Document Ra5ODjd3mZmnJx47nE8jVp1wa

ft EA~UnitcdStatcs ~., EnvirunmantBI P<ot~Jtiou ,. Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 10/22/2018- 10/23/2018 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: FRS Number: Identification/Permit Number: Media Number: NAICS: Mustang Gas Products LLC Ringwood Gas Plant 266454 E. County Road 47 Ringwood, Oklahoma 73768 (same as above) (same as above) Major Kent Sales Kent.Sales@MustangFuel.com I Environmental Health & Safety Supervisor . 110000752025 Air Title V Permit No: 2011-046-C (M-1) RMP EPA Facility Identifier: 100000064299 211112 =Natural Gas Liquid Extraction Personnel participating in inspection: Tony Robledo US EPA/6EN-AS Kent Sales Mustang Gas Products LLC Inspector Environmental Health & Safety Supervisor (214) 665-8182 (580) 747-7475 EPA Lead Inspector Signature/Date fcrv> A,f!-o -ffi, :!U Tony Robledo u /2-~-t? Date . Supervisor Signature/Date _. ,J 1~ Samuel Tates IZ)fp/z.oJB Date 6ENFORM-019-R6 (10/6/14) 1 Mustang Gas Products LLC, Ringwood Gas Plant Inspection Date 10/22/2018- 10/23/2018 Section I -INTRODUCTION PURPOSE OF THE INSPECTION I, United States Environmental Protection Agency (EPA) Region 6 inspector Tony Robledo, arrived at the Mustang Gas Products LLC (Mustang), Ringwood Gas Plant, atapproximately 9:00a.m. on October 22, 2018, for an announced inspection. I conducted an opening meeting with the following persons in attendance as identified in Table 1. Name . Kent Sales Sunni Stephenson Daniel Kapke Tony Robledo Table 1: Opening Meeting Attendance Position Mustang Environmental Health & Safety Supervisor Mustang Environmental Health & Safety Compliance Coordinator Mustang Pipeline Operator EPA Inspector 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. FACILITY DESCRIPTION The Ringwood Gas Plant is a natural gas processing plant which extracts natural gas liquids from inlet gas. Products resulting from the facility's process include natural gas liquids and pipeline quality natural gas. High pressure natural gas enters the facility through inlet separators to the cryogenic process then tore-compressor number 17. In the cryogenic process, gas is first dried in the mole sieve dehydrator and then sent through a series of temperature and pressure changes where gas and liquid products are separated. The mole sieve dehydrators absorb water from the natural gas, but not hydrocarbons. In the lean oil process, gas is first dried in the triethylene glycol dehydrator and then sent through the lean oil absorber where natural gas liquids are removed from the gas stream. The resulting rich oil is heated to remove natural gas liquid products. The liquid product from both the cryogenic plant and the lean oil plant goes through an amine treater to remove carbon dioxide and any trace amount of sulfur and the product is sent to the product sales pipelines. The off-gases from the amine unit are sent to the flare. The Me nos Booster Station is a gathering and boosting station located adjacent to the Ringwood Gas Plant which includes compressor engines, a triethylene glycol dehydrator, glycol reboiler, and condensate storage tanks. Both the Me nos Booster Station and the Ringwood Gas Plant are included in the facility's Title V permit. There are no listed toxic substances, only flammable substances, which exceed their respective threshold quantities stored at this facility. The facility produces approximately 9 million cubic feet per day of natural gas. The facility has four full-time employees. Section II - OBSERVATIONS I conducted a walk-through of the facility on October 22, 2018, accompanied by Mustang personnel to observe the facility process, equipment, storage tanks, and operation. I observed no spills, leaks, or air emissions with the FUR'" Series GF320 infrared camera. 2 Mustang Gas Products LLC, Ringwood Gas Plant Inspection Date 10/22/2018 -10/23/2018 40 C.F.R. Part 68- CHEMICAL ACCIDENT PREVENTION PROVISIONS Subpart A- General 40 C.F.R. 68.10 Applicability- Mustang 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. Mustang listed the NAICS code (211112) natural gas liquid extraction, as the process in its Risk Management Plan (RMP). The Mustang facility 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 the Mustang facility a Program 3 subject to 40 C.F.R. 68.10(d). 40 C.F.R. 68.12 General Requirements- Mustang re-submitted a RMP five-year update on June 8, 2016. 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- Mustang has an established 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. Mustang 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- Mustang 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 Mustang facility personnel. Mustang applied the offsite consequence analysis parameters as required by this subpart. 40 C.F.R. 68.25 Worst-Case Release Scenario Analysis- Mustang 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 Mustang facility personnel. Mustang selected their only natural gas liquid storage tank (numbered 9) for the worst-case release scenario. Mustang used EPA's RMP*Comp to determine the distance to the endpoint in the worst-case release scenario. Mustang used the proper endpoints for flammables as required by this subpart. 40 C.F.R. 68.28 Alternative Release Scenario Analysis- Mustang identified and reported an alternative release scenario for the RMP covered flammable substances. I requested documentation of the alternative release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate Mustang facility personnel. Mustang selected three condensate tanks as its alternative 3