AS-88529_0_CA_CAI_20220512

From: Jim Shay <[e-mail]>
Sent: Thursday, May 12, 2022 11:49 AM
To: Engard, Brett <[e-mail]>; Tom Huet <[e-mail]>
Subject: [External] RE: AS-88529 Russell Standard UST-62

Brett,

Please see attached the incident investigation form for the asphalt spill at our Black
Mountain, NC plant. The form includes several corrective actions that we are implementing to
prevent a recurrence. The form also includes a narrative of the release on Page 1.

Also, I will provide a written narrative of the cleanup here:

On 5/2/22, at 12:30 PM, an asphalt tank (Tank #16-250,000G Asphalt Cement Tank) was
overfilled at the Russell Standard Emulsion plant at 1561 Grovestone Rd, Black Mountain, NC
28711. The spill resulted in approximately 6 tons (~1,500 Gallons) of liquid asphalt to spill down
the side of the 250,000 gallon tank, spread around the perimeter of the tank, across an
access road, and to the banked edge of the secondary containment structure. Russell
Standard immediately employed it’s Facility Response Plan, which is a plan requirement of
the US EPA. After an initial assessment and immediate diking was established to stop the
asphalt from travelling any further, the notifications were made, an incident command post
was established, and the Oil Response Organization was contacted to respond to help with
the clean-up. US Ecology (Russell Standard Black Mountain’s designated OSRO) arrived on
the scene and immediately began recovery of the material. Raw asphalt does not penetrate
soils, and hardens as it cools, so the clean-up consisted primarily of rolling the material into
manageable rolls (which included the layer of limestone/gravel on top of the soil), and
loading the material into plastic-lined roll off containers for disposal in the landfill (asphalt is
a non-regulated waste). All records, bills of lading, and manifests for the loads to the landfill
are in possession of US Ecology at this time. Waste manifest records could be made available
at a later date, by request (we have not yet received them from US Ecology, who transferred
the loads on our behalf). After approximately 9 hours of clean-up activity in which all the
asphalt was scraped and removed from the base of the tank perimeter, the access road, the
containment structure bank, and any other spill material, US Ecology was released from the
site by the Russell Standard incident commander.

Tank #16 still has evidence of the spill on the side of the tank (on the outer skin of the
insulation). This asphalt is dried and hardened at this time, although still quite sticky in some
places. There is no risk of this material spreading or causing any damage to soils or
waterways of NC. Russell Standard is collecting quotes from industrial cleaning service
companies to professionally clean the residual material from the tank.

The estimated lost asphalt is 6 tons. The estimated dirt and comingled wastes (primarily
stone) accounts for another 2-3 tons of material for a grand total of 9 tons of comingled
waste shipped to the landfill. Unfortunately, spilled asphalt is rarely recoverable in a manner
that its reusable.

I included (attached) a site map in which I drew the impacted area. The entire spill has been
cleaned and removed from the site, with the exception of removing the stuck-on/hardened
asphalt on the side of the tank.

I believe I’ve included each of the items you’ve requested in the bullet points in your email
below. Please let me know if I missed anything. Also, please let us know if there are any more
questions.

Thank you,

Jim Shay
EHS Director

Mobile: [phone]
RussellStandard.com

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Russell Standard

SAFETY INCIDENT INVESTIGATION FORM

Site Location: Russell Standard- Black Mountain Emulsion Plant

Date of Incident: 5/2/22

Time of Incident: 12:30 PM

Employee Names (list names of employees involved or witnessing the incident):

1.) Eric Penland

2.) Keith Ellis

3.) Brian Jackson (not directly involved)

4.) Susan Boyle (In Lab at time of incident)

5.) Joel Perry (Off-Site at time of incident)

6.) Casey Clark (Maymead Driver in Plant at time of spill)

Incident Type (Circle or Highlight one):

• Injury/Illness
• Equipment Damage
• Property Damage
• Auto
• Near Miss
• Other (SPILL)

Was the Incident Preventable/Non Preventable by the employee(s) involved (circle or
highlight one):

MAJOR PREVENTABLE (>$3000 in damages or significant injury)

MINOR PREVENTABLE (<$2900 in damages or minor injury)

Copy valid only on date printed: 5/12/22

NON-PREVENTABLE (caused by third party, act of nature, etc.)

What was the task/job being performed? Give a brief description of the incident:

Eric Penland was offloading rail cars of asphalt into Tank #9, which is one of 2 large Asphalt
tanks at the Black Mountain plant. As the product was being unloaded, Keith Ellis noticed that
Tank #16 (250,000G) was overflowing from the top of the tank, with asphalt pouring down the
sides of the tank. Keith immediately notified Eric, who immediately shut the pump off. Then,
Eric proceeded to check the valves that direct product to the intended tank. Eric discovered
that a secondary valve that isolates Tank #16 from other tanks and completely stops the flow
of asphalt into Tank #16, was partially OPEN. The valve was approximately 1 and ½ turns open.
The valve should be normally closed. The open valve resulted in asphalt being able to pass
through the valve and into Tank #16, causing the tank to overflow. The product SHOULD have
been going into Tank #9 ONLY. Tank #16 has no overfill alarm, and a gauge board fill indicator
is the primary fill monitoring device.

Describe any tools, machinery, equipment, or PPE that was being used at the time of the
incident:
1.) Rail car Offloading equipment (pump, face shield, hand tools)
2.) Normal Plant PPE

Was the employee working alone? Yes No

Witness Name(s):

1.) Eric Penland
2.) Keith Ellis

Contributing Factors:
1.) Valves are not labeled. Valves are not labeled “OPEN” or “CLOSED”
2.) Valves are not physically checked prior to loading/unloading per written SOP.
3.) Prior unloading anomaly from 4-27-22 in which rail cars were unloaded into Tank #16
until gauge board read 35’6’’, and when the gauge board was “wiggled”, it self
adjusted to 36’1’’. This means that an overload event occurred on 4-27-22, although
this overload event was considered a mistake, and was not investigated as a potential

Copy valid only on date printed: 5/12/22

valve issue. This also means that the product in the tank was around 7” higher than
the safe fill level.
4.) Trucks loaded out of Tank #16 between 4-27-22, allowing the level of asphalt in Tank
#16 to drop slightly to below the safe fill point.
5.) When the offloading of railcars on 5-2-22 began, the intent was to direct ALL asphalt
into Tank #9. Due to the secondary valve being 1 and ½ turns OPEN, some asphalt was
allowed into Tank #16.
6.) Not having valves marked OPEN and CLOSED, as well as not following the SOP, which
states that valves must be checked prior to offloading, is a causal factor.
7.) The gauge board issue, as well as safe fill levels for Tank #16 needs to be investigated
for function and proper operation.
8.) Due to early season supply stocking, plant is managing constantly full capacity in
Asphalt tanks.

Did the incident involve neglect or abuse of company property or equipment? Yes No

If YES, Explain: NA

NOTE: If the answer to the above question is “YES”, send a copy of this completed form to
the Equipment Manager for assignment of Disciplinary Actions.

Was the incident reported in a timely manner by the employee(s) responsible: Yes No

Copy valid only on date printed: 5/12/22

ROOT CAUSE ANALYSIS

Why Did The Incident Happen?
It was assumed that “normally closed” valves were properly closed and secured. Valves
were not physically checked prior to unloading on 5-2-22. A prior incident of overfilling (4-
27-22) was assumed to be the result of a hung/stuck gauge board indicator.

WHY?
Valves are not labeled for function, but more importantly are not visibly identifiable as OPEN
or CLOSED.

WHY?
The SOP identifies the valves and the procedures for valve/tank isolation, but not everybody
in the plant has viewed or been trained on the SOP. Plant personnel did not follow the
written SOP. If the valve were properly closed, the spill incident with Tank #16 would not
have happened.
WHY?
Vibration from the pump and piping may have caused the valve to loosen and become
OPEN. No employee remembers ever opening the valve in the time period going back a
week or more.

WHY? Check of valve prior to unloading must take place every time. Follow SOP.

WHY?

How Can This Incident Be Prevented From Re-Occurring?
Revise SOP as needed to ensure valve configuration and sequencing is accurately depicted
(The main revision needed is to insert new photos after the chain pull device and markings
are implemented). Label all valves for function and product carried, including routing to
each Tank (by number). Label all valves for OPEN or CLOSED. Install a chain pull locking
device that will ensure the valve does not “walk” or vibrate open. Paint visual indicators that
can easily be seen that will help to be able to tell if the valve is properly OPEN or CLOSED.

Copy valid only on date printed: 5/12/22

Investigate the function of the gauge board on Tank #16. Install high level alarms on all
Asphalt tanks.

Steps For Corrective Action and Projected Completion Date:

Corrective Action Person Responsible Expected Completion Date
Revise SOP as needed to
ensure valve function is
accurate. Add language to
ensure operators check
valves before commencing
unloading.
Joel Perry 6/2/22
Label all valves for function
and product carried,
including routing to each
Tank (by number). Label all
valves for OPEN or CLOSED.
Joel Perry 6/2/22
Install a chain pull locking
device that will ensure the
valve does not “walk” or
vibrate open. Paint visual
indicators that can easily
be seen that will help to be
able to tell if the valve is
properly OPEN or CLOSED.
Joel Perry 6/2/22
Investigate the function of
the gauge board on Tank
#16. Install high level alarms
on all Asphalt tanks.
Joel Perry 6/2/22 (gauge board)
1/31/23 (overfill alarms)
Physically mark the “high
fill” or “Safe fill” mark on
gauge board, as well as on
Asphalt tanks.
Joel Perry 6/2/22

Corrective Actions Entered into “Actions Needed Register” by: NA

Disciplinary Action (if known by investigator(s)): NA

Copy valid only on date printed: 5/12/22

The following persons have participated in the incident investigation and root cause
analysis and are aware of the findings:

Jim Shay-EHS Director
Bob Guenther- Emulsion Operation Manager
Joel Perry-Black Mountain Plant Manager
Eric Penland-Plant Operator

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