Document RpwjbMYOZEgwy7oZpdOXBNmd8

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 1445 Ross Avenue Dallas, Texas 75202-2733 DEC 4 20f4 CERTIFIED MAIL - RETURN RECIEPT REQUESTE D: 7014 0150 0000 2453 3405 Mr. Bill Gibson Director EHS&T Audits Enterprise GC, LP 1100 Louisiana Ilouston, Texas 77002 Re: Clean Air Act Section 114 Information Request Dear Mr. Gibson: Enclosed is an Information Request (Request) issued to Enterprise GC, LP under the authority of Section 114 of the Clean Air Act (CAA). The purpose of this Request is to obtain information regarding the fire that occurred on March 11 , 2014, at the Shoup Plant located at 802 McKenzie Road, Corpus Christi, Texas 78410. Please provide the information requested within thirty (30) days of your receipt of this letter to Tony Robledo at the above address. If you have any questions relating to this Request, please contact Tony Robledo, a member of my staff, at 214-665-8 182. Enclosure cc: Michael De La Cruz, TCEQ Director Compliance Assurance and Enforcement Division Enclosure A Information Request Enterprise GC, LP The U.S. Environmental Protection Agency (EPA) Region 6 is issuing this request for in formation to Enterprise GC, LP pursuant to Section 114 of the Clean Air Act (CAA), 42 U.S.C. 74 14 for the purpose of determining compliance with the CAA, including CAA section l l 2(r). Section l l 4(a) authorizes the Administrator of EPA to require the submission of information. The Administrator has delegated this authority to the Director of the Compliance Assurance and Enforcement Division, EPA Region 6. This information request pertains to the Enterprise GC, LP Shoup Plant located in Corpus Christi, Texas. You must submit all requested information under an authorized signature on the certification statement in Enclosure B, which provides: I certify und er penalty of law that I have examined and am familiar with the information in the enclosed documents, including all attachments. Based on my inquiry ofthose individuals with primary responsibility for obtaining the information, I certify that the statements and information are, to the best of my knowledge and belief, true and complete. f am aware that there are significant penalties for submitting false statements and information, including the possibility of fine and imprisonment for knowing violations. We may use any information submitted in response to thi s request in an adm inistrative, civ il,' or criminal action. All information responsive to this Request should be sen t to the following: Tony Robledo (6RC-ER) U.S. EPA Region 6 1445 Ross Avenue, Suite 1200 Dallas, TX 75202-2733 I. Instructions I. If information or documentation not known or not available to you as of the date of submission of a response to this Request should later become known or available to you, you must supplement your response to EPA. Moreover, should you find, at any time after the submission of your response, that any portion of the submitted information is false or misrepresents the truth, you must notify EPA of this fact as soon as possible and provide EPA with a corrected response. There are significant penalties for submitting false information, including the poss ibility of fine or imprisonment. Re: Information Request Enterprise GC, LP 2. For each document produced in response to this Request, indicate on the document, or in some other reasonable manner, the number of the question to which it responds. Please submit all information for each question in a logically sequenced, bound format. 3. Please provide a separate response to each question and subpart of a question set forth in this Request and precede each answer with the number of the question to which it corresponds. 4. In your response to each question, identify each person answering the question, including each person answering any subparts of the question, as well as each person consuJted in the preparation of your response. 5. For each question, identify each document consulted, examined, or referred to in the preparation of the response or that contains information responsi ve to the question, and provide a true and correct copy of each such document if not provided in response to another specific question. Indicate on each document produced in response to this Request the nwnber of question to which it corresponds. 6. Failure to submit requested information in accordance with statutory or regu latory requirements constitutes a violati on of the CAA. II. Confidential Business Information You must provide the information requested even if you consider it confidential information or trade secrets. You may assert a business confidentiality claim for part or all of the information requested, as described below and set fo rth in 40 C.F.R. Part 2, Subpatt B. [nformation covered by such a claim will be disclosed by EPA only to the extent and onJy by the procedures set forth in 40 C.F.R. Part 2, Subpart B. If no confidentiality claim accompat1ies the information when EPA receives it, the information may be made available to the public by the EPA wi thout further notice to you. 40 C.F.R 2.203(a); see also 41 fed. Reg. 36,902 (Sept. 1. 1976); 43 Fed. Reg. 4,000 (Dec. 18, 1985). If you wish EPA to treat any information or response as confidential, you must advise EPA and comply with the following procedures. Place on or attach to the information at the time it is submitted to EPA a cover sheet, stamped or typed legend, or other suitable form of notice employing such language as trade secret, proprietary, or company confidential. You must clearly identify allegedly confidential portions of otherwise non-confidential documents and you may want to submit these separately to fac ilitate identification and handling by EPA. Jf you seek confidential treatment only until a ce11ain date or until occurrence of a certain event, state this in your notice. Include an explanation of your claim that disclosure of the info1mation would likely result in substantial harmful effects on your business' competitive position, referring to the applicable substantive criteria in 40 C.F.R. 2.308. Specify the harmful effects, why they should be viewed as substat1tial and the causal relationship between di sclosure and substantial harmful effects. You must make a separate assertion of 2 Re: Information Req uest Enterprise GC, LP confidentiality for each response and each record that you consider confidential. Submit a written index for each record for which you assert a claim of confidentiality that includes the fo llowing information: 1. Describe the response or document and nature of the information. For a document, include the name of the author(s), the date the document was issued, the summary title, and the names of the recipient(s). 2. Specify the portion of the response or document for which you asse11 a claim of confidentiality by reference to page numbers, paragraphs, and lines, or specify entire document. 3. Briefly identify the basis of your claim. If you believe that facts and documents necessary to substantiate confidentiality are themselves confidential , please identify them as such so that EPA may maintain their confidenti ality pursuant to 40 C.F.R. Part 2, Subpart B. III. Definitions l . Unless specifically defined in thi s Request or in the CAA or its impl ementing regulations, all terms used in thi s Request will have their ordinary meaning. 2. The term s 'document" or "documents" shall mean written documentation of any kind, including documentation solely in electronic form . It includes any document in the possession or control of the company or the possession or contro l of any person hired by the company. A copy of a document rather than the original may be provided 3. The term "Enterprise GC, LP" includes any officer, director, agent, or employee of Enterprise GC, LP, including any merged, conso lidated, or acquired predecessor or parent, subsidiary, di vision, or affiliate thereof, and any related partnerships or limited partnerships. 4. The terms "you" or "yours" shall mean Enterprise GC, LP , as defined in Paragraph 3 above, inc luding the company or corporation , its subsidiaries, division, affiliates, predecessors, successors, assigns, and its fo rmer and present officers, directors, agents, employees, representatives, attorneys, consultants, accountants and all other persons acting on its behalf. 5. The tenn "Facility" refers to the Enterprise GC, LP Shoup Pl ant located at McKenzie Road, Corpus Christi, Texas 78410. 3 Re: Information Request Enterprise GC, LP 6. Words in the masculine shall be construed as the feminine, and vice versa, and words in the singular shall be construed in the plural, and vice versa, where appropriate in the context of a particular question or questions. JV. Information Requested With respect to the fi re that occu1Ted at the Facil ity on March 11, 2014 (the 'Incident"): 1) Please describe the facility, including the purpose of the faci lity, what processes take place there, the equipment used, etc. 2) Describe the Inlet Gas Separator maintenance that was taking place on March 11 , 2014. 3) Identify by name, company, position, and function who was performing that mainte nance. 4) What substances were inside the Inlet Gas Separator on March 11 , 2014? 5) Was the standard operating procedure (SOP) for cleaning the Inlet Gas Separator followed on March 10, 20 14, and March 11 , 2014? If not, then explain any deviation from the SOP. 6) lf a contractor was performing work on the Inlet Gas Separator on March 11, 2014, then please explain how you provided oversight to ensure SOP and other safety requirements were fo llowed by the contractor during the maintenance activities. 7) Please provide a detailed narrative describing the Incident that occurred on March 11 , 2014. 8) Please provide a timeline of the maintenance activities on the Inlet Gas Separator, including the Incident and the responses to the Incident. 9) Did the water used to clean the inside of the vessel react with a substance inside the vessel or otherwise cause the lncident? Jf so, then please explain. 10) Please describe Procedure SHP-001. Please attach a copy. Does the Procedure require that all High Point Vent Valves be open when the vessel is flooded with water? If so, then were the Inlet Gas Separator High Point Vent Valves open on the vessel at issue in the Incident? If not, then why not? What was the impact of having the High Point Vent Valves remain closed during cleaning or flooding with water? 4 Re: Information Request Enterprise GC, LP 11 ) Who sprayed water into the vessel in response to the smoke? Did you have a representative managing the contractors at the time water was sprayed into the vessel in response to the smoke? 12) Is the Inlet Gas Separator part of a risk management plan covered process? 13) Please describe any injuries that resulted from the incident describing the extent of injury. 14) Please describe any property damage, on-site or off, that resulted from the Incident. 15) Are you undertaking an investigation or analysis into the cause of the Incident? If so, then please describe any conclusions that have resulted from the investigation or analysis. 16) Have you, or any other entity, performed a root cause analysis of the causes of the incident? If so, then please attach any draft or final copy of the root cause analysis currently in your possession or under your control. 17) What measures have you undertaken to prevent a recurrence of the Incident? 5 Re: Jn formation Request Enterprise GC, LP Enclosure B Clean Air Act Section 114 Information Request Statement of Certification I certify under penalty of law that I have examined and am familiar with the information in the enclosed documents, including all anachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are, to the best of my knowledge and belief, true and complete. I am aware that there are significant penalties for submitting false statements and information, including the possib ili ty of fine and imprisonment for knowing violations. S ignature: Printed Name: Office or Title: 6