Document B887KQZZxdL2m47va1Ldp4zqw

Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 08/18/2020 - 08/31/2020 Air RMP Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Williams Partners Operating LLC Larose Cryogenic Plant 1474 Highway 24 Larose, Louisiana 70373 Same as above Same as above Lafourche Calbert Dufrene Calbert.DufreneJr@williams.com Operations Manager FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: 110000753578 1560-00120-V12 RMP 1000 0011 3076 21113 Natural Gas Extraction 1311 Crude Petroleum and Natural Gas Personnel participating in inspection: Tony Robledo U.S. EPA Howard Cole U.S. EPA Keri Carson Meyers LDEQ Bryn Ray LDEQ Glen Jenkins LDEQ Jamie Vicknair LDEQ Calbert Dufrene Williams Partners Operating LLC Danny Pitre Williams Partners Operating LLC James Adams Williams Partners Operating LLC Charles Folse Williams Partners Operating LLC Jerry Knight Williams Partners Operating LLC Russell Gregg Williams Partners Operating LLC Justin Cortez Williams Partners Operating LLC Larry Green Williams Partners Operating LLC Brocke Marretta Williams Partners Operating LLC Inspector/Enforcement Officer Inspector Inspector Inspector Inspector Inspector Operations Manager Lead Operator Maintenance Supervisor Safety and Health Specialist Engineering Manager Environmental Specialist Coordinator of Maintenance Supervisor Asset Integrity Facility Engineer EPA Lead Inspector Signature/Date ANTHONY Tony Robledo 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: 2020.10.23 11:15:59 -05'00' Supervisor Signature/Date SAMUEL TATES Samuel Tates Digitally signed by SAMUEL TATES DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=SAMUEL TATES, 0.9.2342.19200300.100.1.1=68001003655433 Date: 2020.10.23 10:47:46 -05'00' 6ENFORM-020-R8.2 (02/12/2020) 1 Section I - INTRODUCTION PURPOSE OF THE INSPECTION Williams Partners Operating LLC Larose Cryogenic Plant Inspection Date: 08/18/2020 - 08/31/2020 On August 11, 2020, the United States Environmental Protection Agency (EPA) Region 6 sent an email to the Operations Manager, Williams Partners Operating LLC (Williams), at the Larose Cryogenic Plant, located in Larose, Louisiana, to announce the initiation of a Clean Air Act Risk Management Plan (RMP) Virtual Partial Compliance Evaluation (VPCE). The e-mail informed the Operations Manager at the Larose Cryogenic Plant of a Microsoft Teams video opening conference scheduled on August 18, 2020. During the video opening conference, Region 6 inspectors Tony Robledo and Howard Cole, and Louisiana Department of Environmental Quality (LDEQ) Chemical Accident Prevention Program inspectors Keri Meyers, Bryn Ray, Jamie Vicknair, and Glen Jenkins met with Calbert Dufrene (Operations Manager), Danny Pitre (Lead Operator), James Adams (Maintenance Supervisor), Charles Folse (Safety and Health Specialist), Jerry Knight (Engineering Manager), Russell Greg (Environmental Specialist), Justin Cortez (Coordinator of Maintenance), Larry Green (Supervisor Asset Integrity), and Brocke Marretta (Facility Engineer). I presented my credentials and informed Larose Cryogenic facility personnel that this was an EPA inspection to determine compliance with the federal Chemical Accident Prevention Program. The scope of the inspection was a virtual partial compliance evaluation (VPCE), which included an evaluation of the facility's compliance with the Clean Air Act (CAA) Section 112(r) and the Chemical Accident Prevention Provisions in 40 C.F.R. Part 68, as well as the General Duty Clause. EPA inspectors discussed general VPCE procedural questions, confidential business information (CBI) procedures, interview schedules, proposed timelines, the exit conference, and final report. This VPCE is a new compliance monitoring tool that EPA Region 6 is utilizing during the public health emergency generated by COVID-19.This inspection included reviewing and obtaining copies of documents and records, conducting interviews, and taking statements via video conference. FACILITY DESCRIPTION The Williams Larose facility is natural gas processing plant that receives natural gas from pipelines and separates the gas stream via fractionation into pipeline quality natural gas (primarily methane) and natural gas liquids (NGLs - ethane, propane, butanes, and natural gasoline). The products from the facility are transferred via commercial pipeline. As such, the Larose facility is classified as a Program 3 RMP facility. The facility handles flammable mixtures consisting of regulated chemicals in excess of the threshold amounts. The Larose facility does not use, process or store a reportable quantity of toxic regulated substances. The Larose facility employs 45 full-time employees at this non-union plant. The plant operates 24 hours a day, seven days a week. Section II - OBSERVATIONS EPA Region 6 documented its observations on the Program Level 3 Checklist (Appendix #1). 2 Williams Partners Operating LLC Larose Cryogenic Plant Inspection Date: 08/18/2020 - 08/31/2020 Section III - AREAS OF CONCERN Closing Meeting - A closing meeting was conducted on September 3, 2020, to discuss Areas of Concern (AOC), the inspection report completion process, and next steps. AOC 1 - 40 C.F.R. 68.65(d)(2) Process Safety Information. "The owner or operator shall document that equipment complies with recognized and generally accepted good engineering practices." Williams failed to properly classify process piping containing methane, ethane, propane, butane, and natural gas in accordance with API 570 Fourth Edition, February 2016, Piping Inspection Code: In-service Inspection, Rating, Repair, and Alteration of Piping Systems (API 570), Section 6.3.4. Piping Services Classes and Table 1. Piping Circuit DISC-LAR-FL-02, DISC-LAR-FL-03, DISC-LAR-FL-09 containing flare gas were not classified and should be Classified as Class 1. Piping Circuits LH-21, LH-25, LH-27 LH-47, LH-50, containing liquid hydrocarbons were improperly classified as Class 2 and not properly classified as Class 1. Piping Circuits G-04, G-18, G-19, G-62, G-121 containing gas hydrocarbon were not classified or improperly classified as Class 2, and not properly classified as Class 1. Piping Circuits GH-46-A10, GH-043-A10, containing gas hydrocarbon were not classified or improperly classified as Class 2 and not properly classified as Class 1. AOC 2 - 40 C.F.R. 68.69(c) Operating Procedures. "The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to stationary sources. The owner or operator shall certify annually that these operating procedures are current and accurate." Williams failed to certify its operating procedures annually. Williams certified its 2018 operating procedures on September 25, 2018, and its 2019 operating procedures on November 13, 2019, which is more than 30 days past due. EPA guidance provides a 30-day grace period from one certification to the next on a 365-day annual cycle. AOC 3 - 40 C.F.R. 68.73(b) Mechanical Integrity. "The owner or operator shall establish and implement written procedures to maintain the on-going integrity of process equipment." Williams failed to implement pre-inspection activities and field assessment activities of its Corrosion Under Insulation (CUI) and Corrosion Under Fireproofing (CUF) Inspection Guidelines dated April 1, 2020. Williams failed to develop and implement written procedures to maintain the ongoing integrity of the following piping: LH-21, LH-25, G-18, and G-19. Piping circuits LH-21 and LH-25 didn't have inspection plans developed until April 2018. Piping circuits G-18 and G-19 did not have an official inspection and test plan to maintain ongoing mechanical integrity until October 31, 2017. 3 Williams Partners Operating LLC Larose Cryogenic Plant Inspection Date: 08/18/2020 - 08/31/2020 AOC 4 - 40 C.F.R. 68.73(d)(2) Mechanical Integrity. "Inspection and testing procedures shall follow recognized and generally accepted good engineering practices." Williams failed to use the correct recognized and generally accepted good engineering design code in their Condition Monitoring Locations (CML) calculations for the inspection and analysis of the Slug Catcher (ZAX1000). Williams incorrectly used the American Society of Mechanical Engineers (ASME) process piping standard B31.3 instead of the ASME process piping standard B31.8. AOC 5 - 40 C.F.R. 68.73(d)(3) Mechanical Integrity. "The frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers' recommendations and good engineering practices, and more frequently if determined to be necessary by prior operating experience." Williams failed to conduct the proper frequency of internal inspections for five drums (MBF-105A 2nd Stage Suction Drum; MBF-108A 3rd Stage Suction Drum; MBF-513 2nd Stage Suction Drum; MBF-518 3rd Stage Suction Drum; and MBF-525 Solar Suction Scrubber). Williams set the due dates for a completion of the late internal inspections for all five drums to September 2020, with no previous internal inspection records. The delay of internal inspections was due to the nationwide pandemic. Williams failed to conduct the proper frequency of external inspections for one drum (MBF-525 Solar Suction Scrubber). Williams conducted an A-scan re-inspection on December 7, 2011, and based on the results of this inspection, the inspector set the next Ultrasonic Testing (UT) external and visual inspection for December 6, 2016. However, the next UT external and visual inspection was not conducted until July 27, 2018 (visual), and August 22, 2018 (UT), which was 19 and 20 months late, respectively. ZAX-1000: A-scan baseline inspection was conducted on June 7, 2007 with the next UT and external visual inspection set for January 29, 2012 and the remaining service life of the piping calculated at 9.30 years. The remaining life expired in 2016 based on the 2007 A-scan inspection. No inspection records were available for the 2012 inspection. UT and external inspections were conducted on January 26, 2016, and consequently were approximately 3.5 years late. The pipe was also still in operation, within 9 months of its service life retirement date, before any additional UT testing was performed. Williams failed to conduct for the flare knockout drum (ZZZ-182) UT inspections prior to July 31, 2020, internal or external inspections at any time, data analysis, short/long term corrosion rates, remaining life, and reinspection dates. AOC 6 - 40 C.F.R. 68.73(e) Mechanical Integrity. "The owner or operator shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in 68.65) before further use or in a safe and timely manner when necessary means are taken to assure safe operation." Williams failed to correct deficiencies as identified in a Flare Study conducted on October 27, 2013 that identified 109 recommendations. At the time of this inspection, nine recommendations/modifications 4 Williams Partners Operating LLC Larose Cryogenic Plant Inspection Date: 08/18/2020 - 08/31/2020 were still remaining. Williams reported that on October 9, 2020, all 109 recommendations had been completed with appropriate Management of Change documentation, and that the delay was due to the national pandemic and Louisiana hurricanes. AOC 7 - 40 C.F.R. 68.75(d) Management of Change. "If a change covered by this paragraph results in a change in the process safety information required by 68.65 of this part, such information shall be updated accordingly." Williams failed to perform a Management of Change for the process change and re-rate of unit MBD-101 to address the installation of a Temperature Alarm High-High (TAHH) to the Condensate System Temperature Controller TIC 106-1 which required a change in the process safety information. AOC 8 - 40 C.F.R. 68.79(d) Compliance Audits. "The owner or operator shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected." Williams failed to promptly document that finding #7 of 14 had been corrected from its January 2019 Compliance Audit regarding the implementation of a piping Corrosion Under Insulation (CUI) program. Williams noted that this finding was completed on November 13, 2019, which was 48 days prior to the projected due date of December 31, 2019, and CUI program implementation is currently pending. Section IV - FOLLOW UP None. Section V - LIST OF APPENDICES Appendix 1 - Checklist - Inspection Symbol Key: Y - Yes, N - No, N/A - Not Applicable, S - Satisfactory, M - Marginal, U - Unsatisfactory. 5 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 Section A - Management [68.15] Management system developed and implemented as provided in 40 CFR 68.15? N/A Comments: S M Has the owner or operator: 1. Developed a management system to oversee the implementation of the risk management program elements? Y [68.15(a)] 2. Assigned a qualified person or position that has the overall responsibility for the development, implementation, and Y integration of the risk management program elements? [68.15(b)] 3. Documented other persons responsible for implementing individual requirements of the risk management program Y and defined the lines of authority through an organization chart or similar document? [68.15(c)] Section B: Hazard Assessment [68.20-68.42] Hazard assessment conducted and documented as provided in 40 CFR 68.20-68.42? N/A Comments: S M Hazard Assessment: Offsite consequence analysis parameters [68.22] 1. Used the following endpoints for offsite consequence analysis for a worst-case scenario: [68.22(a)] Y For toxics: the endpoints provided in Appendix A of 40 CFR Part 68? [68.22(a)(1)] For flammables: an explosion resulting in an overpressure of 1 psi? [68.22(a)(2)(i)]; or For flammables: a fire resulting in a radiant heat/exposure of 5 kw/m2 for 40 seconds? [68.22(a)(2)(ii)] For flammables: a concentration resulting in a lower flammability limit, as provided in NFPA documents or other generally recognized sources? [68.22(a)(2)(iii)] 2. Used the following endpoints for offsite consequence analysis for an alternative release scenario: [68.22(a)] Y For toxics: the endpoints provided in Appendix A of 40 CFR Part 68? [68.22(a)(1)] For flammables: an explosion resulting in an overpressure of 1 psi? [68.22(a)(2)(i)] For flammables: a fire resulting in a radiant heat/exposure of 5 kw/m2 for 40 seconds? [68.22(a)(2)(ii)] For flammables: a concentration resulting in a lower flammability limit, as provided in NFPA documents or other generally recognized sources? [68.22(a)(2)(iii)] 3. Used appropriate wind speeds and stability classes for the release analysis? [68.22(b)] Y 4. Used appropriate ambient temperature and humidity values for the release analysis? [68.22(c)] Y 5. Used appropriate values for the height of the release for the release analysis? [68.22(d)] Y 6. Used appropriate surface roughness values for the release analysis? [68.22(e)] Y 7. Do tables and models, used for dispersion analysis of toxic substances, appropriately account for dense or neutrally Y buoyant gases? [68.22(f)] 8. Were liquids, other than gases liquefied by refrigeration only, considered to be released at the highest daily Y maximum temperature, based on data for the previous three years appropriate for a stationary source, or at process temperature, whichever is higher? [68.22(g)] U N N/A N N/A N N/A U N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A Page 1 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 Hazard Assessment: Worst-case release scenario analysis [68.25] 9. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an endpoint resulting from an accidental release of a regulated toxic substance from covered processes under worstcase conditions? [68.25(a)(2)(i)] 10. Analyzed and reported in the RMP one worst-case release scenario estimated to create the greatest distance to an endpoint resulting from an accidental release of a regulated flammable substance from covered processes under worst-case conditions? [68.25(a)(2)(ii)] 11. Analyzed and reported in the RMP additional worst-case release scenarios for a hazard class if the worst-case release from another covered process at the stationary source potentially affects public receptors different from those potentially affected by the worst-case release scenario developed under 68.25(a)(2)(i) or 68.25(a)(2)(ii)? [68.25(a)(2)(iii)] 12. Has the owner or operator determined the worst-case release quantity to be the greater of the following: [68.25(b)] Y N N/A Y N N/A Y N N/A Y N N/A If released from a vessel, the greatest amount held in a single vessel, taking into account administrative controls that limit the maximum quantity? [68.25(b)(1)] If released from a pipe, the greatest amount held in the pipe, taking into account administrative controls that limit the maximum quantity? [68.25(b)(2)] 13.a. Has the owner or operator for toxic substances that are normally gases at ambient temperature and handled as a gas or liquid under pressure: 13.a.(1) Assumed the whole quantity in the vessel or pipe would be released as a gas over 10 minutes? [68.25(c)(1)] Y N N/A 13.a.(2) Assumed the release rate to be the total quantity divided by 10, if there are no passive mitigation systems in place? [68.25(c)(1)] Y N N/A 13.b. Has the owner or operator for toxic gases handled as refrigerated liquids at ambient pressure: 13.b.(1) Assumed the substance would be released as a gas in 10 minutes, if not contained by passive mitigation systems Y N N/A or if the contained pool would have a depth of 1 cm or less? [68.25(c)(2)(i)] 13.b.(2) If released substance would be contained by passive mitigation systems in a pool with a depth > 1 cm; Assumed the quantity in the vessel or pipe (as determined per 68.25(b)) would be spilled instantaneously to form a liquid pool? [68.25(c)(2)(ii)] Calculated the volatility rate at the boiling point of the substance and at the conditions specified in 68.25(d)? [68.25(c)(2)(ii)] Y N N/A 13.c. Has the owner or operator for toxic substances that are normally liquids at ambient temperature: 13.c.(1) Assumed the quantity in the vessel or pipe would be spilled instantaneously to form a liquid pool? [68.25(d)(1)] Y N N/A 13.c.(2) Determined the surface area of the pool by assuming that the liquid spreads to 1 cm deep, if there is no passive mitigation system in place that would serve to contain the spill and limit the surface area, or if passive mitigation is in place, was the surface area of the contained liquid used to calculate the volatilization rate? [68.25(d)(1)(i)] 13.c.(3) Taken into account the actual surface characteristics, if the release would occur onto a surface that is not paved or smooth? [68.25(d)(1)(ii)] Y N N/A Y N N/A Page 2 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 13.c.(4) Determined the volatilization rate by accounting for the highest daily maximum temperature in the past three years, the temperature of the substance in the vessel, and the concentration of the substance if the liquid spilled is a mixture or solution? [68.25(d)(2)] Y N N/A 13.c.(5) Determined the rate of release to air from the volatilization rate of the liquid pool? [68.25(d)(3)] Y N N/A 13.c.(6) Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.25(d)(3)] What modeling technique did the owner or operator use? [68.25(g)] Choose an item. Y N N/A 13.d. Has the owner or operator for flammables: 13.d.(1) Assumed the quantity in a vessel(s) of flammable gas held as a gas or liquid under pressure or refrigerated gas released to an undiked area vaporizes resulting in a vapor cloud explosion? [68.25(e)] Y N N/A 13.d.(2) For refrigerated gas released to a contained area or liquids released below their atmospheric boiling point, assumed the quantity volatilized in 10 minutes results in a vapor cloud? [68.25(f)] Y N N/A 13.d.(3) Assumed a yield factor of 10% of the available energy is released in the explosion for determining the distance to the explosion endpoint, if the model used is based on TNT-equivalent methods? [68.25(e)] Y N N/A 14. Used the parameters defined in 68.22 to determine distance to the endpoints? [68.25(g)] Y N N/A 15. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, Y N N/A any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.25(g)] What modeling technique did the owner or operator use? [68.25(g)] RMP*Comp 16. Ensured that the passive mitigation system, if considered, is capable of withstanding the release event triggering the scenario and will still function as intended? [68.25(h)] Y N N/A 17. Considered also the following factors in selecting the worst-case release scenarios: [68.25(i)] Smaller quantities handled at higher process temperature or pressure? [68.25(i)(1)] Proximity to the boundary of the stationary source? [68.25(i)(2)] Y N N/A Hazard Assessment: Alternative release scenario analysis [68.28] 18. Identified and analyzed at least one alternative release scenario for each regulated toxic substance held in a covered process(es) and at least one alternative release scenario to represent all flammable substances held in covered processes? [68.28(a)] Y N N/A 19. Selected a scenario: [68.28(b)] That is more likely to occur than the worst-case release scenario under 68.25? [68.28(b)(1)(i)] That will reach an endpoint off-site, unless no such scenario exists? [68.28(b)(1)(ii)] Y N N/A Page 3 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 20. Considered release scenarios which included, but are not limited to, the following: [68.28(b)(2)] Transfer hose releases due to splits or sudden hose uncoupling? [68.28(b)(2)(i)] Process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds? [68.28(b)(2)(ii)] Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure? [68.28(b)(2)(iii)] Y N N/A Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture disks? [68.28(b)(2)(iv)] Shipping container mishandling and breakage or puncturing leading to a spill? [68.28(b)(2)(v)] 21. Used the parameters defined in 68.22 to determine distance to the endpoints? [68.28(c)] Y N N/A 22. Determined the rate of release to air by using the methodology in the RMP Offsite Consequence Analysis Guidance, Y N N/A any other publicly available techniques that account for the modeling conditions and are recognized by industry as applicable as part of current practices, or proprietary models that account for the modeling conditions may be used provided the owner or operator allows the implementing agency access to the model and describes model features and differences from publicly available models to local emergency planners upon request? [68.28(c)] What modeling technique did the owner or operator use? [68.25(g)] RMP*Comp 23. Ensured that the passive and active mitigation systems, if considered, are capable of withstanding the release event triggering the scenario and will be functional? [68.28(d)] Y N N/A 24. Considered the following factors in selecting the alternative release scenarios: [68.28(e)] The five-year accident history provided in 68.42? [68.28(e)(1)] Failure scenarios identified under 68.50? [68.28(e)(2)] Y N N/A Hazard Assessment: Defining off-site impacts-Population [68.30] 25. Estimated population that would be included in the distance to the endpoint in the RMP based on a circle with the point of release at the center? [68.30(a)] Y N N/A 26. Identified the presence of institutions, parks and recreational areas, major commercial, office, and industrial buildings in the RMP? [68.30(b)] Y N N/A 27. Used most recent Census data, or other updated information to estimate the population? [68.30(c)] Y N N/A 28. Estimated the population to two significant digits? [68.30(d)] Y N N/A Hazard Assessment: Defining off-site impacts-Environment [68.33] 29. Identified environmental receptors that would be included in the distance to the endpoint based on a circle with the point of release at the center? [68.33(a)] Y N N/A 30. Relied on information provided on local U.S.G.S. maps, or on any data source containing U.S.G.S. data to identify environmental receptors? [Source may have used LandView to obtain information] [68.33(b)] Y N N/A Hazard Assessment: Review and update [68.36] 31. Reviewed and updated the off-site consequence analyses at least once every five years? [68.36(a)] Y N N/A 32. Completed a revised analysis and submit a revised RMP within six months of a change in processes, quantities stored or handled, or any other aspect that might reasonably be expected to increase or decrease the distance to the endpoint by a factor of two or more? [68.36(b)] Y N N/A Page 4 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 Hazard Assessment: Documentation [68.39] 33. For worst-case scenarios: a description of the vessel or pipeline and substance selected, assumptions and parameters Y used, the rationale for selection, and anticipated effect of the administrative controls and passive mitigation on the release quantity and rate? [68.39(a)] 34. For alternative release scenarios: a description of the scenarios identified, assumptions and parameters used, the Y rationale for the selection of specific scenarios, and anticipated effect of the administrative controls and mitigation on the release quantity and rate? [68.39(b)] 35. Documentation of estimated quantity released, release rate, and duration of release? [68.39(c)] Y 36. Methodology used to determine distance to endpoints? [68.39(d)] Y 37. Data used to estimate population and environmental receptors potentially affected? [68.39(e)] Y Hazard Assessment: Five-year accident history [68.42] 38. Has the owner or operator included all accidental releases from covered processes that resulted in deaths, injuries, or Y significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage? [68.42(a)] None reported. 39. Has the owner or operator reported the following information for each accidental release: [68.42(b)] Y Date, time, and approximate duration of the release? [68.42(b)(1)] Chemical(s) released? [68.42(b)(2)] Estimated quantity released in pounds and percentage weight in a mixture (toxics)? [68.42(b)(3)] NAICS code for the process? [68.42(b)(4)] The type of release event and its source? [68.42(b)(5)] Weather conditions (if known)? [68.42(b)(6)] On-site impacts? [68.42(b)(7)] Known offsite impacts? [68.42(b)(8)] Initiating event and contributing factors (if known)? [68.42(b)(9)] Whether offsite responders were notified (if known)? [68.42(b)(10)] Operational or process changes that resulted from investigation of the release? [68.42(b)(11)] Section C: Prevention Program Implemented the Program 3 prevention requirements as provided in 40 CFR 68.65 - 68.87? N/A S M N N/A N N/A N N/A N N/A N N/A N N/A N N/A U Page 5 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 Prevention Program- Safety information [68.65] 1. Has the owner or operator compiled written process safety information, which includes information pertaining to the Y N N/A hazards of the regulated substances used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process, before conducting any process hazard analysis required by the rule? [68.65(a)] Does the process safety information contain the following for hazards of the substances: [68.65(b)] Material Safety Data Sheets (MSDS) that meet the requirements of the OSHA Hazard Communication Standard [29 CFR 1910.1200(g)]? [68.48(a)(1)] Toxicity information? [68.65(b)(1)] Permissible exposure limits? [68.65(b)(2)] Physical data? [68.65(b)(3)] Reactivity data? [68.65(b)(4)] Corrosivity data? [68.65(b)(5)] Thermal and chemical stability data? [68.65(b)(6)] Hazardous effects of inadvertent mixing of materials that could foreseeably occur? [68.65(b)(7)] 2. Has the owner documented information pertaining to technology of the process? Y N N/A A block flow diagram or simplified process flow diagram? [68.65(c)(1)(i)] Process chemistry? [68.65(c)(1)(ii)] Maximum intended inventory? [68.65(c)(1)(iii)] Safe upper and lower limits for such items as temperatures, pressures, flows, or compositions? [68.65(c)(1)(iv)] An evaluation of the consequences of deviation? [68.65(c)(1)(iv)] 3. Does the process safety information contain the following for the equipment in the process: [68.65(d)(1)] Materials of construction? 68.65(d)(1)(i)] Piping and instrumentation diagrams [68.65(d)(1)(ii)] Electrical classification? [68.65(d)(1)(iii)] Relief system design and design basis? [68.65(d)(1)(iv)] Ventilation system design? [68.65(d)(1)(v)] Design codes and standards employed? [68.65(d)(1)(vi)] Material and energy balances for processes built after June 21, 1999? [68.65(d)(1)(vii)] Safety systems? [68.65(d)(1)(viii)] 4. Has the owner or operator documented that equipment complies with recognized and generally accepted good engineering practices? [68.65(d)(2)] 5. Has the owner or operator determined and documented that existing equipment, designed and constructed in accordance with codes, standards, or practices that are no longer in general use, is designed, maintained, inspected, tested, and operating in a safe manner? [68.65(d)(3)] Prevention Program- Process Hazard Analysis [68.67] 6. Has the owner or operator performed an initial process hazard analysis (PHA), and has this analysis identified, evaluated, and controlled the hazards involved in the process? [68.67(a)] Y N N/A Y N N/A Y N N/A Y N N/A Page 6 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 7. Has the owner or operator determined and documented the priority order for conducting PHAs, and was it based on an appropriate rationale? [68.67(a)] Y N N/A 8. Has the owner used one or more of the following technologies to conduct process PHA: [68.67(b)] What-if? [68.67(b)(1)] Checklist? [68.67(b)(2)] What-if/Checklist? [68.67(b)(3)] Hazard and Operability Study (HAZOP) [68.67(b)(4)] Failure Mode and Effects Analysis (FMEA) [68.67(b)(5)] Fault Tree Analysis? [68.67(b)(6)] An appropriate equivalent methodology? [68.67(b)(7)] Y N N/A 9. Did the PHA address: The hazards of the process? [68.67(c)(1)] Identification of any incident that had a likely potential for catastrophic consequences? [68.67(c)(2)] Engineering and administrative controls applicable to hazards and interrelationships?[68.67(c)(3)] Consequences of failure of engineering and administrative controls? [68.67(c)(4)] Stationary source siting? [68.67(c)(5)] Human factors? [68.67(c)(6)] An evaluation of a range of the possible safety and health effects of failure of controls? [68.67(c)(7)] Y N N/A 10. Was the PHA performed by a team with expertise in engineering and process operations and did the team include appropriate personnel? [68.67(d)] Y N N/A 11. Has the owner or operator established a system to promptly address the team's findings and recommendations; Y N N/A assured that the recommendations are resolved in a timely manner and documented; documented what actions are to be taken; completed actions as soon as possible; developed a written schedule of when these actions are to be completed; and communicated the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations? [68.67(e)] 12. Has the PHA been updated and revalidated by a team every five years after the completion of the initial PHA to assure that the PHA is consistent with the current process? [68.67(f)] Y N N/A 13. Has the owner or operator retained PHAs and updates or revalidations for each process covered, as well as the resolution of recommendations for the life of the process? [68.67(g)] Y N N/A Prevention Program- Operating procedures [68.69] 14. Has the owner or operator developed and implemented written operating procedures that provide instructions or steps for conducting activities associated with each covered process consistent with the safety information? [68.69(a)] Y N N/A Page 7 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 15 Do the procedures address the following: [68.69(a)] Steps for each operating phase: [68.69(a)(1)] Initial Startup? [68.69(a)(1)(i)] Normal operations? [68.69(a)(1)(ii)] Temporary operations? [68.69((a)(1)(iii)] Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner? [68.69(a)(1)(iv)] Emergency operations? [68.69(a)(1)(v)] Normal shutdown? [68.68(a)(1)(vi)] Startup following a turnaround, or after emergency shutdown? [68.69(a)(1)(vii)] Operating limits: [68.69(a)(2)] Consequences of deviations [68.69(a)(2)(i)] Steps required to correct or avoid deviation? [68.69(a)(2)(ii)] Safety and health considerations: [68.69(a)(3)] Properties of, and physical hazards presented by, the chemicals used in the process [68.69(a)(3)(i)] Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment? [68.69(a)(3)(ii)] Control measures to be taken if physical contact or airborne exposure occurs? [68.69(a)(3)(iii)] Quality control for raw materials and control of hazardous chemical inventory levels? [68.69(a)(3)(iv)] Y N N/A Any special or unique hazards? [68.69(a)(3)(v)] Safety systems and their functions? [68.69(a)(4)] 16. Are operating procedures readily accessible to employees who are involved in a process? [68.69(b)] 17. Has the owner or operator certified annually that the operating procedures are current and accurate and that procedures have been reviewed as often as necessary? [68.69(c)] 18. Has the owner or operator developed and implemented safe work practices to provide for the control of hazards during specific operations, such as lockout/tagout? [68.69(d)] Prevention Program - Training [68.71] 19 Has each employee involved in operating a process, and each employee before being involved in operating a newly assigned process, been initially trained in an overview of the process and in the operating procedures? [68.71(a)(1)] Y N N/A Y N N/A Y N N/A Y N N/A 20. Did initial training include emphasis on safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks? [68.71(a)(1)] Y N N/A 21. In lieu of initial training for those employees already involved in operating a process on June 21, 1999, an owner or Y N N/A operator may certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures [68.71(a)(2)] 22. Has refresher training been provided at least every three years, or more often if necessary, to each employee involved in operating a process to assure that the employee understands and adheres to the current operating procedures of the process? [68.71(b)] Y N N/A Page 8 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 23, Has owner or operator ascertained and documented in record that each employee involved in operating a process has Y N N/A received and understood the training required? [68.71(c)] 24. Does the prepared record contain the identity of the employee, the date of the training, and the means used to verify that the employee understood the training? [68.71(c)] Y N N/A Prevention Program - Mechanical Integrity [68.73] 25. Has the owner or operator established and implemented written procedures to maintain the on-going integrity of the process equipment listed in 68.73(a)? [68.73(b)] Y N N/A 26. Has the owner or operator trained each employee involved in maintaining the on-going integrity of process equipment? [68.73(c)] Y N N/A 27. Performed inspections and tests on process equipment? [68.73(d)(1)] Y N N/A 28. Followed recognized and generally accepted good engineering practices for inspections and testing procedures? [68.73(d)(2)] Y N N/A 29. Ensured the frequency of inspections and tests of process equipment is consistent with applicable manufacturers' recommendations, good engineering practices, and prior operating experience? [68.73(d)(3)] Y N N/A 30. Documented each inspection and test that had been performed on process equipment, which identifies the date of the Y N N/A inspection or test, the name of the person who performed the inspection or test, the serial number or other identifier of the equipment on which the inspection or test was performed, a description of the inspection or test performed, and the results of the inspection or test? [68.73(d)(4)] 31. Corrected deficiencies in equipment that were outside acceptable limits defined by the process safety information before further use or in a safe and timely manner when necessary means were taken to assure safe operation? [68.73(e)] Y N N/A 32. Assured that equipment as it was fabricated is suitable for the process application for which it will be used in the construction of new plants and equipment? [68.73(f)(1)] Y N N/A 33. Performed appropriate checks and inspections to assure that equipment was installed properly and consistent with design specifications and the manufacturer's instructions? [68.73(f)(2)] Y N N/A 34. Assured that maintenance materials, spare parts and equipment were suitable for the process application for which they would be used? [68.73(f)(3)] Y N N/A Prevention Program - Management Of Change [68.75] 35. Has the owner or operator established and implemented written procedures to manage changes to process chemicals, Y N N/A technology, equipment, and procedures, and changes to stationary sources that affect a covered process? [68.75(a)] 36. Do procedures assure that the following considerations are addressed prior to any change: [68.75(b)] The technical basis for the proposed change? [68.75(b)(1)] Impact of change on safety and health? [68.75(b)(2)] Modifications to operating procedures? [68.75(b)(3)] Necessary time period for the change? [68.75(b)(4)] Authorization requirements for the proposed change? [68.75(b)(5)] 37. Were employees, involved in operating a process and maintenance, and contract employees, whose job tasks would be affected by a change in the process, informed of, and trained in, the change prior to start-up of the process or affected parts of the process? [68.75(c)] Y N N/A Y N N/A Page 9 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 38. If a change resulted in a change in the process safety information, was such information updated accordingly? [68.75(d)] 39. If a change resulted in a change in the operating procedures or practices, had such procedures or practices been updated accordingly? [68.75(e)] Prevention Program - Pre-startup Safety Review [68.77] 40. If the facility installed a new stationary source, or significantly modified an existing source, (as discussed at 68.77(a)) did it perform a pre-startup safety review prior to the introduction of a regulated substance to a process to confirm: [68.77(b)] Construction and equipment was in accordance with design specifications? [68.77(b)(1)] Safety, operating, maintenance, and emergency procedures were in place and were adequate? [68.77(b)(2)] Y N N/A Y N N/A Y N N/A For new stationary sources, a process hazard analysis had been performed and recommendations had been resolved or implemented before startup? [68.77(b)(3)] Modified stationary sources meet the requirements contained in management of change? [68.77(b)(3)] Training of each employee involved in operating a process had been completed? [68.77(b)(4)] Prevention Program - Compliance audits [68.79] 41. Has the owner or operator certified that the stationary source has evaluated compliance with the provisions of the prevention program at least every three years to verify that the developed procedures and practices are adequate and being followed? [68.79(a)] Y N N/A 42. Has the audit been conducted by at least one person knowledgeable in the process? [68.79(b)] Y N N/A 43. Are the audit findings documented in a report? [68.79(c)] Y N N/A 44. Has the owner or operator promptly determined and documented an appropriate response to each of the findings of the audit and documented that deficiencies had been corrected? [68.79(d)] Y N N/A 45. Has the owner or operator retained the two most recent compliance reports? [68.79(e)] Y N N/A Prevention Program - Incident investigation [68.81] 46. Has the owner or operator investigated each incident that resulted in, or could reasonably have resulted in a catastrophic release of a regulated substance? [68.81(a)] Y N N/A 47. Were all incident investigations initiated not later than 48 hours following the incident? [68.81(b)] Y N N/A 48. Was an accident investigation team established and did it consist of at least one person knowledgeable in the process Y N N/A involved, including a contract employee if the incident involved work of a contractor, and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident? [68.81(c)] 49. Was a report prepared at the conclusion of every investigation? [68.81(d)] Y N N/A 50. Does every report include: [68.81(d)] Date of incident? [68.81(d)(1)] Date investigation began? [68.81(d)(2)] A description of the incident? [68.81(d)(3)] The factors that contributed to the incident? [68.81(d)(4)] Any recommendations resulting from the investigation? [68.81(d)(5)] Y N N/A Page 10 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 51. Has the owner or operator established a system to address and resolve the report findings and recommendations, and Y are the resolutions and corrective actions documented? [68.81(e)] 52. Was the report reviewed with all affected personnel whose job tasks are relevant to the incident findings including Y contract employees where applicable? [68.81(f)] 53. Has the owner or operator retained incident investigation reports for at least five years? [68.81(g)] Y Section D - Employee Participation [68.83] 1. Has the owner or operator developed a written plan of action regarding the implementation of the employee Y participation required by this section? [68.83(a)] 2. Has the owner or operator consulted with employees and their representatives on the conduct and development of Y process hazards analyses and on the development of the other elements of process safety management in chemical accident prevention provisions? [68.83(b)] 3. Has the owner or operator provided to employees and their representatives access to process hazards analyses and to Y all other information required to be developed under the chemical accident prevention rule? [68.83(c)] Section E - Hot Work Permit [68.85] 1. Has the owner or operator issued a hot work permit for each hot work operation conducted on or near a covered Y process? [68.85(a)] 2. Does the permit document that the fire prevention and protection requirements in 29CFR 1910.252(a) have been Y implemented prior to beginning the hot work operations? [68.85(b)] 3. Does the permit indicate the date(s) authorized for hot work and the object(s) upon which hot work is to be Y performed? [68.85(b] 4. Are the permits being kept on file until completion of the hot work operations? [68.85(b)] Y Section F - Contractors [68.87] 1. Has the owner or operator obtained and evaluated information regarding the contract owner or operator's safety Y performance and programs when selecting a contractor? [68.87(b)(1)] 2. Informed contract owner or operator of the known potential fire, explosion, or toxic release hazards related to the Y contractor's work and the process? [68.87(b)(2)] 3. Explained to the contract owner or operator the applicable provisions of the emergency response or the emergency Y action program? [68.87(b)(3)] 4. Developed and implemented safe work practices consistent with 68.69(d), to control the entrance, presence, and Y exit of the contract owner or operator and contract employees in the covered process areas? [68.87(b)(4)] 5. Periodically evaluated the performance of the contract owner or operator in fulfilling their obligations (as described Y at 68.87(c)(1) - (c)(5))? [68.87(b)(5)] Section G - Emergency Response [68.90 - 68.95] Developed and implemented an emergency response program as provided in 40 CFR 68.90-68.95? N/A Comments: S M 1. Is the facility designated as a "first responder" in case of an accidental release of regulated substances" Y 1.a. If the facility is not a first responder: N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A N N/A U N N/A Page 11 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 1.a.(1) For stationary sources with any regulated substances held in a process above threshold quantities, is the source included in the community emergency response plan developed under 42 U.S.C. 11003? [68.90(b)(1)] 1.a.(2) For stationary sources with only regulated flammable substances held in a process above threshold quantities, has the owner or operator coordinated response actions with the local fire department? [68.90(b)(2)] 1.a.(3) Are appropriate mechanisms in place to notify emergency responders when there is need for a response? [68.90(b)(3)] 2. An emergency response plan is maintained at the stationary source and contains the following? [68.95(a)(1)] Procedures for informing the public and local emergency response agencies about accidental releases? [68.95(a)(1)(i)] Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures? [68.95(a)(1)(ii)] Procedures and measures for emergency response after an accidental release of a regulated substance? [68.95(a)(1)(iii)] 3. The emergency response plan contains procedures for the use of emergency response equipment and for its inspection, testing, and maintenance? [68.95(a)(2)] 4. The emergency response plan requires, and there is documentation of, training for all employees in relevant procedures? [68.95(a)(3)] 5. The owner or operator has developed and implemented procedures to review and update, as appropriate, the emergency response plan to reflect changes at the stationary source and ensure that employees are informed of changes? [68.95(a)(4)] 6. Did the owner or operator use a written plan that complies with other Federal contingency plan regulations or is consistent with the approach in the National Response Team's Integrated Contingency Plan Guidance (``One Plan'')? If so, does the plan include the elements provided in paragraph (a) of 68.95, and also complies with paragraph (c) of 68.95? [68.95(b)] 7. Has the emergency response plan been coordinated with the community emergency response plan developed under EPCRA? [68.95(c)] Section H - Risk Management Plan [40 CFR 68.190 - 68.195] 1. Does the single registration form include, for each covered process, the name and CAS number of each regulated substance held above the threshold quantity in the process, the maximum quantity of each regulated substance or mixture in the process (in pounds) to two significant digits, the five- or six-digit NAICS code that most closely corresponds to the process and the Program level of the process? [68.160(b)(7)] 2. Did the facility assign the correct program level(s) to its covered process(es)? [68.160(b)(7)] Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Y N N/A Page 12 of 13 Rev 01/31/2011 RMP Program Level 3 Process Checklist Facility Name: Larose Cryogenic Plant September 2020 3. Has the owner or operator reviewed and updated the RMP and submitted it to EPA [68.190(a)]? Reason for update: Y N N/A Five-year update. [68.190(b)(1)] Within three years of a newly regulated substance listing. [68.190(b)(2)] At the time a new regulated substance is first present in an already regulated process above threshold quantities. [68.190(b)(3)] At the time a regulated substance is first present in an new process above threshold quantities. [68.190(b)(4)] Within six months of a change requiring revised PHA or hazard review. [68.190(b)(5)] Within six months of a change requiring a revised OCA as provided in 68.36. [68.190(b)(6)] Within six months of a change that alters the Program level that applies to any covered process. [68.190(b)(7)] 4. If the owner or operator experienced an accidental release that met the five-year accident history reporting criteria (as described at 68.42) subsequent to April 9, 2004, did the owner or operator submit the information required at 68.168, 68.170(j) and 68.175(l) within six months of the release or by the time the RMP was updated as required at 68.190, whichever was earlier. [68.195(a)] 5. If the emergency contact information required at 68.160(b)(6) has changed since June 21, 2004, did the owner or operator submit corrected information within thirty days of the change? [68.195(b)] Y N N/A Y N N/A Page 13 of 13 Rev 01/31/2011