Document YLEk9xx1OnMg50kD51Y09zoD

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 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: Facility Representatives: EPA Inspectors: Other lnspector(s): ..r..o.. Title: ro "C Author: ..r.o... Q) Subject: ~ Keywords: EPA Lead Inspector Signature/Date Supervisor Signature/Date 08/11-14/2014 Air RMP Motiva Enterprises Port Arthur Refinery 2100 Houston Avenue I 2555 Savannah Avenue Port Arthur, TX 77641 P. 0. Box 712 Port Arthur, TX 77641-0712 Jefferson Terry Rodeheaver I Process Safety Refinery Manager Port Arthur 110000464024 - RMP # 1000 0015 7297 AFS # 48-245-00020 32411 Petroleum Refineries Terry Rodeheaver Joseph Duplechin Juan Cardenas Damian Fryoux Greg Willms William Watson Dave Hensley Debbie Ford Craig Haas Dan Roper Anthony Gaglione PSM Manager PSM Specialist PSM Specialist Environmental Tech. General Manager Technical Manager EPA (6EN-AS) EPA (6EN-AA) EPA (Headquarters) ERG ERG (409) 982-5711 (409) 982-5711 (409) 982-5711 (409) 982-5711 (409) 982-5711 (409) 982-5711 (214) 665-6739 (214) 665-7235 (202) 564-6447 (571) 329-2067 (703) 842-0697 Motiva Enterprises Port Arthur Refinery Port Arthur Jefferson County Texas US EPA Region 6 Compliance Assurance and Enforcement Division Dallas TX Inspection Report Risk Management Plan RMP 112r 112(r) ~~#-&>~. Dave Hensley ~ 1~ Samuel Tates ~.,_.. ... S-?-2-o/..>- Date s/'7/loJJ Date ' 6ENFORM-019-RS (2/3/14) Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 Section I - INTRODUCTION PURPOSE OF THE INSPECTION EPA Region 6 inspectors Debbie Ford, Craig Haas, Dave Hensley, and EPA contractors Dan Roper and Anthony Gaglione arrived at the Motiva Enterprises Port Arthur Refinery (PAR) at 8:00 AM on August 11, 2014, for an announced inspection. We met with the Process Safety Engineer Manager, Process Safety Management (PSM) Specialist, PSM Specialist, Environmental Tech., General Manager, and Technical Manager. I presented my credentials to those present and informed them that this was an EPA inspection to determine compliance of their Risk Management Program. The scope of the inspection is the Clean Air Act section 112(r), Chemical Accident Prevention Provisions (40 CFR part 68). An employee bargaining unit representative was invited to participate in the inspection. FACILITY DESCRIPTION PAR is located in Port Arthur, Texas at 2555 Savannah Avenue. The refinery operates a variety of processes to produce petroleum products (e.g., propane, butane, gasoline, diesel, jet fuel, furnace oil, etc.) from raw, sour crude oil. The refinery has several regulated flammables, such as propane and butane as well as flammable mixtures. One of the by-products of petroleum refining is hydrogen sulfide, which is a RMP listed toxic substance. Within the refinery, hydrogen sulfide is converted into elemental sulfur, which is a marketable product. PAR operates 8,760 hours per year. Section II - OBSERVATIONS 40 C.F.R. Part 68 - CHEMICAL ACCIDENT PREVENTION PROVISIONS Subpart A - General 40 C.F.R. 68.10 Applicability - I observed that PAR is a stationary source that has an Air Operating Permit 8404 and more than a threshold quantity of a RMP regulated substance in more than one process; therefore, these regulations are applicable to those processes. PAR submitted a Risk Management Plan (RMP) that describes one process containing a hydrogen sulfide and multiple processes with flammable chemicals held at more than a threshold quantity. These processes units are Program 3 due to the NAIC code of 32411 Petroleum Refineries and the processes are subject to OSHA's Process Safety Management Standard (29 CFR 1910.119). 40 C.F.R. 68.12 General requirements - PAR resubmitted their RMP on July 20, 2011, due to a regulated substance present above threshold quantity in new or previously not covered process (40 CFR 68.190(b)(4)). PAR has also developed and implemented a management system as provided in 68.15, conducted a hazard assessment as provided in 68.20-42, implemented the prevention requirements of 68.65-87, developed and implemented an emergency response program as provided in 68.90-95, and submitted in the RMP the prevention program data elements as provided in 68.175, as required under the Program 3 requirements. 40 C.F.R. 68.15 Management - PAR provided me documentation of the management system they had set up for the implementation of the Risk Management Program elements. I reviewed the documentation and found that it describes who is assigned to oversee the Risk Management Program, and who is assigned to positions responsible for portions of the Risk Management Program. 2 Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 Subpart B - Hazard Assessment 40 C.F.R. 68.20 Applicability - The RMP from PAR states that its processes are classified as Program 3 stationary sources subject to this part; therefore, PAR is required to prepare a worst-case release scenario analysis and complete the five year accident history. 40 C.F.R. 68.22 Offsite consequence analysis parameters - I spoke with the Process Safety Manager and the Process Safety Specialist about the offsite consequence analysis conducted by PAR. They used EPA's RMP*Comp to calculate the distance to the endpoint in the toxic worst-case scenarios. PAR used the parameters defined in 40 C.F.R. 68.22 to determine the distance to the endpoints. PAR does have flammable substances held above threshold quantities, so a flammable worst case was also conducted using RMP*Comp and the required parameters. 40 C.F.R. 68.25 Worst-case release scenario analysis - PAR considered release scenarios for the toxic substance (hydrogen sulfide) listed on their RMP. PAR used the release of the entire volume of one of their largest vessels without controls in to calculate their worst-case scenario. PAR used the parameters defined in 40 C.F.R. 68.22 to determine the distance to the endpoints. 40 C.F.R. 68.28 Alternative release scenario analysis - PAR identified and analyzed at least one alternative release scenario for their regulated toxic substance (hydrogen sulfide) held in a covered process. PAR used the parameters defined in 40 C.F.R. 68.22 and the RMP*Comp to calculate the distance to the endpoint. PAR considered mitigation systems when calculating alternative release scenarios. They also used their accident history and the failure scenarios identified in 40 C.F.R. 68.50 in selecting the alternate release scenario. 40 C.F.R. 68.30 Defining offsite impacts - Population - The population included in the distance to the endpoint in the RMP was estimated to two significant figures using aerial imagery of the worst case distances, a house count, and average household populations from the US Census Bureau. 40 C.F.R. 68.33 Defining offsite impacts - Environment - I observed that PAR identified environmental receptors through a map with a circle created with the distance to the endpoint in the RMP. 40 C.F.R. 68.36 Review and update - The PAR Process Safety Specialist said that the offsite release scenario analysis is reviewed at least once every five years. PAR reviews offsite impacts when an addition or changes are made to processes to determine if a new offsite impact analysis or any other changes to the RMP are necessary through their management of change procedures. 40 C.F.R. 68.39 Documentation - PAR provided documentation for the worst-case scenarios and alternative release scenarios. This documentation included a description of the process equipment and the substance selected as worst case, assumptions and parameters used, documentation of estimated quantity released, release rate, duration of release, methodology used to determine distance to endpoints, and data used to estimate population. 40 C.F.R. 68.42 Five year accident history - PAR had reported an accident from February 19, 2005, in its five year accident history in the current RMP submitted July 11, 2011. Craig Haas' review did not identify any accidents that meet the five year accident history reporting criteria of 40 CFR 68.42 during the inspection. 3 Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 Subpart D - Program 3 Prevention Program 40 C.F.R. 68.65 Process safety information (PSI) - Anthony Gaglione of ERG reviewed and provided the following report. Motiva PAR's PSI policy is documented in the refinery's Process Safety Management Policy (GEN0030, Revision #3, authorized 6/20/14). The inspection team conducted field verifications in VPS5 Unit, reviewed the PSI for the VPS5 and Alky Units, and interviewed refinery personnel. The inspection team visited the central control room and interviewed Ensure Safe Production (ESP) operators (i.e., board operators), who were stationed on the CRU4. A Console Operator described how audio and visual alarms indicate when variables are outside of safe limits. The Console Operator demonstrated how to query a variable tag number in the ESP variable table and identify safe limits, inside actions, outside actions, consequences of deviation, and rationale. The Console Operator explained how board operators can radio or call field operators to give instructions on outside actions. The Console Operator also explained how MSDS can be pulled up on the computers. He also showed the inspection team hardcopies of emergency procedures in case of power failure. The inspection team also interviewed the ESP Focal Coordinator who oversees tools for alarms. The ESP Focal Coordinator explained how the ESP variable table manages variable limits and alarms. He explained the three alarm priorities: Low (or alert) alarms to indicate operating limits; Standard (or high) alarms to indicate an abnormal condition with some time to mitigate; and Critical (or urgent) alarms to indicate that the operators must react immediately. The inspection team field verified VPS5 heaters 3 and 4 transfer lines on the VPS5 Atmospheric Heater P&ID (drawing no. YC-210364, rev. 4; PARMP 000107). -- The P&ID indicates a double-block and bleed line on each heater pass consisting of two manual valves with a inch bleeder valve in between them and a spectacle blind (line closed) before the terminal valve. The P&ID noted that blind flanges were to be installed. -- The inspection team observed that there were no valves or spectacle blinds downstream of the bleeder valve and the double-block and bleed line was actually a single-block and bleed line terminating with a blind flange as shown in Photograph 1 [PARMP 000787] (see AOC 40 CFR 68.65(d)(1)(ii)). Based on field verification, the combined wet gas inlet to the combined wet gas cooler had a hand-wheeled valve, not a chain operated valve as indicated on VPS5 combined wet gas cooler P&ID (drawing no. YC-210234, rev. 4S; PARMP 000109). -- Shown in Photograph 2 [PARMP 000789] (see AOC 40 CFR 68.65(d)(1)(ii)). Based on field verification, the temperature indicator installed in thermowell TW-027 on the combined wet gas outlet to the combined wet gas cooler is an instrumented thermocouple, not a local temperature gauge as indicated on VPS5 combined wet gas cooler P&ID (drawing no. YC- 210234, rev. 4S; PARMP 000109) (see AOC 40 CFR 68.65(d)(1)(ii)). -- Shown in Photograph 3 [PARMP 000788]. The inspection team reviewed the Process Safety Management Policy. Attachment 2 includes a table that listed examples (but not all) of the types of PSI listed in the regulation, the documents that contain the PSI examples, and the location of the documents/PSI. Attachment 2 would be more complete if it listed all of the types of PSI elements in paragraph 40 CFR 68.65(d) concerning Information pertaining to the equipment in the covered process. 4 Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 40 C.F.R. 68.67 Process hazard analysis (PHA) - Anthony Gaglione of ERG reviewed and provided the following report. The inspection team reviewed the PAR PHA Policy (Revision #1, authorized 6/16/14). Sections 6.0 and 11.0 make reference to OSHA PSM, but it appears they should also reference EPA RMP. Specifically, Section 11.0 references maintaining PHA reports, updates/revalidations, and documented resolution of recommendations per 29 CFR 1910.119(e), but should also reference 40 CFR 68.67. Additionally, Section 5.0 item 8 refers to Attachment 1, but it seems it should refer to Attachment 2. The inspection team interviewed The Process Safety Manager and PSM / PHA Specialist about PARs PHA policy, scheduling, and recommendation tracking. They explained the refinery's Hazards and Effects Management Process (HEMP) used for assessing risk of PHA recommendations. Recommendations are tracked using an action tracking system. The Process Safety Manager explained that a past compliance audit identified an issue of "blue" recommendations not being tracked. Now, all PHA recommendations, regardless of risk ranking, are tracked. The action tracking system rating score includes the risk assessment matrix score along with statements such as indication that a shutdown is needed or the recommendation can wait until the next turnaround. The action tracking system sends a reminder to the recommendation responsible party and the auditor (PSM / PHA Specialist) twice a month. PHA recommendation due dates can only be extended by upper management (The Process Safety Manager and the Plant Manager). At the time of the inspection, the refinery was regrouping processes for the purpose of PHAs. During an interview in the central control room, The CRU4 Console Operator who was on duty, indicated the PHAs are announced before they begin and PHA final reports are available on the network. 40 C.F.R. 68.69 Operating procedures - PAR maintains operating procedure documents on the facility's intranet. The inspection team reviewed several randomly-selected operating procedures for the Risk Management Program process units. I asked and was provided annual certifications of operating procedure used in RMP processes. Craig Haas reviewed operating procedures and provided the following: I reviewed the "Operating Procedure Annual Review Certification Form For purposes of 29 C.F.R. 1910.119 (f)(3)." There are no references to 40 CFR Part 68. 40 C.F.R. 68.71 Training - I discussed PAR's training program with the Learning Supervisor and two, Field Learning Advisors of Motiva's Training Department. We discussed the training process in detail as well as training documentation. We reviewed the training records for eight employees. I did not observe any overdue trainings during the inspection and procedures are in place to ensure training is completed on time. 40 C.F.R. 68.73 Mechanical integrity - Dan Roper of ERG reviewed and provided the following report. PAR's overall mechanical integrity program is governed by a manufacturing policy, DSM-1510002-RP- 01, and is implemented with numerous site-specific inspection and maintenance procedures (PARMP 000803). The inspection team interviewed the Pressure Equipment Integrity (PEI) Engineering Team Lead, the Mechanical Engineering Manager, and, the Turnaround Manager. 5 Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 The refinery has separate departments for projects and turnarounds, routine maintenance, and engineering, with the latter including the inspection programs. Within the Engineering department, the PEI group is responsible for fixed equipment inspections, while the Mechanical Engineering group is responsible for rotating equipment inspections. For piping, PAR has performed time-based inspections, while for pressure equipment other than piping, the refinery has used a risk based inspection (RBI) program based on API RP 580 (Nov 2009). At the time of the inspection, the refinery was preparing to utilize an internal tool that is designed to provide internal guidance on the application of APR RP 580 (Nov. 2009). The refinery uses database for tracking pressure equipment inspection data. Pressure Equipment Integrity (PEI) Engineering Team Lead indicated PAR had performed and was planning several non-routine inspection projects. In the late 1990s, the refinery performed a 100 percent retroactive positive material identification (Retro PMI). More recently, the refinery evaluated high temperature hydrogen attack and incorporated affected systems into processes' Corrosion Control Documents (CCDs). At the time of the inspection, the refinery was kicking off or planning projects to address low silicon (Si) sulfidation, corrosion under insulation (CUI), soil-air interfaces, and underground lines. The refinery provided a five-year schedule for these non-routine inspection and maintenance projects (PARMP 000804). The PEI Engineering Lead indicated the refinery had performed a risk assessment of the various outside battery limits (OSBL) underground piping systems (PARMP 001199), and is working to consolidate existing piping maps into a master map of transfer lines and was in the process of determining the routing of various transfer lines in the field. For rotating equipment, the refinery utilizes third party contractors for vibration monitoring on critical equipment such as large, unspared compressors. Equipment monitoring data are also regularly collected as part of operator rounds using a vibration data collection system. PAR uses standard database and scheduling software for maintenance planning, including work orders. For turnaround work planning, the refinery uses a software program for scheduling and another database is used for assigning and tracking ownership of work items. Monthly data are prepared for management to review inspection and maintenance metrics, including overdue inspections. The refinery personnel indicated there were no overdue inspections, and that there had not been any for several years. 40 C.F.R. 68.75 Management of Change - Dan Roper of ERG reviewed and provided the following report. PAR's MOC policies include General Refinery Policies GEN0083 - 87, and policy GEN0037 for pre- startup safety reviews (PSSR). PAR tracks MOC submissions, reviews, and approvals using an enterprise-level MOC tracking system. The inspection team interviewed PSM Specialist about PAR's MOC program. Each MOC folder in KMS is audited after close-out to make sure all MOC components are included. MOC forms are completed in hardcopy form. The PSM Specialist indicated hardcopy forms are used to encourage the MOC team to meet in person. The MOC responsible person completes the form, each team member signs off, and the MOC form is scanned and uploaded to the MOC database. PSSR is performed after installation is completed. The MOC responsible person and the process owner are required to sign-off on the 6 Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 PSSR; others may also sign-off on the PSSR as needed. The Lead RCM or ESP Operator may sign the MOC to acknowledge they are aware of it. The MOC database generates reminder emails for MOCs not yet closed out. The inspection team examined the following sample MOCs: "VPS5 Heater Outlet Valve Removal (HTR001-004)" (MOC# M20132748-001) and "VPS-5 Atmos Heater Outlet Line Redesign" (MOC# M20132673-001). MOC# M20132748-001 "VPS5 Heater Outlet Valve Removal" (bates number PARMP 000777-000786) had 11 "Yes/No" checkboxes in the HSE, PQ, Reliability Checklist that were not checked (appendix 13 CBI). A subsequent personnel interview, with the PSM Specialist, confirmed that each box should have been checked either Yes or No (see AOC 40 CFR 68.75(a)). 40 C.F.R. 68.77 Pre-startup review - The MOC procedures address the need for pre-startup review. I reviewed a completed pre-startup review via the intranet electronic documentation system. A check list was used for pre-startup safety review. We reviewed several pre-startup reviews, and did not observe any issues. 40 C.F.R. 68.79 Compliance audits - Craig Haas reviewed and provided the following report. I reviewed the 2011 and 2014 Compliance Audits. These audits were conducted by Motiva personnel from outside PAR. The 2014 Audit Finding number 4 refers to "two of the four incident investigation reports reviewed...." The current PAR personnel could not say with certainty what those four incident investigation reports were. I asked for copies of the four incident investigations referred to. PAR provided copies of three of these incident investigations, which were reviewed and discussed below. It is difficult from the audit reports to determine the extent and scope of the audits. Section 68.79 requires all covered processes to be audited. The PSM Specialist stated during an interview that the Audit of the documents at Port Arthur encompasses all covered processes, while field activities only look at some but not all covered processes. Both Audits refer to OSHA requirements rather than to Part 68. (See AOC 40 CFR 68.79) 40 C.F.R. 68.81 Incident investigation - Craig Haas reviewed and provided the following report. 68.81 Incident Investigations and 68.42 Five Year Accident History PAR personnel mentioned that they were looking into two incidents, the HCU2 trip on May 14, 2014, and the loss of a flare pilot on July 18, 2014, to determine whether these two incidents would be subject to 68.81. I reviewed documents from both and do not believe the meet the definition of "catastrophic release." PAR provided copies of three incident investigations based on my request for copies of investigations referred to in the 2014 Compliance Audit. One report, from the August 17, 2013, HCU2 Fire, indicates that a loss of primary containment and fire caused a shutdown of the unit for over two weeks, and also caused a slowdown/shutdown of other refinery units. The repair cost to the unit was determined. During an interview with The Process Safety Manager and PSM / PHA Specialist they explained that PAR does not consider a repair cost of this level to be a significant property damage. PAR has determined a level that could be considered significant. This is based on the through put of the facility and the values of their products. 7 Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 The HCU2 Report created four recommendations. Two of the recommendations were completed during the investigation, and the other two were assigned completion dates of December 31, 2013. It was unclear from the report if these two items had been completed as of the date of the inspection, August 13, 2014. 40 C.F.R. 68.83 Employee participation - Craig Haas reviewed and provided the following report. The document PSM Policy Attachment 1: Employee Participation Plan: GEN0030 contains no references to Part 68 requirements. Only OSHA PSM requirements are referenced. 40 C.F.R. 68.85 Hot work permit - Craig Haas reviewed and provided the following report. I reviewed six hot work permits provided in response to the request for information and did not note any areas of concern. 40 C.F.R. 68.87 Contractors - PAR retains various contractor companies to perform certain types of work. PAR requires contractors to provide workers who have the proper training prior to working in a Risk Management Program covered area. Contractors must complete Industrial Safety Training Council (ISTC) for Southeast Texas basic safe work training, which covers site-specific training of the hazards of the processes and the requirement of their job tasks. Subpart E - Emergency Response - 40 C.F.R. 68.90 Applicability - Debbie Ford reviewed and provided the following report. PAR is a stationary source with Program 3 processes subject to this part; therefore, PAR is required to comply with the requirements of 40 C.F.R. 68.95. PAR employees respond to accidental releases of regulated substances. 40 C.F.R. 68.95 Emergency response program - On August 12, 2014, Debbie Ford and I met with Motiva's Fire Chief. He explained that Motiva had a paid Fire Department staff of 25 firemen and supervisors with 12 inspectors. Motiva does not depend upon volunteers from the various operational areas of the refinery. They operate four shifts, and they operate two shifts/day with four firemen and a supervisor per shift. According to Motiva's Fire Chief, they use an outside vendor to annually test their pumps to ensure proper flow capacity. On a quarterly basis, the refinery's Maintenance Department changes the oil. When reviewing the 2013 inspection records, we noted that the Ladder 1 Big T truck had no preventative maintenance performed (see Appendix 4) (see AOC 40 CFR 68.95(a)(2)). Fire extinguishers undergo an annual audit by zone (A, B, or C) in the refinery and follow the 41 point Inspection as described in Fire Department Module 2578 (see Appendix 5). These 41 point inspections are performed by Fire Department employees. The Motiva's Fire Chief provided some of the inspection sheets (Fire Extinguisher Yearly Audit) performed in 2014, and he stated that the 2013 inspection sheets have been input into an Excel spreadsheet for tracking. We reviewed the 2014 records provided and none of the forms had a date the inspection was performed. Many of the forms did not have any information in the Hydro Date field. We asked the Motiva's Fire Chief how often the extinguishers had to have a hydrostatic test performed, and he did not know. Note: It must be done every 12 years. Also, the forms only had a Pass/Fail indication, without documentation of the individual 41 points of inspection that must be completed for each fire extinguisher audit. 8 Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 Motiva's Fire Chief also explained that the operators perform monthly inspections on fire extinguishers as detailed in Fire Department training Module 2580 (see Appendix 7). He stated that they used a commercial tracking software to capture the inspection information, and the operators in the unit must perform the inspections in the first 10 days of each month. When we met with the Manager - Health, Safety, and Emergency Response on August 14, he stated that the fire extinguisher inspections are tracked via paper records. Some units use electronic records and some units use paper records to track emergency response equipment inspections. We reviewed a sampling of records (see Appendices 8, 10, 11, and 12) and noted some discrepancies (see AOC 40 CFR 68.95(a)(2): Also, the procedure operators should be using only references recordkeeping of the inspection on the tag physically attached to the fire extinguisher. It states that records should be kept for those requiring corrective action, but it never states how to keep those records and what is done with them to correct the deficiencies. Motiva uses a third party contractor to perform fire hose inspections. We reviewed the 2012 hose inspections (see Appendix 9) and noted several problems: Some hoses have no indication if an inspection was performed (PARMP 000915-917, 922-924, 926) Inspection records provided by a third party vender indicated an inspection was performed, all records were provided in electronic format, but had no date of the inspection, or signature and date signed by the inspector (PARMP 000914, 917-922, 925, 927-930). We asked to see the 2013 hose inspection records and when Motiva representatives opened the 2013 disk (see Appendix 9), they realized the files, although labeled as 2013, they were the 2012 records (see AOC 40 CFR 68.95(a)(2)). PAR has developed an emergency operations procedure, which includes procedures for informing the public and local emergency response agencies about accidental releases. PAR stated that they are in communication with the Local Emergency Planning Committee (LEPC), however when Debbie and I called the Jefferson County LEPC prior to the inspection on August 4, 2014, they did not have the Manager Health, Safety, and Emergency Response as the Emergency Contact. The Manager Health, Safety, and Emergency Response reported that Motiva is a member of the Sabine Neches Chiefs Association that meets monthly, and Motiva also coordinates with the Jefferson County LEPC which meets every other month. He explained that although he has been the Manager of Health, Safety, and Emergency Response since the former Manager Health, Safety, and Emergency Response left 12/1/13, he had not attended any of the meetings of either organization. The current Manager Health, Safety, and Emergency Response also explained that Motiva Fire Chief, had only been in his present position for 2 weeks, although he had been a member of the Motiva Fire Department for 3 years. The Manager Health, Safety, and Emergency Response clarified that Motiva did not have a spreadsheet for the 2013 fire extinguisher annual audits. PAR uses an electronic system that is used to quickly send notification to surrounding facilities and municipalities. Subpart G - Risk Management Plan 40 C.F.R. 68.150 Submission - I reviewed PAR's RMP submitted on July 11, 2011, and noted that the Executive Summary section included the elements as required by 40 C.F.R. 68.155. On July 31, 2014, at 9 Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 4:06 PM, I attempted to contact the Emergency Contact from the RMP, Manager Health, Safety, Emergency Response, at the listed phone number (409) 989-7632. I got a fax machine answer. On August 4, 2014, at 9:15 AM, I talked to an Administrative Assistant in the General Managers office. She stated that the former Manager of Health, Safety, and Emergency Response was no longer with the facility. On August 14, 2014, Debbie Ford and I met with the Process Safety Manager and PSM / PHA Specialist to discuss the RMP submittal. The PSM / PHA Specialist confirmed that the former Manager Health, Safety, and Emergency Response had transferred from the facility on 12/1/13. This was confirmed in an e-mail from Motiva's Human Resources Department dated 8/11/14 (see Appendix 3). The current Manager Health, Safety, and Emergency Response is now the Emergency Contact for the facility. 40 C.F.R. 68.195 Required corrections - Beginning 6/21/04, owners or operators are required to submit a correction within one month of any change in the Emergency Contact information, specifically name, title, telephone number, 24-hour telephone number, or e-mail address. As discussed in 68.95 and 68.150 above, Manager of Health, Safety, and Emergency Response left the PAR 12/1/13 and Motiva did not submit a correction to their RMP by 12/31/13 as required (see AOC 40 C.F.R. 68.195(b)). Section III - AREAS OF CONCERN 1. 40 CFR 68.65(d)(1)(ii) Process safety information: (d) Information pertaining to the equipment in the process. (ii) Piping and instrument diagrams (P&ID's); PAR's PSI did not contain accurate P&IDs for the VPS5 Unit in the following areas: 1) the Heaters 3 and 4 transfer lines 2) the wet gas inlet to the combined wet gas cooler, and 3) in the combined wet gas cooler outlet in the Saturates Gas Plant. 2. 40 CFR 68.75(a) Management of Change: MOC# M20132748-001 was not completed in its entirety when it was approved. 3. 40 C.F.R. 68.79 Compliance audits: The intent of these audits are to provide opportunity for chemical accident prevention program improvement. PAR provided the last two RMP audits for review as discussed above. The audit reports were much abbreviated compared with audits at other refineries. It was difficult to determine the actual scope of the audit. It was not clear from the audit reports that the personnel most familiar with the processes were part of the audits. 4. 40 CFR 68.95(a)(2) Emergency response program: The owner or operator shall develop and implement an emergency response program for the purpose of protecting public health and the environment. Such program shall include the following elements: (2) Procedures for the use of emergency response equipment and for its inspection, testing, and maintenance. Motiva has not adequately implemented its procedures for inspection, testing, and maintenance of emergency response equipment, specifically fire extinguishers, hoses, and fire trucks, as required by 40 CFR 68.95(a)(2). 10 Motiva / Port Arthur Refinery Inspection Date 08/11-14/2014 5. 40 CFR 68.195(b) Required corrections: Emergency contact information-- Beginning June 21, 2004, within one month of any change in the emergency contact information required under 68.160(b)(6), the owner or operator shall submit a correction of that information. The former Manager Health, Safety, and Emergency Response left the PAR 12/1/13 and Motiva did not submit a correction to their RMP by 12/31/13 as required by 40 CFR 68.195(b). Section IV - FOLLOW UP PAR updated their RMP on August 15, 2014, to reflect the change in emergency contact information listing the existing Manager Health, Safety, and Emergency Response as the Emergency Contact. With this update, PAR also corrected some of their RMP process unit descriptions. Section V - LIST OF APPENDICES Appendix 1 - Photo Log -photos taken 08/11-14/2014 (CBI) (not included in published version of the report) Appendix 2 - Opening conference sign-in sheet Appendix 3 - e-Mail dated 8/11/14 from Motiva Human Resources providing transfer date for Emergency Contact change (CBI) (not included in published version of the report) Appendix 4 - 2013 Preventative Maintenance form for Ladder 1 Big T fire truck Appendix 5 - Fire Department Module 2578 - Fire Extinguisher annual 41 point inspection procedure Appendix 6 - Fire Extinguisher Yearly Audit Records - sample records Appendix 7 - Fire Department Module 2580 - Monthly Fire Extinguisher Inspection Maintenance Procedure Appendix 8 - Monthly Fire Extinguisher Inspections - B Shift Alky Unit - selected records Appendix 9 - Hose inspection records - 2013 report containing 2012 inspection records Appendix 10 - Monthly Fire Extinguisher Inspections - Boiler Room - selected records Appendix 11 - Monthly Fire Extinguisher Inspections - MPU Unit - selected records Appendix 12 - Monthly Fire Extinguisher Inspections - DCU2 Unit - selected records Appendix 13 - MOC# M20132748-001 (CBI) (not included in published version of the report) Confidential Business Information (CBI) Appendixes (not included in published version of the report) 11