPILL VOLUME, PER �195.54, ON PHMSA FORM 7000-1 [PART A, QUESTION 9 (REV 12-2015)], STATES PRODUCT CONSUMED BY FIRE INSIDE A TANK IS NOT TO BE COUNTED IN THE SPILL VOLUME. THERE WAS NO RELEASE OF A HAZARDOUS LIQUID FROM THE TANK. ALL LOSSES CAME FROM PRODUCT CONSUMED BY FIRE INSIDE THE PERIMETER OF THE TANK WALL, AND IS THEREFORE NOT TO BE COUNTED AS SPILL VOLUME, AS WE BELIEVE IS SPECIFICALLY CONTEMPLATED BY THE INSTRUCTIONS, MAKING THE REPORTED SPILL VOLUME "ZERO". PAA MAINTAINS THAT THIS INCIDENT IS NOT SUBJECT TO �195.50, �195.52, OR �195.54.- OPERATORS ARE NOT ABLE TO SUBMIT REPORTS WITH UNINTENTIONAL RELEASE VOLUME LESS THAN .1. AFTER COORDINATION WITH THE OPERATOR, PHMSA HAS UPDATED THE FINAL REPORT ON 05/29/2020 WITH UNINTENTIONAL RELEASE VOL

PHMSA trend classification: significant incident, not serious.

PHMSA standardized cause: INCORRECT OPERATION — DAMAGE BY OPERATOR OR OPERATOR'S CONTRACTOR.

PHMSA indexed costs: $2,030,538 reported total cost, $969,965.867 in 1984 dollars, $2,388,727.408 in current-year dollars.

PHMSA trend flags, standardized causes, and indexed costs are analytical fields added to operator-reported incident data. They do not represent final agency causal findings.