Document M44Y3xj50b9MKaRGMgzJjr9Ka

A EA~ UnitcdSt3tcs ~., Environment1l Proltttiol"l ~ Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s) : Media: Regulatory Program(s) 09/19/17 - 9/21/2017 Air Clean Air Act Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: WTG Gas Processing LP WTG South Permian Midstream LLC formerly WTG Benedum Joint Venture LP - Benedum Gas Plant State Highway 1555 Midkiff, Texas 79755 (same as above) (same as above) Upton Richard Luna I Plant Supervisor rlun a@wtggas.com FRS Number: Identification/Permit Number: Media Number: NAICS: 110025328795 0-0946 RMP EPA Facility Identifier: 100000063682 211112 = Natural Gas Liquid Extraction Personnel participating in inspection: Tony Robledo US EPA/6EN-AS Richard Luna WTG Gas Processing LP Inspector Plant Supervisor (214) 665-8182 (432) 693-2446 EPA Lead Inspector Signature/Date -~.,L Tony Robledo .. /0.. 1/-17 Date Supervisor Signature/Date /~ Samuel Tates 1~ IO IJ/ J2-0 ,ry Date GENFORM -019-RG (10/6/14) 1 WTG South Permian Midstream LLC, Benedum Gas Plant Inspection Date 09/19-21/2017 Section I - INTRODUCTION PURPOSE OF THE INSPECTION The United States Environmental Protection Agency (EPA) Region 6 inspector Tony Robledo arrived at the WTG South Permian Midstream LLC, formerly WTG Benedum Joint Venture LP, Benedum Gas Plant, at approximately 9:30a.m. on September 19, 2017, for an announced inspection. I conducted an opening meeting with the following persons in attendance as identified in Table 1. Name Jeff Sheppard Bobby Roach Jimmy Roach Richard Luna Trae Futrell Elena Hofmann Oscar Guerrero Daniel Gonzales Tony Robledo Table 1: Opening Meeting Attendance Position . . . . Vice-President Engineering and Operations Health, Safety and Environment Director Safety Manager Plant Superintendent Area Manager Environmental Manager EOSolutions Plant Foreman Maintenance Supervisor Inspector and Enforcement Officer EPA Region 6 I presented my credentials to all attendees at the opening meeting and informed them that this EPA inspection was to determine compliance with Clean Air Act Sections 112(r)(1) and 112(r)(7). The scope of the inspection was a partial compliance evaluation (PCE) and included evaluation of the compliance with 40 C.F.R. Part 68- Chemical Accident Prevention Provisions. I was informed of the facility ownership name change to WTG South Permian Midstream LLC (WTG) with an effective date of August 1, 2017. I was provided a safety facility orientation by Jimmy Roach. FACILITY DESCRIPTION The WTG facility operates a variety of processes to produce Y-Grade petroleum products from natural gas, and consists of a 120 million cubic feet per day (MMCF/D) cryogenic plant with two skids, one with scrubbers/filters and dryers and one with Mafi Trench expander, heat exchangers and demethanizer. Off skid equipment is the propane chiller, product surge tank, product settling tank and coalescer filter, and an Ortloff system. The facility processes regulated flammable mixtures to include propane, normal butane, isobutane, ethane, and methane in excess of threshold quantity. WTG has no toxic chemicals that exceed the threshold quantity. The facility has 12 full-time employees. Section II - OBSERVATIONS 1conducted a walk-through of the facility on September 20, 2017, accompanied by facility personnel to observe the process, equipment, storage tanks, and operation. I observed a WTG facility operator use a FUR Series GF320 infrared camera to verify a pressure relief valve leak at the Wilshire inlet receiverno other spills, leaks, or air emissions were observed. I observed a facility flaring event during the walkthrough with no visible emissions. 2 WTG South Permian Midstream LLC, Benedum Gas Plant Inspection Date 09/19-21/2017 40 C.F.R. Part 68- CHEMICAL ACCIDENT PREVENTION PROVISIONS Subpart A- General 40 C.F.R. 68.10 Applicability- WTG is an owner and operator of a stationary source that has more than a threshold quantity of regulated flammable substances, listed in 40 C.F.R. 68.130, in a process and as such is subject to these Chemical Accident Prevention Provisions. WTG listed the NAICS code (211112) natural gas liquid extraction, as the process in their Risk Management Plan (RMP). The WTG process is also subject to the Occupational Safety and Health Administration (OSHA) process safety management standard, 29 C.F.R. 1910.119. These factors make the process at WTG a Program 3 subject to 40 C.F.R. 68.10(d). 40 C.F.R. 68.12 General Requirements- WTG re-submitted a RMP five-year update on September 13, 2013. This submittal lists a covered process for Program 3. This requires the facility to develop and implement a management system, conduct a hazard assessment, implement the prevention requirements of 40 C.F.R. 68.65- 68.87, develop and implement an emergency response program, and submit the data elements from 40 C.F.R. 68.175 in their RMP. 40 C.F.R. 68.15 Management- WTG has a documented management system to oversee the implementation of the risk management program elements, and has assigned a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements. WTG facility personnel provided an organization chart which documents the persons responsible for implementing individual requirements of the RMP as required by this subpart. Subpart B- Hazard Assessment 40 C.F.R. 68.20 Applicability- WTG is an owner or operator of a stationary source subject to this subpart with a Program 3 process that must prepare an offsite consequence analysis as provided in 68.25 of this subpart, complete the five-year accident history as provided in 68.42, and comply with all sections in this subpart for this process. 40 C.F.R. 68.22 Offsite Consequence Analysis Parameters -I requested documentation of the offsite consequences analysis. I reviewed the documentation provided and had a discussion with appropriate WTG facility personnel. WTG applied the offsite consequence analysis parameters as required by this subpart. 40 C.F.R. 68.25 Worst-Case Release Scenario Analysis- WTG identified and reported a worst-case release scenario analysis for the RMP covered flammable substances. I requested documentation of the worst-case release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate WTG facility personnel. WTG selected a natural gas liquids vessel (PV 1607) for the worstcase release scenario with a capacity of 174,445 pounds. WTG used EPA's RMP* Comp'" to calculate the distance to the endpoint in the flammables worst-case scenario. However, WTG personnel provided updated capacity information for the natural gas liquids vessel (PV 1607) that identified a capacity of 286,586 pounds which increased the distance to the endpoint in the flammable worst-case scenario. I recommended to WTG personnel that when it updates its RMP to change the facility ownership name that it also correct errors identified in the RMP, update the selected worse-case scenario information, and update the appropriate process chemicals quantity. 3