Based on the information gathered, Ecology determined the cause of the
coupler breakaway and the subsequent spill was failure of the No. 4 MLA
coupler to remain locked on the ship’s flange. The origin of the loss of
lock could not be determined given the information gathered.
Ecology made the following prevention recommendations:
To the marine terminal operator (in addition to the actions already
undertaken):
1. Ensure that the marine loading arm coupler manufacturer provides a
comprehensive list of inspection and preventive maintenance items for the
Nos. 3 and 4 MLA couplers as well as the Nos. 1 and 2 couplers. The list
should include the appropriate torque values for all bolts that require
periodic inspection for tightness.
2. Ensure that all the appropriate marine terminal procedures are
modified to reference the use of the new positive hydraulic shut-off
valves and E-clips located on the couplers.
3. Ensure that all the appropriate marine terminal procedures
sufficiently emphasize that the design of the marine loading arm couplers
requires full rotation of the actuator collar to ensure proper (and
continuous) seal.
To the marine loading arm and coupler manufacturers:
1. Investigate a previous coupler release in New Jersey to determine if
there are similarities to this coupler release that require notification
of other facilities utilizing hydraulically-actuated couplers of similar
design by the manufacturer.
2. Review the coupler manuals supplied to facilities utilizing these
couplers and ensure that all inspection and preventive maintenance items
are clearly stated. Include torque values for all bolts that require
periodic inspection for tightness.
3. Investigate the marine terminal operator's conclusion that the
locking washers on the four bolts holding the clamp cylinder bracket to
the coupler “had lost much of their spring.” Should the conclusion show
merit, ensure that other facilities with similar couplers are properly
notified to inspect and/or replace those locking washers.
4. Review the prevention measures undertaken on the couplers installed
at this marine terminal for potential application to similar couplers
installed at other facilities.
5. Review the loading arm manufacturer's ISO 9001 quality control
system to ascertain how the couplers were installed without the
over-center lock indicators, why replacement indicators were not
subsequently ordered and installed, and why the opening of the No. 4 MLA
coupler during an installation and commissioning hydrotest under the
loading arm manufacturer's supervision was not documented.