Document ba65ND8kGqpk2RyxQL8kD80k3

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 155 Seattle, WA 98101 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION Clean Air Act - Section 112(r) Risk Management Program and EPCRA 312 Tier II Facility Inspection Report FACILITY INFORMATION: Name: Kiva Energy- LP Terminal, LLC Washougal Physical Address: 701 South 28th Street, Washougal, WA 98261 Phone Number: (209) 823-8005 Latitude/Longitude: 45.572722 / -122.342528 RMP Facility ID# 1000 0019 0964 FRS ID#: 110023012862 EJ Concerns: Yes (Above 80%) CONTACT INFORMATION (RMP Implementation): Name: Darren Pahl Phone Number: (209) 351-7512 E-mail: dpahl@kivaenergy.com EMERGENCY CONTACT INFORMATION: Name: Ed Reinhardt Phone (24-hr): (260) 899-7829 E-mail: ereinhardt@kivaenergy.com Website: www.kivaenergy.com TRIP DETAILS: Inspection Date: Inspection Time: Inspectors: March 3, 2023 0900 hours through 1120 hours Mhara Coffman, US EPA Region 10, Lead RMP Inspector in Training Edward Johannes, US EPA Region 10 SEE Grantee, RMP Inspector Erin Williams, US EPA Region 10, EPCRA Coordinator Terry Garcia, US EPA Region 10 SEE Grantee, RMP Inspector Lisa Graves, Weston Solutions, Inc., EPA START Contractor DATE AND PROGRAM LEVELS OF SUBMITTED RMP: Initial Submission Date: March 3, 2005 Date of Latest Update: September 21, 2021 Process (Program 1, 2, 3) as reported in RMP: May 19, 2023 Page 1 of 5 Process ID 1000119162 Description LPG Storage Terminal Process Chemical ID 1000149025 NAICS Code 42471 Program Level 3 Chemical Name CAS Number Propane (74-98-6) Quantity (lbs) 220,806 PURPOSE: The purpose of this inspection was to determine whether this facility is in compliance with Section 112(r) of the Clean Air Act (CAA) and Title 40 Code of Federal Regulations (CFR) Part 68, Chemical Accident Prevention Provisions. The facility has been previously inspected in the past 5 years: No Yes If Yes, Date of Last Inspection: The facility is High Risk: Joint EPCRA inspection: No Yes No Yes CAA Title V Air Permit: Does the facility have a CAA Title V Permit? If Yes, Permit Number: No Yes RELEASE/ACCIDENT HISTORY: Did the facility have a reportable release in the past 5 years? If Yes, Date and Description of the Release: No Yes EPCRA TIER II REPORTING: Did the facility submit the 2022 Tier II report to the SERC? If Yes, Date the Tier II was submitted: 2/3/2023 If No, calendar year of the most recent Tier II: No Yes Did the facility submit a Tier II to the LEPC and local fire department? No Yes If Yes, Date the Tier II was submitted: 2/14/2023 INSPECTION ENTRY: Mhara Coffman led the inspection entry. The EPA Inspection Team (EPA) team met with Darren Pahl at the Kiva Energy - LP Terminal, LLC facility in Washougal, Washington. The team arrived at the facility at 0855 and was joined by the following facility personnel: Ed Reinhardt Les Gleaves Darren Pahl Name Title Terminal Operator Terminal Operations Manager Director Was a state/county/or local emergency representative present? If Yes, Name and Title of Representative: The facility is a first responder: If No, Responding Agency: Washougal Fire Department No Yes No Yes Page 2 of 5 EPA met facility representatives outside the office space, due to limited space for all participants. Lead Inspector Mhara Coffman made introductions, provided a summary of the risk management program (RMP), and explained the purpose of the visit. Each EPA Inspector presented his/her credentials. should be taken during the site tour. Ed Reinhardt and Les Gleaves gave a brief description of the facility, operations, and personal protective equipment required for the tour. Prior to the inspection, EPA sent a certified notice of inspection letter to the facility informing them of the CAA Section 112(r)(6)(L) requirement that facility employees and employee representatives (such as a union representative) have the right to participate in the RMP inspection, and that a copy of the letter must be provided to the employee representative(s) and the letter posted in a manner accessible to employees in the facility. The facility is unionized: If Yes, Name of Union: No Yes An employee representative present during the facility visit: If Yes, Name/Title: Ed Reinhardt, Terminal Operator No Yes GENERAL INFORMATION: The facility is regulated under the RMP as a Program Level 3 facility and is owned and operated by Kiva Energy. This facility is a Liquefied Petroleum Gas (LPG) bulk terminal storage location for resale to retail propane dealers. The facility consists of two 30,000-gallon aboveground storage tanks (ASTs) holding approximately 220,806 pounds each of LPG. The facility receives propane in railcars, transfers the propane to one of two pressurized propane tanks, and ships the LPG off-site with transport trucks. The only regulated substance at the facility site is LPG. The facility has two processes for the transfer of LPG products. One process transfers LPG from a stationary pressure tanker railcar to the facility ASTs. The other process transfers LPG from the AST to a retail LPG transfer truck. Both LPG processes integrate manual and automatic emergency shutdown equipment. There is one full-time employee, who is the terminal operator for the site. ON-SITE OBSERVATIONS: The facility tour was conducted from approximately 0922 to 0954. Facility representative Ed Reinhardt escorted EPA and other facility personnel during the inspection, and EPA observed and inspected both LPG transfer systems and their associated workflows. Shortly after the facility tour Ed Reinhardt left the remaining inspection review due to illness. The transfer of LPG from railcar to AST is initiated from a stationary pressure tanker railcar (photo 1) from a rail tower transfer loading station (photo 2). EPA noted the loading station product lines as rusty and deteriorated (photo 3). The LPG flow gauges are color coded to show the transfer of liquid (red gauge) and gas (yellow gauge) products (photo 4). The system has a flammable gas detector (photo 5) and a built-in hydrostatic release valve (photo 6). The transfer of product is powered through compressors and vane pumps (photo 7). Product lines are labeled with directional flow arrows and inspectors noted some of the product lines have rust deterioration (photo 8). Two product lines had UT Checkpoint markers for pipe density testing (photo 9). Page 3 of 5 Two ASTs (commonly referred to as 10). Only one of the two ASTs are labeled with a tank number (Tank 1 is left facing). Both ASTs are clearly labeled with universal placards for flammable gas (photo 11). Both ASTs rest in concrete saddles and are secured in place with tank straps. EPA noted weathering on the concrete saddles and rust below the ASTs (photo 12). The transfer of LPG from an AST to a retail transfer truck is initiated once a driver logs into the Tecalemit Control Panel system (photo 13). A driver will access the system through a touch panel interface (photo 14) inside of the entrance gate. A facility billboard communicates operating procedures to drivers visiting the facility (photo 15). The facility is equipped with three security cameras for 24-hour surveillance. Once a driver has checked into the facility, they park in the fueling area for the LPG transfer. A green light signal (photo 16) near the Tecalemit panel will verify that the truckload is grounded. The fill meter will track the quantity of LPG dispersed and create a ticket recording the quantity received by the driver (photo 17). An unlabeled emergency shutoff mechanism is situated adjacent to the meter (photo 17). The (photo 18) that, in the event of a system failure, will automatically shut off the flow of LPG. In addition, the facility has a second fueling area for smaller transfer trucks, called bobtails (photo 19). The facility has an emergency action plan in the event of a release. Other safety features observed during the inspection were the ecology blocks surrounding the LPG transfer systems, fire extinguishers (photo 20), a windsock (photo 21), and two crash gates with emergency exits (photo 22). The photographs that were taken at the facility are included in Attachment A to this report. After touring the RMP-covered process areas at Kiva Energy, the inspection team split up in vehicles and the facility office space review the RMP documentation. Upon completion of the document review, EPA provided a debriefing to Les Gleaves and Darren Pahl. INFORMATION COLLECTED FROM FACILITY: 1. Emergency Action Plan Appendix A Map 2. Washougal Washington U.S.A. LPG Storage Terminal Process Flow Diagram 3. Les Gleaves, Kiva Energy Business Card AREAS OF CONCERNS ADDRESSED IN CLOSING CONFERENCE: 1. The facility Hazard Assessment is missing various calculations in the documentation for the offsite consequence analysis parameters. [68.20-68.42]. Kiva Energy was unable to provide documentation for the worst case scenario and alternative release scenario for the LPG process. 2. The facility did not document Process Hazard Analysis (PHA) findings and recommendations are resolved in a timely manner, what actions are to be taken, and complete actions as soon as possible for the 2019 PHA. [68.67(e)] 3. The facility has not promptly determined and documented an appropriate response to each of the findings for the 2018 Compliance Audit and documented that deficiencies have been corrected. [68.79(e)] Page 4 of 5 DOCUMENTS REQUESTED NOT INCLUDED IN REPORT: The following documents were requested during the inspection but are not included in this report. These documents will still be reviewed to determine compliance with Section 112(r) of the CAA. 1. Copy of Tier II submittal to LEPC and local fire department. 2. RMP and COMP parameter printout 3. Worst Case Scenario maps 4. Summary description of Worst Case and Alternative Case 5. Initial Process Hazard Analysis from 1999 INSPECTION REPORT CERTIFICATION: This is to certify that I, Mhara Coffman, was the lead inspector at this facility and that I have verified the accuracy of the observations in this inspection report: Inspector Signature RMP Coordinator/Approval EPCRA Coordinator/Approval Land Enforcement Section Chief/Approval Page 5 of 5 Site Name: City, State: Photographer: File Photo 1.jpg Photo 2.jpg Photo 3.jpg Photo 4.jpg Photo 5.jpg Photo 6.jpg Photo 7.jpg Photo 8.jpg Photo 9.jpg Photo 10.jpg Photo 11.jpg Photo 12.jpg Photo 13.jpg Photo 14.jpg Photo 15.jpg Photo 16.jpg Photo 17.jpg Photo 18.jpg Photo 19.jpg Photo 20.jpg Photo 21.jpg Photo 22.jpg Kiva Energy LP Terminal, LLC Washougal Washougal, Washington Lisa Graves Photo Layout ID 1 2 3 4 5 6 7 8 9 11 11 12 13 14 15 16 17 18 19 20 21 22 Date 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 3/3/2023 Time Description 9:42 AM Stationary Railcar for Odorized Liquid Petroleum Gas (LPG) 9:43 AM Rail Towers for Railcar LPG Transfer 9:50 AM Rust on Product Transfer Lines 9:50 AM Color Coded Liquid (Red) and Gas (Yellow) LPG Valves 9:52 AM Flammable Gas Detector 9:51 AM Hydrostatic Release Valve 9:31 AM Compressors and Vane Pumps 9:52 AM Rust on LPG Transfer Line 9:52 AM UT Checkpoint for Pipe Density 9:32 AM LPG Above Ground Storage Tanks (ASTs) 9:34 AM Release Valve at Top of LPG Tank and Universal Placards for Flammable Gas 9:33 AM Weathered Tank Saddle Below the AST 9:29 AM Truck Driver Invoice System and Facility Power Supply 9:29 AM Tecalemit Control Panel 9:30 AM Facility Communication Billboard for Truck Drivers 9:29 AM Green Light Signal to Verify Truckload is Grounded 9:32 AM Fill Meter and Ticket Printer Station 9:42 AM Fill Station with "Smart Hose" 9:42 AM Fill Station for Small Transfer Trucks 9:30 AM Ecology Block Barricade for LPG Transfer System and Fire Extinguisher 9:30 AM Facility Windsock 10:56 AM Crash Gate and Emergency Exit