Document 8Oang8raz9byJ3x9wGrDX2GB5

Enterprise GC LLC Texas City Terminal Inspection Date: 05/09/2023 - 05/11/2023 Inspection Date(s): Media Program: Regulatory Program(s) Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT 05/09/2023 - 05/11/2023 Air Clean Air Act (CAA) 112(r) and 40 Code of Federal Regulations (C.F.R.) Part 68 Chemical Accident Risk Management Plan (RMP) Program Level 3 Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact/Title: (email address) Enterprise GC LLC (EPCO) Texas City Terminal 700 14th Street South Texas City, Texas 77590 P.O. Box 4324 Houston, Texas 77210 Galveston Doug D'Aquila DJDAQUILA@eprod.com Staff Engineer - Safety/Process Safety Management (PSM) FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: 110000503054 Not Applicable RMP 10000 0006 5449 42471 - Petroleum Bulk Stations and Terminals Personnel participating in inspection: Tony Robledo U.S. EPA Aimee Boss U.S. EPA Tommy Montemayor Enterprise GC LLC Norman Slagle Enterprise GC LLC Cameron Bachtel Enterprise GC LLC Douglas D'Aquila Enterprise GC LLC Dwayne Zeno Enterprise GC LLC Kyle Wingate Enterprise GC LLC Heather Makarczyk Enterprise GC LLC Ricky Bockhorn Enterprise GC LLC Loren Toppass Enterprise GC LLC Ismael Gonzales Enterprise GC LLC Sean Boardman Enterprise GC LLC David Leiser Enterprise GC LLC Casey Shows Enterprise GC LLC Inspector/Enforcement Officer Inspector/Enforcement Officer Lead Operations Texas City Superintendent PSM Specialist Staff Engineer - Safety/PSM Safety PSM Manager Senior Field Environmental PSM Coordinator Maintenance Planner Maintenance Planner Mechanical Integrity (MI) Planner Director MI Senior Manager MI Supervisor EPA Lead Inspector Signature/Date ANTHONY ROBLEDO Digitally signed by ANTHONY ROBLEDO DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ANTHONY ROBLEDO, 0.9.2342.19200300.100.1.1=68001003655529 Date: 2023.05.19 15:03:11 -05'00' Tony Robledo Supervisor Signature/Date 6ENFORM-19-R8.2 (02/12/2020) SAMUEL TATES Date: 2023.05.22 10:02:08 -05'00' Digitally signed by SAMUEL TATES Samuel Tates 1 Enterprise GC LLC Texas City Terminal Inspection Date: 05/09/2023 - 05/11/2023 Section I - INTRODUCTION PURPOSE OF THE INSPECTON We, the Environmental Protection Agency (EPA) Region 6 inspectors Tony Robledo and Aimee Boss arrived at the Enterprise GS LLC facility at approximately 9:00 a.m. on May 9, 2023, for an announced inspection. We met with facility representatives noted above at the opening meeting. We presented our credentials and informed facility personnel that this was an EPA inspection to determine compliance with the Clean Air Act (CAA) Sections 112(r)(1) and 112(r)(7). The scope of the inspection was a partial compliance evaluation (PCE) and included evaluation of the facility's compliance with 40 C.F.R. Part 68 - Chemical Accident Prevention provisions. FACILITY DESCRIPTION The Enterprise GC LLC (EPCO) Texas City Terminal receives and distributes refinery grade propylene, refinery grade butane, propane, butane, isobutane, and butane/butylene mix. The facility also has nine liquified petroleum gas storage tanks, and an area for the loading/unloading of trucks and rail cars. The facility handles regulated flammable chemical mixtures above the RMP threshold quantity. There are no listed toxic substances stored at the facility which exceed their respective threshold quantities. EPCO began its current ownership and operation in 2002. There are four full-time employees at this non-union facility. The facility operates 24 hours a day, 7 days a week. Section II - OBSERVATIONS We conducted a walk-through of the facility, accompanied by facility representatives, to observe the facility process equipment, and overall operations. We used the Forward Looking Infrared (FLIRTM) Series GF320 camera, and observed no spills, leaks, or fugitive hydrocarbon emission trails. The findings are found on the RMP Program Level 3 Checklist, located in Appendix #1. During the walk-through, we observed that the facility was missing proper markings on piping (Photo Nos. 1, 2, 3 4 & 5 located in Appendix #2) - e.g., direction of flow, color-coding to identify the hazardous material present, placement of pipe labels, and type and size of letters on pipe labels - as required by the American National Standards Institute (ANSI)/the American Society of Mechanical Engineers (ASME) Standard A13.1 (ANSI/ASME A13.1), Scheme for the Identification of Piping Systems. This standard is considered a recognized and generally accepted good engineering practice for above ground piping systems. Section III - AREAS OF CONCERN Close-out Meeting - We convened a closing meeting on Thursday, May 11, 2023, to discuss the Area of Concern (AOC) noted during the inspection, the inspection completion process, and to answer questions from EPCO personnel. AOC 1. 40 C.F.R. 68.65(d)(2) - Process Safety Information (d) Information pertaining to the equipment in the process. (2) The owner or operator shall document that equipment complies with recognized and generally accepted good engineering practices. 2 Enterprise GC LLC Texas City Terminal Inspection Date: 05/09/2023 - 05/11/2023 EPCO failed to properly label piping for process equipment, as required by American National Standards Institutes (ANSI)/American Society of Mechanical Engineers (ASME) Standard A13.1. On May 18, 2023, EPCO provided additional documentation stating its justification for the Refinery Grade Propylene Surge Tank 57029-PV17.012 and associated piping being U.S. Department of Transportation jurisdictional. Section IV - FOLLOW UP Additional information and documentation were provided after the inspection as noted above. Section V - LIST OF APPENDICES Appendix #1 - RMP Program 1 Checklist Inspection Symbol Key: Y - Yes, N - No, N/A - Not Applicable; S - Satisfactory, M - Marginal, U - Unsatisfactory. Appendix #2 - Photo Log 3