Document JNbaxZrme3EmBNrOK5x8p7XnO

0"EPA;u.n_i'~.omdonSlt.lJl,.l.'nl:.c:lioo Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) Company Name: Facility Name: Facility Physical Location : August 20-23, 2018 Air Clean Air Act Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions Chevron Phillips Chemical Company LP Pasadena Plastics Complex 1400 Jefferson Rd (city, state, zip code) Pasadena, TX 77506 Mailing address: (city, state, zig code) County/Parish: Facility Contact: 1400 Jefferson Rd Pasadena , TX 77506 Harris Gary Piana- (713)475-3666 I Plant Manager -- FRS Number: Identification/Permit Number: Media Number : NAICS: SIC: 110000462730 EPA Facility Identifier: 100000126375 325211 Plastics Material and Resin Manufacturing 2869 Plastics Material and Resin Personnel participating in inspection: Gary Pia na Chevron Ph illips Chem ical Jeff Nicki Chevron Phillips Chemical Paula Wiley Chevron Phillips Chemical James Allred Chevron Phillips Chemical Michael Dykhouse Chevron Phillips Chemical Pam Colon Chevron Phillips Chemical Joe Reynolds Chevron Phillips Chemica l Blake Sieminski US EPA Area Manager EHS&S PSM Supervisor Asset Integrity Manager Operations Manager Training Supt. Emergency Response/Security Coordinator Inspector/ Enforcement Off. (713)475-3666 (713)475-3666 (713)475-3666 (713)475-3666 (713)475-3666 (713 )47 5-3 6 6 6 (713)475-3666 (214)665-8062 EPA Lead Inspector Signature/Date EPA Lead Inspector Signature/Date Supervisor Signature/Date Blak/ Sieminski J);tt_ ~ ------ - Supervisor Signatu re/ Date Samuel Tates ~/)~ Date I or /!1-J/bt/1 Date /Of Jo./2.oJf} GENFORM-019-RG (10/6/14) 1 Chevron Phillips. I Pasadena Plastics Complex Inspect ion Date 8/ 20-23/ 2018 Section I - INTRODUCTION PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector Blake Sieminski arrived at the Pasadena Plastics Complex at approximately 2:00 .PM on Monday August 20, 2018 for an announced inspection. I met with Jeff Nicki, Paula Wiley, and Gary Piana and multiple Chevron Phillips Company (CPC) employees. I presented my credentials and informed them that this was an EPA inspection to determine compliance w ith the facility's Chemical Accident Prevention Provisions program. The scope of the inspection is a partial compliance evaluation (PCE) and included evaluation of the compliance of t he facility with the Clean Air Act (CAA) Section 112(r) and the Chemical Accident Prevention Provisions (40 C.F.R. Part 68). The Pasadena Plastics Complex (PPC) is listed as a Risk Management Plan (RMP) Program three {3) facility. The Pasadena Plastics Complex is a union facility. The Texas Co.m;.;..;.;m..;.;.i;..s:..s;:..i:.o:..:.n...:..o-=..n.;.;.._ _ __ _ _ _ __ Environmental Quality was notified of this PCE inspection. Gary Piana Cathy Gill Jeff Nicki Mark A. Garza Joe Reynolds Lisa Moseley Trey Griffin Paula Wiley Krista Boone Craig Peikert James Allred Cory Miller Michelle Gates Paul Waite Jason Wright . Vasser Qutub Trish Badall Michael Dykhouse Anthony N. Jackson Chad Thomas Manzoor Khan Chris Hunt Travis Hensley Blake Sieminski Table 1: Opening Meeting Attendance; Monday August 20, 2018 Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemica l Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemica l Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemica l Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Plant Manager EH&S/ Tech Manager EHS&S Superintendent Environmental Supervisor Emergency Response/Security Coordinator Procurement Manager QA Superintendent PSM Supervisor Projects and Engineering Team Lead I.T. Manager Asset Integrity Manager Safety Supervisor Fi nance Manager P&S SOPT. Reliability Lead Process and Controls lead Fixed Equipment lead Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phi llips Chemica l Chevron Phillips Chemical U.S. EPA Operations Manager Maintenance Manager PEG OPS Supt. PES OPS Su pt. IEC Superintendent PE7 OPS Supt. Inspector/ Enforcement Off. 2 Chevron Phillips. I Pasadena Plastics Complex Inspection Date 8/20-23/20 18 FACILITY DESCRIPTION Chevron Phillips ChemicallP operates a plastics material and resin manufacturing facility. The facility is located in Pasadena, Texas. PPC is a facility which receives and/or stores various regulated flammable chemicals by trucks, and pipelines. The products onsite include propane, isobutane (propane, 2methyl), and ethylene (ethene). The facilit y employs approximately 340 employees and 75 contractors. Section II- OBSERVATIONS On Wednesday August 22, 2018, Jeff Nicki, Michael Dykhouse and I conducted a site drive-through of the facility to observe the covered process, equipment and operations. The facility has three (3) Polyethylene Plants known as PE6, PE7 and PES. We toured worst case scenario reactor 8-1 which is a reactor in PES due to proximity to the neighboring Calpine steam plant and walked t hrough the control room of PE7 and saw hydrocarbon unloading. 40 C.F.R. Part 68- CHEMICAL ACCIDENT PREVENTION PROVISION Subpart A- General 40 C.F.R. 68.10 Applicability -I observed that PPC is a stationary source, with a CAA Title-V permit (ID 0 -01315) that has more than a threshold quantity of regulated substances in their process. PPC resubmitted a RM P (5-year update 40 CFR 68.190 (b)(1)) on May 31, 2018, that described the process containing flam mables held at more than a threshold quantity. PPC is a RMP Program 3 facility. PPC is subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119). 40 C.F.R. 68.12 General requirements- I reviewed there-submission of PPC's RMP that was resubmitted on May 31, 2018, that lists flammable chemicals for a Program level 3 process. 40 C.F.R. 68.15 Management- PPC developed a management system to oversee t he implementatio n of the risk management program elements. The organizational chart that was provided to me outlined the positions to implement the individual elements of the RMP as required by this subpart. Subpart B- Hazard Assessment- 40 C.F.R. 68.20 Applicability- PPC is a Program 3 stationary source subject to this part. The facility is required to prepare an offsite consequence analysis and complete the five-year accident history. 40 C.F.R. 68.22 Offsite consequence analysis parameters- I reviewed the offsite consequence analysis and supporting documentation. I reviewed the documents and discussed with Paula Wiley to assure the data was accurate and t o confirm the parameters used by PPC to document this data. 40 C.F.R. 68.25 Worst-case release scenario analysis- PPC ident ified and documented a worse-case release scenario analysis for the RMP covered flammable substances. The distance to endpoint for f lammable substances was calculated using RMP*Comp'M. 3 Chevron Phillips. I Pasadena Plastics Co mplex Inspection Date 8/20-23/2018 40 C.F.R. 68.28 Alternative release scenario analysis- PPC identified and analyzed at least one alternative release scenario for each regulated flammable substance as well as at least one alternat ive release scenario to represent all flammable substances held in covered processes. The distance to endpoint was calculated using RMP*Comp'M. 40 C.F.R. 68.30 Defining offsite impacts-population -I talked with PPC about the offsite consequence analysis done. PPC used the year 2010 Census Bureau population data to calculate population num bers reported in their RMP. 40 C.F.R. 68.33 Defining offsite impacts-environment- PPC provided maps that identified the potential offsite impacts and identified public receptors. _ _ _ _ _....4:~0'-"C'.F.R. _ 68.36 Bmew and update- I reviewed...eeCs.d.orumentatioO-tbat-i.llustrated-r:eiews..and updates regarding the offsite consequences are occurring at least every five years. 40 C.F.R. 68.39 Documentation- PPC provided documents of the offsite consequence analysis data. For worst-case and alternative case scenarios, a description of the vessel or pipeline, the substance selected as worst-case, and the rationale for selection was included; likewise, assumptions included any administrative controls and any passive mitigation that were assumed to limit the quantity that could be released, estimated quantity released, release rate, and duration of release. The methodology used to determine distance to endpoint was documented by the facility. The data used to estimate population was provided in the form of maps that had the distance to endpoint labeled with a circle from the emissions point . 40 C.F.R. 68.42 Five-year accident history- PPC did not report any accidenta l release(s) in their RMP that resulted in deaths, injuries or property damage. Subpart D- Program 3 Prevention Program 40 C.F.R. 68.65 Process safety information -I reviewed various sections of process safety information for the RMP un its at PPC. 40 C.F.R. 68.67 Process Hazard {PHA)- I reviewed the PHA for the RMP process. The July 28, 2016 PHA was conducted using What-if, Hazard and Operability Study (HAZOP) and Layer of protection analysis {LOPA). 40 C.F.R. 68.69 Operating procedures- I reviewed the Operating Procedures that were requested from PPC. PPC uses a paper and electronic document management system to maintain its operating procedures. I reviewed and discussed with PPC personnel operating procedures which included the Standard Operating Procedure {SOP) Certification Procedure, Confined Space Entry and Lockout/ Tag out Procedures . I observed that PPC certified that the operating procedures were current, accurate, and that the proced ures had been reviewed as often as necessary. PPC provided documentation that its operating procedures were certified, current, accurate, and that procedures had been reviewed as often 4