Document Ra8vZNRynez4Jk9zg0bXzxK5B

Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 09/20/2022 - 09/21/2022 Air Clean Air Act Section 112(r) and 40 Code of Federal Regulations (C.F.R.) Part 68 Chemical Accident Risk Management Plan (RMP) Program 2 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 Identifier Number: NAICS: Kinder Morgan Energy Partners LP KM Liquids Terminals LLC 530 North Witter Pasadena, Texas 77506 300 Beltway Green Boulevard Pasadena, Texas 77503 Harris Keith Cormier Operations Manager Keith_Cormier@kindermorgan.com 110000504892 / TX0000004820100092 CAA Title V O984 RMP 1000 0011 8124 493190 Other Warehousing and Storage Personnel participating in inspection: Tony Robledo U.S. EPA Zackary Ward Kinder Morgan Greg Allen Kinder Morgan Corey Banks Kinder Morgan Gabriel Andrade Kinder Morgan Keith Cormier Kinder Morgan Chuck Richey Kinder Morgan Scott Eady Kinder Morgan EPA Lead Inspector Signature/Date ANTHONY ROBLEDO Tony Robledo Inspector/Enforcement Officer Emergency Response Manager Environmental Health & Safety Manager Process Safety Management/Risk Management Plan Specialist Risk Management Plan Manager Operations Manager Maintenance Manager Director Environmental Health & Safety 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: 2022.09.28 09:47:04 -05'00' Supervisor Signature/Date Digitally signed by SAMUEL SAMUEL TATES TATES Date: 2022.09.28 12:20:29 -05'00' Samuel Tates Kinder Morgan Energy Partners LP/KM Liquids Terminals LLC Inspection Dates: 09/20/2022 - 09/21/2022 Section I - INTRODUCTION PURPOSE OF THE INSPECTION I, Environmental Protection Agency (EPA) Region 6 inspector Tony Robledo, arrived at the Kinder Morgan Energy Partners LP (Kinder Morgan), KM Liquids Terminals LLC at approximately 9:00 a.m. on September 20, 2022, for an announced inspection. I met with Kinder Morgan managers and staff at the opening meeting. I presented my credentials, and informed them 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 compliance with 40 C.F.R. Part 68 - Chemical Accident Prevention Provisions. FACILITY DESCRIPTION The primary purpose of the facility is to temporarily store, break bulk1, and distribute Vinyl Acetate Monomer (VAM) to a single end user. VAM is used as a raw material for manufacturing polyvinyl resins such as those used in latex paints, paper coating, adhesives, textile finishing, and safety glass interlayers. VAM is received by barge and is transferred to two storage tanks. VAM is distributed to a single customer via pipeline. The facility also has equipment for unloading ships, barges, rail cars and tank trucks containing other materials. The facility handles one regulated toxic chemical (VAM) above RMP threshold quantities. The facility was constructed in 1953 and acquired by Kinder Morgan in the early 2000's. There are 150 fulltime employees at this union and non-union represented facility. The plant operates 24 hours a day, 7 days a week. Section II - OBSERVATIONS I conducted a walk-through of the facility, accompanied by Kinder Morgan personnel, to observe the facility process, equipment, and vessels. I observed that the facility was missing proper markings on VAM piping (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 American National Standards Institutes (ANSI)/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. I also observed no spills, leaks, or fugitive hydrocarbon emission trails with the Forward Looking Infrared (FLIRTM) Series GF77 optical gas imaging camera. Additional observations and findings are found on the RMP Program Level 2 Checklist, located in Appendix #1. Section III - AREAS OF CONCERN Closing Meeting - I convened a closing meeting on Wednesday, September 21, 2022, to discuss the Areas of Concern (AOC) noted during the inspection, the inspection completion process, and to answer questions from Kinder Morgan personnel. AOC 1 - 40 CFR 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. 1 Break bulk is a shipping term for cargo that does not fit in a standard shipping container or cargo bin. Break bulk cargo is instead transported individually in bags, boxes, crates, drums, or barrels. 2 Kinder Morgan Energy Partners LP/KM Liquids Terminals LLC Inspection Dates: 09/20/2022 - 09/21/2022 Kinder Morgan failed to properly label VAM piping for process equipment as required by American National Standards Institutes (ANSI)/American Society of Mechanical Engineers (ASME) Standard A13.1. Section IV - FOLLOW UP There were no additional records requested and no additional follow up for this inspection. Section V - LIST OF APPENDICES Appendix #1 - RMP Program 2 Checklist Inspection Symbol Key: Y - Yes, N - No, N/A - Not Applicable; S - Satisfactory, M - Marginal, U - Unsatisfactory. 3