Document ga98q3k0JX3q3ambRGBeLd5D9

EPA Inspection Report - Page 1 of 237 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 Contacts: FRS Number: Identification/Permit Number: M edia Number: NAICS: SIC: Facility Representatives: EPA Inspectors: State lnspector(s): Title: Author: ..C..1.J. C1J Subject: "0 ..C..1.J. Q) ~ Keywords : EPA Lead Inspector Signature/Date 11/20/2013 Air Clean Air Act {CAA), Title V, State Implementation Plan (SIP), New Source Performance Standards (NSPS), National Emission Standard for Hazardous Air Pollutants (NESHAP), Risk Management Plan (RMP) Regency Field Services, LLC Keystone Gas Plant 6297 CR 301 Kermit, TX 79745 P.O. Drawer R Kermit, TX 79745 Winkler County Tommy Johnson I Plant Manager Tommy.Johnson@Regencygas.com John David Rider I PSM/RMP Manager John.rider@regencygas.com 110015744550 Title V: Site Operating Permit 0 -2940; RMP 1000 0016 2628 AFS # 48-495-00006 486210 {Pipe line Transportation of Natural Gas) 211112 (Natural Gas Liquid Extraction) 4922 (Natural Gas Transmission), 1321 {Natural Gas Liquids) Tommy Johnson Mary Valencia Kelly Jamerson Clarence E. Rasco Richard Dansby Debbie Ford Clint Rachal Amanda Ferguson Dominique Duplechain None Plant Manager Specialist Env. Permitting Director- North Assets Env. Compliance Coord. PSM Specialist Enf. Officer/Inspector Enf. Officer/Inspector Enf . Officer/Inspector Enf. Officer/Inspector (817) 302-9854 {432) 631-2344 {c) {817) 302-9780 {432) 940-1939 {c) (817) 302-9782 (575) 390-6032 (432) 923-2187 {214) 665-7235 {214) 665-6474 {214) 665-8420 {214) 665-7484 Regency Field Services Keystone Gas Plant Kermit W inkler County TX US EPA Region 6 Compliance Assurance and Enforcement Division Dallas TX Inspection Report Clean Air Act CAA Risk Management Plan RMP 112r 112{r) General Duty Clause GDC State Implementation Plan SIP Title V New Source Performance Standards NSPS National Emission Standard for Hazardous Air Pollutants NESHAP Air Taxies Energy Extraction Oil and Gas a_/~ Debbie S. Ford s~ I j ;;l<-f/; y Date 6ENFORM-019-R3 (11/14/2013) EPA Inspection Report - Page 2 of 237 EPA Inspection Report - Page 3 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 the indirect parent of Regency Field Services, LLC (see Appendix 5). According to Mr. Johnson, the design capacity of the gas plant is 125 million standard cubic feet per day (MMSCFD), but it averages operations at 85-95 MMSCFD. Mr. Johnson became Plant Manager at Keystone in July 2011. Mr. Johnson provided a process flow diagram (see Appendix 4) and reviewed current operations at the facility. The Keystone Gas Plant receives gas streams from four inlet pipelines: 600 pound (lb) high-pressure gas 300 lb inlet gas 100 lb inlet gas low-pressure (10-19 lbs) inlet gas. The facility uses various compressors throughout the site to boost pressures of the gas to meet processing and pipeline pressures. The facility also has pigging receivers on the 600 lb and 300 lb inlet pipelines. Keystone processes the condensate in an onsite condensate stabilizer to remove lighter components and then routes these gases to the low-pressure inlet gas stream. Keystone stores the condensate in pressurized tanks before shipment offsite via truck. The facility uses an H2S analyzer to monitor the sulfur content of the inlet gas. If the inlet gas has more sulfur content than can be handled by the SRU, the gas is routed to the Acid Gas Flare (FL-1). The inlet gas is typically 1.25% acid gas components: approximately 75-80% carbon dioxide (CO2) and 20-25% hydrogen sulfide (H2S). The acid gas is routed through the Amine Unit to remove the CO2 and H2S. The rich amine is regenerated in the amine regenerator and the acid gas is routed to the Sulfur Recovery Unit (SRU), which consists of 4 beds: A and D use a SelectOx process; B and C use the Claus process. Molten sulfur collects in the sulfur pit prior to offsite shipment via truck. The SRU has a sulfur production capacity of 20 long tons (LT) per day but averages operation at 12 LT/day. The Amine Unit's outlet gas containing less than 1 ppm H2S content is routed through the glycol dehydrator and the molecular (mole) sieve dehydrators to remove moisture from the gas stream prior to the separation stage in the Cryogenic Plant. The mole sieve dehydrators consist of three beds: two are online and the third is regenerating. The Cryogenic Plant separates gas liquids from methane. The methane stream, or residue gas, is shipped via pipeline to El Paso Energy (aka Kinder Morgan) or Trans Western, which is owned by Energy Transfer. The remaining liquids, consisting of hydrocarbons C2 and higher, is called Y-grade and is shipped via pipeline to Enterprise Products. PERMIT HISTORY Permit or PBR number PBR 36121 (exemption registration) PBR 36121 PBR 73140 PBR 90277 NSR Permit 2724 Date or Regulation 9/8/97 (30 Texas Administrative Code (TAC) 106.183, 106.492, 106.512) 12/18/09 (30 TAC 106.512) 30 TAC 106.492 30 TAC 106.492 3/8/04 Description 2 new Caterpillar engines (C23, C24); Glycol Heater No. 3; Therminol Heater No. 2; Ellenberger Emergency Flare Caterpillar engines C26, C27, C28 Grandfathered sources C1-C10, C13-C18, C20; High Pressure Flare Existing process flare as emergency flare. SRU/ Amine/ Glycol Unit/ AG Flare, C21, C22, 3 EPA Inspection Report - Page 4 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 General Operating Permit (GOP) O-769 Site Operating Permit (SOP) O-2940 Voided 9/17/13 9/17/13 LDAR Voided upon issuance of SOP Includes case-by-case Compliance Assurance Plan (CAM) for SRU catalytic incinerator Section II - OBSERVATIONS During the plant tour, Clint Rachal used an infrared camera, FLIR Model GF320 Serial Number 44401279, to detect hydrocarbon emissions at the facility. I carried an MSA Sirius Multigas Detector with Photoionization Detector (PID) Serial Number A3-12746 to detect hydrogen sulfide (H2S), lower explosive limits (LEL), oxygen (O2), and volatile organic compounds (VOCs). The Sirius was calibrated at the hotel on the morning of the Keystone inspection (see Appendix 7). Note: When the data was downloaded from the instrument log, I noted that the time in the data log was approximately 2 hours later than the actual time the instrument was operated. This was the first inspection which used the MSA Sirius since it was purchased by EPA. The instrument time was set to current time after the inspection. Production Data - Ms. Valencia provided the following production data for Keystone Gas Plant: 2011 2012 2013 INLET (MCF) 37,131,303 41,020,923 32,680,237 RESIDUE (MCF) 26,042,630 29,326,436 21,706,759 NGL (BBLS) 3,864,618 4,218,528 3,286,769 CONDENSATE (GALLONS) 9,863,696 10,525,539 8,408,191 SULFUR (LONG TONS) 1,205 2,768 2,480 Emission Point Review: I.D. Description C1 Clark BA-6 S/N 36067 1200 HP Installed: 1971 C2 Clark BA-6 S/N 36068 1200 HP Installed: 1971 C3 Clark BA-6 S/N 36069 1200 HP Installed: 1971 C4 Clark BA-6 S/N 36070 1200 HP Installed: 1971 C5 Clark BA-6 S/N 36071 1200 HP Installed: 1971 C6 Clark HBA-6 S/N 36072 1320 HP Installed: 1971 C7 Clark HBA-6 S/N 36073 1320 HP Installed: 1971 C8 Clark BA-6 S/N 36075 1200 HP Installed: 1971 C9 Clark HBA-6 1320 HP Service Inlet compression 300 lb service Inlet compression 300 lb service Inlet compression 300 lb service Inlet compression 100 lb service Inlet compression 100 lb service Inlet compression 100 lb service Inlet compression 100 lb service Inlet compression Observations Not operating. Operating. Not operating. Operating Operating Not operating. Operating. Out of service. Inlet compression Out of service. 4 EPA Inspection Report - Page 5 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 I.D. Description S/N 36074 Installed: 1971 C10 Clark BA-6 1200 HP S/N 36076 Installed: 1971 C17 Clark HBA-6 1320 HP S/N 36213 Installed: 1971 C18 Clark HBA-6 1320 HP S/N 36253 Installed: 1971 C20 Cooper Bessemer GMW V-250-8 2700 HP S/N 47619 Installed: 1971 C21 Cooper Bessemer GMW V-275-8 3200 HP S/N 48257 Installed: 1971 C22 Cooper Bessemer GMW V-275-8 3200 HP S/N 48258 Installed: 1971 C23 Cat G3608-8 2350 HP S/N 4WF00067 Installed: Jul 1997 C24 Cat G3612-12 3530 HP S/N 1YG00118 Installed: 8/4/09 (not subject to NESHAP Subpart ZZZZ since replacement in-kind) C25 Clark HRA6 660 HP S/N 21281 Installed: 1971 C26 Caterpillar G3516 TALE 4SLB 1340 HP S/N WPW02715 Mfg date: Jan 2009 Oxidation catalyst (CO reduction 93%) C27 Caterpillar G3516 TALE 4SLB 1340 HP S/N WPW02697 Mfg date: Dec 2008 Oxidation catalyst (CO reduction 93%) C28 Caterpillar G3516 TALE 4SLB 1340 HP S/N WPW02751 Mfg date: Jan 2009 Oxidation catalyst (CO reduction 93%) FL-1 Acid Gas (AG) Flare FL-2 High Pressure (HP) Flare FL-6 Low Pressure (LP) Flare S-1 SRU Catalytic Incinerator (D Bed) CAM requirements: sulfur dioxide (SO2) Continuous Emission Monitoring System (CEMS): SO2 hourly average 182.88 lbs/hr Posey Pond (sump after Acid Gas Knockout Drum in SRU) LTN BN-WWTK Produced Water Tank 210 bbl LTS BS-WWTK Produced Water Tank 210 bbl *see discussion under LP Flare below. Service Inlet compression Recompression Recompression Inlet compression Recompression Recompression Inlet compression (LP system) Inlet compression (LP system) Reinjection Refrigeration Refrigeration Refrigeration Observations Out of service. Not operating. Not operating. Not operating. Operating. Operating. Operating. NSPS Subpart KKK Operating. Operating. NESHAP Subpart ZZZZ NSPS Subpart JJJJ Operating. NESHAP Subpart ZZZZ NSPS Subpart JJJJ Operating. NESHAP Subpart ZZZZ NSPS Subpart JJJJ Operating. Visible emissions observed using FLIR camera. Operating. No flame present * Approximately 10% visible emissions (white) observed. (see SRU below) Visible emissions observed with FLIR camera Visible emissions observed with FLIR camera Visible emissions observed with FLIR camera 5 EPA Inspection Report - Page 6 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Compressors - Caterpillar engines C26, C27, and C28 replaced engines that were damaged in a fire at the facility in 2009. The new engines are 4-stroke, lean burn (4SLB) natural gas-fired engines and are subject to NESHAP Subpart ZZZZ and NSPS Subpart JJJJ. Requirement Date of Construction (commenced) Initial Notification (per 40 CFR 63.6645(c) due no later than 120 days after subject to Subpart ZZZZ) Actual startup date (notification date - due within 15 days of actual startup) Installation date Performance testing - NESHAP initial (w/in 180 days of startup) semi-annual NSPS 8760 testing C26 11/3/09 1/20/10 (due 3/3/10) 3/16/10 (3/30/10) Apr. 2010 6/24/10 12/21/10 5/24/11 11/22/11 5/23/12 11/12/12 5/14/13 12/19/13 6/24/10 5/24/11 5/23/12 5/14/13 C27 9/10/09 1/6/10 (due 1/8/10) 1/24/10 (1/28/10) Dec. 2009 4/28/10 10/26/10 5/24/11 11/22/11 5/23/12 11/12/12 5/14/13 12/19/13 6/24/10 5/24/11 5/23/12 5/15/13 C28 9/10/09 1/6/10 (due 1/8/10) 1/24/10 (1/28/10) Dec. 2009 5/11/10 11/09/10 5/24/11 11/22/11 5/31/12 11/12/12 5/5/13 12/19/13 6/24/10 5/24/11 5/31/12 5/15/13 Keystone noted on their performance testing reports that after 2 semi-annual compliant tests, they could test annually, but since they had deviations on temperature records, they were continuing with a semi-annual performance test schedule. Keystone noted in the two Title V Deviation Reports reviewed (see Appendices 20 and 21) that the Continuous Monitoring System did not record the temperature as follows: Reporting Period Reporting Period Compressor 7/1/12-12/31/12 1/1/13-6/30/13 C-26 93 hours (2.39% of operating time) 262 hours (6.54% of operating time) C-27 107 hours (2.53% of operating time) 270 hours (6.6% of operating time) C-28 103 hours (2.47% of operating time) 261 hours (7.8% of operating time) I have requested information about the cause of these deviations from Ms. Valencia and will review when I receive the requested information. Keystone self-reported in the Title V Deviation Report for the period 1/7/13 - 7/6/13 that they failed to submit the NESHAP Subpart ZZZZ Semi-Annual Deviation Report by the due date of 7/30/13 (within 30 days after the reporting period ended on 6/30/13) (see AOC # 1). Emission Events - Prior to the inspection, I reviewed incidents reported to the Texas Commission on Environmental Quality (TCEQ) Excess Emission Reporting System and Emission Inventory records for 2011. The Keystone Gas Plant experienced the following numbers of events: 6 EPA Inspection Report - Page 7 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Reportable Non-reportable* 2013 123 89 2012 99 127 2011 86 n/a 2010 33 n/a *from Title V Deviation Report for 2H 2012 and 1H 2013. Only represents half of the reporting year. The causes of the events reviewed often were one or more of the following categories: Pigging caused one or more compressors to shut down, thus causing flaring Compressor #23 shut down for a variety of reasons, causing flaring Field units shut down, causing flaring Amine Unit shut down, causing the plant to go sour, thus requiring the plant to flare until the gas could be treated SRU shut down due to high temperatures in a bed or the auxiliary burner would not light Chiller issues The AG Flare experienced some significant emission events in 2011: TCEQ STEERS Event Begin SO2 number Date Event End Date Days (lbs) 154347 5/10/11 6/24/11 46 1,790,000 156621 7/9/11 7/10/11 2 55,700 156718 7/12/11 9/9/11 60 2,700,000 159465 9/18/11 10/21/11 34 1,540,000 161142 10/29/11 10/30/11 2 125,000 161775 11/8/11 3/28/12 142 11,600,000 SO2 (tons) 895 27.85 1,350 770 62.5 5,800 SO2 avg (lbs/hr) 1,621 1,160 1,875 1,887 2,604 3,403 Due to the large number of events reported to the STEERS database, I have not evaluated all of the events from 2010-2013. I reviewed the 2011 events since the 2011 Emission Inventory reported 9,900 tons of SO2 in upset emissions from the AG Flare. I am noting that the remaining events should be reviewed as a follow-up to this inspection. Since the October 2013 turnaround, the facility has continued to have flaring events at the AG Flare (see Appendix 18): TCEQ STEERS Event Begin Event End SO2 SO2 SO2 avg number Date Date Days (lbs) (tons) (lbs/hr) 189210 10/14/13 10/22/13 8 150,000 75 781 Producers were informed to shut in gases to the plant for the duration of the shutdown. 190405 11/4/13 11/5/13 2 33,200 16.6 691 Computers in the Distributed Control System shutdown. No uninterrupted power supply for operating the plant. I am noting this for follow-up. 7 EPA Inspection Report - Page 8 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 TCEQ STEERS Event Begin Event End SO2 SO2 SO2 avg number Date Date Days (lbs) (tons) (lbs/hr) 190938 11/17/13 11/18/13 2 31,900 16 664 Heaters shutdown in the SRU due to a false low oil indicator. And the auxiliary burner would not light. * 191652 12/4/13 12/5/13 2 92,100 46 1,918 Auxiliary burner went down and could not relight it.* *According to Mr. Johnson, during the October turnaround, Keystone upgraded the burner and ignition system on the auxiliary burner to improve reliability. I am recommending to follow-up on the SO2 emissions from the facility to ensure that the Keystone Gas Plant has not caused an exceedance of the National Ambient Air Quality Standard for SO2 or PM2.5. Flares - The facility uses three flares: - AG Flare (Emission Point FL-1) is an unassisted flare that combusts acid gases when the SRU is down or if the facility inlet gas is too high in sulfur that the SRU cannot properly treat the gas or if the residue gas is off-spec (greater than 4 ppm sulfur) and cannot enter the sales pipeline. The AG Flare also combusts the non-condensable stream from the Glycol Dehydrator reboiler. Site Operating Permit (SOP) O2940 issued 9/17/13 indicates that its operation is authorized under New Source Review (NSR) Permit 2724 issued 3/8/04. The flare is subject to the requirements of 40 CFR 63 Subpart A and 40 CFR 60 Subpart A. I requested testing records for the AG flare, but at the time of this inspection report had not received a response from Keystone. - HP Flare (Emission Point FL-2) is an unassisted flare that combusts the high pressure (600 lb) residue gas from within the plant when the sales meter shuts in the Keystone Gas Plant. - LP Flare (Emission Point FL-6) is an unassisted flare that combusts inlet gases to the plant from the low pressure (300 lb and less) pipeline when the facility compressors are shut down. SOP Permit O2940 indicates that the operation of the HP and LP Flares are authorized under 30 TAC 106.492 (see Appendix 10) which requires the flare to be equipped with a "continuously burning pilot or other automatic ignition system that assures gas ignition and provides immediate notification to appropriate personnel when the ignition system ceases to function." The facility uses indicator lights near the pipe rack for the AG and HP Flares. The indicator light for the LP flare is located on the control panel at the base of the flare and is only visible by walking or driving to the control panel (see AOC #2). When we observed the LP Flare with the FLIR camera, the flare was not lit (see AOC #3). We walked to the control panel and the indicator light was not on. Mr. Thompson opened the control panel and the power was off to the panel. He turned the switch on, but the power did not turn on. He walked to the flare base and reported that the entire ignition system was disassembled. Later, Ms. Valencia reported that the LP Flare had maintenance work on the ignition system performed during the turnaround in October (see Appendix 13). The systems could not be tested until the gas plant came back online. Subsequent to the inspection, Ms. Valencia supplied daily meter flow times and volumes to the LP Flare (see Appendix 11). As reported in a 1/10/14 e-mail from Ms. Valencia, LP Flare igniter system still was not operational. I will continue to follow up on this issue. It should be noted that Keystone reported several Emission Events to TCEQ when they routed emissions to the LP Flare, but no operator noted that the flare was not lit. Mr. Johnson stated that the operators observe the flare indicator lights on their 8 EPA Inspection Report - Page 9 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 daily plant walkthroughs. Subsequent to the inspection, Ms. Valencia provided the updated GRU Log Sheet in which the operators must document that the flares are lit. When we observed the AG Flare with the FLIR camera, we observed that the flare was operating, but we also observed unburned hydrocarbons trailing downwind for a significant distance. This was observed when the flare was operating with a minimal flow. As discussed above, the facility has experienced some flaring events with high quantities of SO2 emitted. I am recommending a follow-up to ensure that the flows to the AG Flare are within the design specifications of the AG Flare. Sulfur Recovery Unit (see Appendix 6 for SRU Flow Diagram) - According to Mary Valencia, the SRU is not subject to the LDAR monitoring program since the unit has not been modified or reconstructed to trigger applicability. Mr. Johnson reported that in early 2012, pneumatic controls of the SRU had been changed to programmable logic controls (PLC). Also, Mr. Johnson stated that during the plantwide turnaround October 14-21, Keystone changed a 10" inlet valve to a 14" inlet valve with an actuator, upgraded the auxiliary burner's ignition system and burner to improve reliability, and added more exchangers and condensers. At the time of the inspection, we observed emissions from the vent stack off the incinerator bed (D Bed). Mr. Johnson indicated that the goal was to have no visible emissions from the stack. He explained that Keystone had hired a consultant, Sulfur Experts, to evaluate their SRU about 10 days prior to our inspection. He stated that he had not received a report from the company, but there may be channeling through the D Bed which was affecting the efficiency of the unit. During the plant tour, the MSA Sirius Multigas Detector alarmed for volatile organic compounds (VOCs) when Clint Rachal observed emissions from multiple open-ended pipes (see Appendix 1 - Photo 3; Appendix 2 - Video MOV_2681.mp4) in an area known as the Posey Pond. Mr. Johnson explained that this was a sump after the acid gas knockout drum. The Keystone Gas Plant's operating permits do not reflect the three point sources observed during the inspection and Keystone does not report these emissions in their emission inventory reporting (see AOC #4). I also observed visible staining of the soil around the sump area. Ms. Valencia reported in the 12/4/13 e-mail that the sump had overflowed when the knockout drum was drained and that the soil had been removed since our visit. According to the flow diagram, the Posey Pond drains into the Bass Sump, and accumulated liquids pump into the Produced Water Tanks LTN and LTS. These appear to be the tanks BN-WWTK and BS- WWTK, respectively, which are described in the permit application as 210 barrel (bbl) waste water disposal tanks. During the plant tour, Clint Rachal detected visible emissions with the FLIR camera from the vent stack from each tank (see Appendix 1 - Photo 1; Appendix 2 - Video MOV_2678.mp4). Emissions from these tanks are authorized by 30 TAC 106.352, according to the permit application, which limits "total emissions, including process fugitives, combustion unit stacks, separator, or other process vents, tank vents, and loading emissions from all such facilities constructed at a site under this subsection shall not exceed 25 tpy each of SO2, all other sulfur compounds combines, or all VOCs combined...." (30 TAC 106.352(l)(2)). Since the facility called these tanks "produced water tanks" and we observed emissions from the tank vents, I have noted that there should be follow-up to determine actual emissions from the tanks. We discussed the emissions observed with the FLIR camera and the fact that the tank vents did not have a flame arrestor when electrical panels and truck loadout are located at the base of the tanks. Ms. Valencia noted in the 12/4/13 e-mail that Keystone is in the process of generating a work order to install a flame arrestor (Enardo valve) on each tank vent. During the inspection, I requested the last two Title V Semi-Annual Deviation Reports (see Appendices 20 and 21). During my review of these reports, I noted the following self-reported deviations for the SRU: 9 EPA Inspection Report - Page 10 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Reporting Period Reporting Period Requirement 7/7/12-1/6/13 1/7/13-7/6/13 Permit 2724 issued 3/8/04 - Condition 1 - One (1) 24-hour period* Eight (8) 24-hour periods* Maximum Allowable Emission Rate (MAERT) for the SRU Stack (Emission Point S-1) is 182.88 lbs/hr of SO2 (see AOC #5) Permit 2724 issued 3/8/04 - Condition 3 - Eleven (11) 24-hour Thirteen (13) 24-hour Minimum sulfur recovery efficiency is 95% periods* periods* (see AOC #6) *Keystone is reporting the deviations for the MAERT emission limit and the efficiency as a 24-hour period. Permit 2724 doesn't indicate that the lb/hr Emission Rate has a 24-hour averaging period and the formula for calculating efficiency is based upon lb/hr. I am noting these issues for follow-up. Leak Detection and Repair (LDAR) - The Keystone Gas Plant is an onshore natural gas processing plant and is subject to NSPS Subpart KKK for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. Keystone contracts their monitoring and some first attempt at repair for leaking components to TEAM Industrial Services in Midland, TX. At the time of the inspection I asked for copies of 2012-2013 Daily Work Records and Daily Calibration Forms provided to Keystone whenever TEAM was onsite. The Daily Work Record provides a summary of information such as names and identification numbers of technicians who were onsite, the serial numbers of instruments used that day, number of components monitored or remonitored, how many leaks were found, number of first attempts performed, and times in and out for the workers. The Daily Calibration Form is filled out for each TVA-1000 instrument used to monitor that day. Thus, if the Daily Work Record indicated that there were three technicians onsite, each with a TVA, there should be a corresponding Daily Calibration Form to document the calibration required by EPA Method 21. I reviewed the records provided (see Appendix 14) and Keystone only provided Daily Work Records and Daily Calibration Forms for 10/10/12 - 9/30/13. I noted in the Follow-up Section below that the additional records should be obtained from Keystone and reviewed. The number of components monitored by technicians per day seemed appropriate. There were some discrepancies noted: - The number of leaks in the LDAR report for October and November 2012 was one more for each month than was noted on the Daily Work Record sheets. - Missing Daily Calibration Forms for 1/16/13, 6/26/13, 7/22/13, 7/23/13, 9/30/13. - On the 2/13/13 Daily Work Record (see Appendix 15), there were 9 leaks documented, but they were not reported in the semi-annual report (see Appendix 16, see AOC #6). - Keystone did not provide any daily records for March 2013, but the report documented some pump leaks - No daily records for October 2013. - One of the Daily Calibration Sheets on 7/23/13 wasn't signed by the technician. - Technicians are drawing a line through the mid-day and end-of-day calibrations and drift. It is not clear if the technicians are performing calibration checks to quality-assure the monitoring data for the day. Technicians are instructed on the form to put "N/A" for Mid-Day and End-of-Day at appropriate Leak Definitions if NOT used for those periods, but they are not doing so. - There were several components that had been on the Delay of Repair portion of the report that were removed from Delay of Repair without a unit shutdown. - Determine what corrective action Keystone has implemented to prevent the shutdown of the DCS system in a power failure situation. 10 EPA Inspection Report - Page 11 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 As part of the inspection, I asked for a backup copy of the electronic database that TEAM uses to store monitoring data for the Keystone Plant. I received this from TEAM on 12/4/13. I have noted that this data should be analyzed for compliance with NSPS Subpart KKK requirements. Also, I have asked for a summary of units at Keystone that are subject to monitoring under the LDAR program. At this time, I have not received a reply. RMP OBSERVATIONS written by Dominique Duplechain Subpart A-General 68.12 General Requirements - Keystone submitted a single Risk Management Plan (RMP) which registered two covered processes Propylene (Refrigerant) and Natural Gas Liquids (NGLs) that are subject to Program 1 requirements. The latest RMP update, dated 8/16/2011, (see Appendix 22) identified two flammable chemicals, propylene (see Appendix 23) and NGL flammable mixture (see Appendix 24), that are above the threshold quantities identified in 68.130. In order to be eligible for Program 1, a facility must analyze the worst case release scenario and document that the nearest public receptor is beyond the distance to a flammable endpoint, complete a five year accident history, and ensure that response activities are coordinated with emergency planning and response agencies. At the time of the 8/16/2011 RMP update, the facility certified that the distance to the specified endpoint was less than the distance to the nearest public receptor and that it had no accidental release that caused offsite impact. At the time of the inspection, Keystone provided documentation on the Offsite Consequence Analysis (OCA) (see Appendices 22 and 25). The results of the analysis for both propylene and natural gas liquid flammable mixture indicated that the estimated distance to flammable endpoint was 0.3 miles at 1 psi overpressure. The OCA map did not clearly identify the facility, the point of release, or distance to endpoint. In an email dated 12/13/2013, Mr. David Rider, PSM/RMP Manager for Regency Energy Partners, provided a new OCA map which clearly identified the facility, point of release, public receptors, and distance to endpoint (See Appendix 29). It appears that the facility has public receptors within the distance to endpoint and is subject to Program 3 requirements. 68.12(b)(1) (see AOC # 8). In emails dated 12/4/13 and 12/5/13, Mr. Rider provided reports for two incidents: - 3/1/2009 incident (see Appendix 26): an employee used a metal bucket to shield a NGL leak from a valve which resulted in a fire and employee injuries. - 1/24/2011 incident (see Appendix 27): Unit #24's 2nd stage discharge piping experienced an internal explosion causing a gas release into the Caterpillar compressor building. The accumulated gas flashed injuring an employee and caused damage to the building. A key contributing factor was the failure to use purging and lock out/tag out procedures. Keystone rated this event as catastrophic. It appears the 3/1/2009 event which involved a release of NGL flammable mixture, a RMP process chemical held above a threshold quantity, and resulted in medical treatment for an employee should have been reported as part of the facility's five year accident history. 68.12(b)(2) (see AOC # 9). I reviewed EPA's Central Data Exchange to determine if any updates were submitted after 3/1/2009. No updates were submitted between 3/1/2009 and 8/16/2011. It appears that the facility did not correct the RMP submittal within six months of the date of the 3/1/2009 event as required by 68.195(a) (see AOC # 10). 11 EPA Inspection Report - Page 12 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 For the 3/1/2009 incident, it appears that Keystone failed to identify hazards associated with the leaking valve and leaking chemical, as well as, failed to minimize the consequences of the NGL release by using a metal bucket to shield the leak. 112(r)(1) (see AOC # 11). For the 1/24/2011 incident, it appears that Keystone failed to maintain a safe facility and did not the take the necessary steps to prevent the gas accumulation and release by failing to utilize purging and lock out/tag out procedures prior to and/or during start up. 112(r)(1) (see AOC # 12). Keystone provided its Emergency Response Plan (ERP) which was updated on 11/6/2013 (see Appendix 28). According to Mr. Dansby, the plan was coordinated with the Local Emergency Planning Committee (LEPC). The plan identified the LEPC contact information and listed contact numbers for Winkler County emergency response. Subpart B-Hazard Assessment 68.22 OCA parameters - The OCA documentation (see Appendix 22) for the worst case scenarios for natural gas liquids indicated the following: Vapor Cloud Explosion and estimated distance to 1 psi overpressure is 0.3 miles. The OCA documentation for the worst case scenarios for propylene indicated the following: Vapor Cloud Explosion, estimated distance to 1 psi overpressure is 0.3 miles, wind speed 1.5 meters/second, stability class F, and a temperature of 77F. Keystone provided no other documentation at the time of the inspection. 68.25 Worst-case release scenario analysis - Keystone performed a worst case analysis for propylene and NGL flammable mixture. See the above OCA parameters. 68.30 Defining offsite impacts-population - At the time of the inspection, Keystone could not provide any documentation which showed the point of the release at the center and radius determined by the distance to endpoint. The OCA map provided at the time of the inspection did not clearly identify the facility, point of release, public receptors, and distance to flammable endpoint. It appears that Keystone failed to appropriately determine its public receptors. 68.30(a) (see AOC # 13). 68.33 Defining offsite impacts-environment - At the time of the inspection, Keystone could not provide any United States Geological Survey maps or any data source containing USGS data to identify environmental receptors. It appears that Keystone failed to identify environmental receptors within the radius from release to endpoint. 68.33(a) (see AOC #14). 68.36 Review and update - Keystone provided the 2011 update which included a summary of the worst case scenario analysis. It is unknown if the OCA was reviewed at the time of the update. 68.39 Documentation - The OCA documentation for the worst case scenarios for NGL flammable mixture indicated the following: Vapor Cloud Explosion and estimated distance to 1 psi overpressure is 0.3 miles. The OCA documentation for the worst case scenarios for propylene indicated the following: Vapor Cloud Explosion, estimated distance to 1 psi overpressure is 0.3 miles, wind speed 1.5 meters/second, stability class F, and a temperature of 77F (See Appendix 22). Keystone provided no other documentation. The RMP executive summary indicates that the largest vessel with natural gas liquids was selected for the worst case scenario, but the summary does not mention any vessel containing propylene. The RMP submittal indicates that Keystone has two processes. It appears that Keystone failed to maintain offsite consequence analysis records for both processes which include: rationale for selection of worst case for each covered process, anticipated effect of 12 EPA Inspection Report - Page 13 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 controls and mitigation, documentation of release rate and duration of release, and data used to estimate population. 68.39(a-e) (see AOC #15). Subpart G Risk Management Plan 68.155 Executive Summary - I reviewed the Executive Summary in the 2011 RMP update (see Appendix 22). The description of the stationary source indicated that the facility receives natural gas with H2S and water removed. According to Mr. Dansby, the field handles sour gas. It appears that Keystone failed to accurately identify the type of gas handled at the stationary source. 68.155(b) (see AOC #16). The executive summary listed Southern Union Gas Services as the parent company with La Grange Acquisitions as the owner/operator. According to Mr. Rider, Southern Union Gas Servicer (SUGS) is now Regency Field Services LLC. The owner/operator is also Regency Field Services LLC. Mr. Rider indicated that corrections to the RMP were submitted to their third party. At the time of the inspection, Mr. Dansby indicated that Mr. Tommy Johnson, Plant Manager, was the emergency contact for the facility. The RMP lists Dwight Bennett as the emergency contact. Mr. Bennett is a current employee for Keystone but no longer in the same role. It appears that Keystone failed to correct the emergency contact information the RMP within one month as required by 68.195(b) (see AOC #17). Subpart D Program 3 Prevention Program Keystone is subject to the OSHA PSM standard. Based on the updated OCA map (See Appendix 29), it appears that the nearest public receptor is within the distance to a flammable endpoint. Program 3 requirements were not evaluated as a part of this inspection. Section III - AREAS OF CONCERN EEPI CLOSEOUT CONFERENCE At the closeout meeting with Mr. Thompson and Ms. Valencia, I discussed concerns with the produced water tanks and the fact that there was no flame arrestor on the vent pipes for the two tanks. I asked Ms. Valencia to provide documentation about the concentration of hydrocarbons coming from the tank. I have not received this information to date. I also discussed the H2S and VOC alarms at the Posey Pond. Finally, I discussed the LP Flare that had no pilot. At the time of the inspection, Clint reported that he observed emissions from the LP Flare with the FLIR camera, but after I observed the videos from the office, I determined that the emissions were carryover from the AG Flare. We left the facility at 5:20 pm. INSPECTION AREAS OF CONCERN EEPI Areas of Concern: 1. Keystone self-reporting that the company did not submit the NESHAP Subpart ZZZZ Semi-Annual Deviation Report by the due date of 7/30/13 as required by 40 CFR 63.6650. 2. Keystone has not designed the High Pressure Flare and Low Pressure Flare with ignition systems that provide immediate notification to appropriate personnel when the ignition system ceases to function as required by 30 TAC 106.492(1)(B) as referenced by page 30 of Site Operating Permit O-2940 issued 9/17/13. 13 EPA Inspection Report - Page 14 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 3. Keystone operated the Low Pressure Flare after the turnaround that ended 10/21/13 without a flame present as required by 40 CFR 60.18(c)(2) as referenced by page 17 of Site Operating Permit O-2940 issued 9/17/13. 4. Keystone did not receive New Source Review authorization for three emission points from the sump known as the Posey Pond located downstream of the Acid Gas Knockout Drum in the Sulfur Recovery Unit as required by 30 TAC 116.110(a)(1) and page 1 of Site Operating Permit O2940 issued 9/17/13. 5. Keystone self-reported nine (9) exceedances of the SRU Stack (Emission Point S-1) emission rate limit for the following 24-hour periods: 10/18/12, 2/15-16/13, 4/8/13, 4/16-17/13, 4/21-22/13, and 6/20/13. The emission rate is limited to 182.88 lbs/hr as required by Permit 2724 Condition 1 as referenced by GOP Permit O-0769 Condition (b)(7). 6. Keystone self-reported twenty-four (24) exceedances of the SRU sulfur recovery efficiency for the following 24-hour periods: 7/28/12, 8/16-17/12, 8/22/12, 10/13/12, 10/18/12, 11/7-8/12,12/23/12, 12/31/12-1/1/13, 1/16-18/13, 2/14-16/13, 3/13-14/13, 3/19-20/13, 3/24-26/13. The sulfur recovery must be at least 95% efficient as required by Permit 2724 Condition 3 as referenced by GOP Permit O-0769 Condition (b)(7). 7. Keystone's LDAR contractor, TEAM Industrial Services, documented 9 (nine) leaking components on the 2/13/13 Daily Work Record, but Keystone did not report any leaking components for the month of February in the Semi-Annual NSPS Subpart KKK Report for October 2012-March 2013 as required by 40 CFR 60.636(a). RMP Areas of Concern: 8. At the time of the inspection, Keystone provided documentation on the Offsite Consequence Analysis (OCA). The results of the analysis for both propylene and natural gas liquids flammable mixture indicated that the estimated distance to flammable endpoint was 0.3 miles at 1 psi overpressure. The OCA map did not clearly identify the facility, the point of release, or distance to endpoint. In an email dated 12/13/2013, Mr. David Rider, PSM/RMP Manager for Regency Energy Partners, provided a new map OCA which clearly identified the facility, point of release, public receptors, and distance to endpoint (See Appendix 29). It appears that the facility has public receptors within the distance to endpoint and is subject to Program 3 requirements. 68.12(b)(1) 9. It appears the 3/1/2009 event which involved a release of NGL flammable mixture, a RMP process chemical held above a threshold quantity, and resulted in medical treatment for an employee should have been reported as part of the facility's five year accident history. 68.12(b)(2) 10. It appears that the facility did not correct the RMP submittal within six months of the date of the 3/1/2009 event as required by 68.195(a) 11. In regards to the 3/1/2009 incident, it appears that Keystone failed to identify hazards associated with the leaking valve and leaking chemical, as well as, failed to minimize the consequences of the NGL release by using a metal bucket to shield the leak. 112(r)(1) 12. In regards to the 1/24/2011 incident, it appears that Keystone failed to maintain a safe facility and did not the take the necessary steps to prevent the gas accumulation and release by failing to utilize purging and lock out/tag out procedures prior to and/or during start up. 112(r)(1) 13. At the time of the inspection, Keystone could not provide any documentation which showed the point of the release at the center and radius determined by the distance to endpoint. The OCA map provided at the time of the inspection did not clearly identify the facility, the point of release, public receptors, or distance to endpoint. It appears that Keystone failed to appropriately determine its public receptors. 68.30(a) 14. At the time of the inspection, Keystone could not provide any United States Geological Survey maps or any data source containing USGS data to identify environmental receptors. It appears that 14 EPA Inspection Report - Page 15 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Keystone failed to identify environmental receptors within the radius from release to endpoint. 68.33(a) 15. It appears that Keystone failed to maintain offsite consequence analysis records which include: rationale for selection of worst case for each covered process, anticipated effect of controls and mitigation, documentation of release rate and duration of release, and data used to estimate population. 68.39(a-e) 16. It appears that Keystone failed to accurately identify the type of gas handled at the stationary source in the RMP executive summary. 68.155(b) 17. At the time of the inspection, Mr. Dansby indicated that Mr. Tommy Johnson, Plant Manager, was the emergency contact for the facility. The RMP lists Dwight Bennett as the emergency contact. Mr. Bennett is a current employee for Keystone but no longer in the same role. It appears that Keystone failed to correct the emergency contact information in the RMP within one month as required by 68.195(b) Section IV - FOLLOW UP The following areas should be further evaluated for compliance: - Keystone's LDAR contractor, TEAM Industrial Services, provided a backup of their electronic database. This should be loaded into Excel spreadsheets and analyzed to determine compliance with NSPS Subpart KKK. - Keystone should test the vapor pressure of the material in the LTN and LTS tanks and provide calculations to demonstrate actual emissions from the tanks. - Keystone did not provide all of the requested TEAM Daily Work Records and Daily Calibration Forms. Due to the discrepancies noted between the records provided and the Semi-Annual LDAR Reports, additional records and reports should be requested and reviewed for compliance issues. - Keystone has experienced some AG flaring events with significant SO2 emissions both as total emissions from the event and as a high emission rate. Keystone should demonstrate that they have not caused an exceedance of the National Ambient Air Quality Standard for SO2 and PM2.5. - The operation of the AG Flare should be evaluated with respect to the manufacturer's design specifications to determine the cause of the unburned hydrocarbons observed with the FLIR camera. - All of the performance testing records for Compressor Engines C-26, C-27, C-28 need to be reviewed to ensure that all testing is conducted, as required. - Review the information from Keystone regarding the problems with recording the temperature for the Compressors C-26, C-27, and C-28. - As of 1/10/14 the LP Flare igniter system was still not operational. - Obtain and review testing records for the AG Flare. - On 12/4/2013, Keystone submitted changes to the RMP which updated the registration information to Regency Field Services and updated the executive summary. - On 12/12/2013, Mr. David Rider, PSM/RMP Manager for Regency Energy Partners, emailed (see Appendix 29) a new OCA map which identified industrial receptors within the distance to endpoint. He indicated that Regency Field Services intended to resubmit the RMP for Keystone as a Program level 3. 15 EPA Inspection Report - Page 16 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Section V - LIST OF APPENDICES Appendix 1 - Photo Log - 11 photos taken 11/20/13 Appendix 2 - Video Log - 8 FLIR videos taken 11/20/13 Appendix 3 - Opening conference sign-in sheet Appendix 4 - Process flow diagrams: - General Process Flow - Glycol Flow - Cryogenic System Appendix 5 - Mary Valencia e-mail dated 12/4/13 Appendix 6 - SRU H2S Flow Diagram Appendix 7 - MSA Sirius Multigas Detector with PID (S/N A3-12746) data log for 11/20/13 Appendix 8 - Site Operating Permit O2940 issued 9/17/13 - selected pages Appendix 9 - Update to Initial Site Operating Permit Application dated 9/16/11 - selected pages Appendix 10 - 30 TAC 106.492 - Flares Appendix 11 - Low Pressure Flare flow meter (KP-19) hours and rate from 10/22/13 - 12/3/13 Appendix 12 - 30 TAC 116.110 - New Source Review Permits - Permit Application Appendix 13 - Keystone Shutdown Project List for October 14-21, 2013 Turnaround Appendix 14 - LDAR Analysis of Daily Work Record and Semi-Annual NSPS Subpart KKK Reports Appendix 15 - TEAM Industrial Services - Daily Work Record dated 2/13/13 Appendix 16 - Semi-Annual 40 CFR 60, Subpart KKK Report for October 2012-March 2013 dated 4/25/13 Appendix 17 - 6 Emission Events reported to TCEQ in 2011 Appendix 18 - 4 Emission Events reported to TCEQ since October 2013 Appendix 19 - Permit 2424 renewal dated 3/8/04 - selected pages Appendix 20 - Title V Permit O-769 Semi-Annual Deviation Report for 7/7/12-1/6/13 dated 2/5/13 - selected pages Appendix 21 - Title V Permit O-769 Semi-Annual Deviation Report for 1/7/13-7/6/13 dated 8/5/13 - selected pages Appendix 22 - RMP update dated 08/16/11 Appendix 23 - Material Safety Data Sheet (MSDS) for Propylene Appendix 24- MSDS for Natural Gas Liquids Appendix 25 - OCA old map (supplied at time of the inspection) Appendix 26 - Incident Report dated 3/1/09 Appendix 27 - Incident Report dated 1/24/11 Appendix 28 - ERP dated 11/6/13 Appendix 29 - E-mail from John Rider dated 12/13/13 with attachments 16 EPA Inspection Report - Page 17 of 237 Regency Field Services /Keystone Gas Plant Inspection Date 11/20/2013 Appendix 1 Photograph Log EPA Inspection Report - Page 18 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Tank LTN Tank LTS Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DC_2677 new.jpg (The original file DC_2677.jpg did not record properly in the FLIR camera. The photo was to have been the same as the visible light image recorded at the beginning of Video 2678. Using the software, FLIR Video Report, I pulled the image from Video 2678....D. Ford) 11/20/2013 1:27 pm (approximately) Clint Rachal Produced water tanks LTN (north tank) and LTS (south tank). Visible emissions observed from vent pipe at the top of each tank where the red arrows are pointing. Page 1 of 11 EPA Inspection Report - Page 19 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Tank LTN Tank LTS Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DC_2679.jpg 11/20/2013 1:32 pm Clint Rachal Produced water tanks LTN (north tank) and LTS (south tank). observed from vent pipe at the top of each tank. Visible emissions Page 2 of 11 EPA Inspection Report - Page 20 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DC_2680.jpg 11/20/2013 1:37 pm Clint Rachal Acid Gas Flare sump (knock out prior to flare). Receives gas stream from 4th bed of the Sulfur Recovery Unit. Also known at the facility as the Posey Pond. Visible emissions observed with the FLIR camera at the red arrows. Also, staining in the sand indicates that the sump had overflowed in the past. Page 3 of 11 EPA Inspection Report - Page 21 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DC_2682.jpg 11/20/2013 1:44 pm Clint Rachal Three (3) facility flares: (l-r) High Pressure, Acid Gas, Low Pressure Flares. Low pressure flare was not lit. Page 4 of 11 EPA Inspection Report - Page 22 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DC_2687.jpg 11/20/2013 2:27 pm Clint Rachal Clark Recompressor #18 Page 5 of 11 EPA Inspection Report - Page 23 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DC_2689.jpg 11/20/2013 2:49 pm Clint Rachal Skimmer sump. Page 6 of 11 EPA Inspection Report - Page 24 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DC_2691.jpg 11/20/2013 3:00 pm Clint Rachal Visible leak with FLIR camera observed from top of sight glass at valve 0399 at Product Accumulator tank. Page 7 of 11 EPA Inspection Report - Page 25 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: DC_2693.jpg 11/20/2013 3:02 pm Clint Rachal Visible emissions with FLIR camera observed from piping on the Product Accumulator Tank. This piping had been used during the recent turnaround to relieve pressure. Page 8 of 11 EPA Inspection Report - Page 26 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Vent stack off the Sulfur Pit. Vent stack off the 4th bed (incinerator) - slight (approx. 10% opacity) white emissions Photo File Name: Date of Photo: Time of Photo: Photographer: Description: RIMG0006.JPG 11/20/2013 1:09 pm Amanda Ferguson Sulfur Recovery Unit (SRU). Stacks, l-r, Sulfur Pit and Incinerator Stack. Page 9 of 11 EPA Inspection Report - Page 27 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: RIMG0007.JPG 11/20/2013 1:13 pm Amanda Ferguson SRU close up. Beds 1-4, left to right. Page 10 of 11 EPA Inspection Report - Page 28 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Appendix 1 Photo File Name: Date of Photo: Time of Photo: Photographer: Description: RIMG0008.JPG 11/20/2013 1:16 pm Amanda Ferguson SRU Sulfur pit. Note spilled mollten sulfur has cooled and hardened. Page 11 of 11 EPA Inspection Report - Page 29 of 237 Regency Field Services /Keystone Gas Plant Inspection Date 11/20/2013 Appendix 2 Video Log EPA Inspection Report - Page 30 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Appendix 2 Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_2678.mp4 11/20/2013 1:30 pm Clint Rachal Produced water tanks LTN (north tank) and LTS (south tank). Visible emissions observed from vent pipe at the top of each tank. Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_2681.mp4 11/20/2013 1:39 pm Clint Rachal Acid Gas Flare sump (knock out prior to flare). Receives gas stream from 4th bed of the Sulfur Recovery Unit. Also known at the facility as the Posey Pond. Visible emissions observed with the FLIR camera. Also, staining in the sand indicates that the sump had overflowed in the past. Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_2683.mp4 11/20/2013 1:46 pm Clint Rachal Three (3) facility flares: (l-r) High Pressure, Acid Gas, Low Pressure Flares. Low pressure flare was not lit. Visible emissions observed from Acid Gas Flare. Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_2686.mp4 11/20/2013 1:58 pm Clint Rachal Low Pressure Flare on the left. time of inspection. No flame present at Page 1 of 2 EPA Inspection Report - Page 31 of 237 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Video Log Location: Regency Field Services, LLC - Keystone Gas Plant City: Kermit Winkler County State: TX Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_2688.mp4 11/20/2013 2:28 pm Clint Rachal Clark Recompressor #18 Appendix 2 Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_2690.mp4 11/20/2013 2:51 pm Clint Rachal Skimmer sump. Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_2692.mp4 11/20/2013 3:01 pm Clint Rachal Visible leak with FLIR camera observed from top of sight glass at valve 0399 at Product Accumulator tank. Video File Name: Date of Video: Time of Video: Videographer: Description: MOV_2694.mp4 11/20/2013 3:03 pm Clint Rachal Visible emissions with FLIR camera observed from piping on the Product Accumulator Tank. This piping had been used during the recent turnaround to relieve pressure. Page 2 of 2 EPA Inspection Report - Page 32 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 3 Opening Conference Sign-In Sheet EPA Inspection Report - Page 33 of 237 EPA Inspection Report - Page 34 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 4 Process Flow Diagrams: - General Process Flow - Glycol Flow - Cryogenic System EPA Inspection Report - Page 35 of 237 EPA Inspection Report - Page 36 of 237 EPA Inspection Report - Page 37 of 237 EPA Inspection Report - Page 38 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 5 e-Mail from Mary Valencia dated 12/4/13 EPA Inspection Report - Page 39 of 237 Ford, Debbie From: Sent: To: Cc: Subject: Attachments: Valencia, Mary [Mary.Valencia@RegencyGas.com] Wednesday, December 04, 2013 12:16 PM Ford, Debbie Johnson, Tommy RE: Keystone inspection - status of outstanding records SRU Block Flow Diagram.pdf; KP-19 low pressure flare meter volumes since plant back on after shutdown Oct 2013.xlsx; #2 GRU Log Sheet.pdf; Keystone October 2013 Shutdown Project list to EPA.xlsx Sorry, time got away from me this morning. Please find our responses in red below. Please let me know if you need anything else. Thanks, From: Ford, Debbie [mailto:Ford.Debbie@epa.gov] Sent: Monday, December 02, 2013 4:02 PM To: Valencia, Mary Cc: Johnson, Tommy Subject: Keystone inspection - status of outstanding records Hi Mary, I hope you had a good Thanksgiving. I still have not received the records requested at the Keystone Gas Plant inspection from 11/20/13. Specifically, The backup files for the LeakDAS LDAR database Team should of fedexed flash drive to you with this data. It should be arriving today The explanation of the corporate relationships of Energy Transfer, Regency Energy Partners, and Regency Field Services. Regency Energy Partners LP is the indirect Parent of Regency Field Services LLC. Energy Transfer Equity LP is the indirect owner of the General Partner of the General Partner of Regency Energy Partners LP The process flow diagram for the SRU (be sure to include the Acid Gas Flare knockout sump (aka the "Posey Pond"), the flare, and the produced water tanks and associated sump) Please find it attached Response to the question about the underground drain system and whether this is monitored under the LDAR program or should be. it is grandfathered from KKK as it has been in place prior to 1992 At the time of the inspection, I also asked for the flow to the Low Pressure Flare for the date of the inspection, but instead, please provide the following information: The actual dates of the turnaround in October Shutdown 10/14/13, back on 10/21/13 The flow to the Low Pressure Flare since the end of the turnaround Low Pressure meter KP-19 volumes attached from 10/22/13 to present Documentation on the scope of work for the turnaround please find it attached Specific information on the work performed on the Low Pressure Flare (there was reference to work during the turnaround, but I would like specific work done on the igniter system, whether performed before, during, or after the turnaround). both control boxes were changed, the upper track was repaired, the SO cable used for ignition and monitoring thermocouple was changed, and all hardware was inspected. This work was done during the turnaround however, the system could not be tested until the plant was brought back up after the turnaround as we didn't have power to the system until the electrical upgrade was complete and we also didn't have any pilot gas with the plant depressured. 1 EPA Inspection Report - Page 40 of 237 Regulatory analysis (i.e. applicability) for the Low Pressure and the Acid Gas Flares. Low pressure flare is permitted under 30 TAC 106.492. Acid Gas flare is permitted under NSR permit 2724. Information on apparent spills observed on the ground o near the Low Pressure Flare ignition panel The stained soil near the low pressure flare ignition panel was removed. A 3" line that belongs to producer in the area was exposed and no leaks were identified. The area will continue to be periodically monitored for any future releases. o at the Posey Pond It ran over while draining the Acid gas Knockout Drum. The liquids from this drum consist mainly of condensed steam (water). The stained soil has been removed. Written procedures used by operations for observation of flares, pumps, other equipment. Include the scope, frequency, and how these observations are documented? The written procedures are the reading sheets we use for monitoring the plant. I changed the #2 GRU sheet to include a flare pilot monitoring column. See log sheet attached Can you provide any follow-up taken on the produced water tanks such as monitoring of the exhaust vents, sampling/analysis of the liquids in the tank, etc? Tanks were completely emptied out after inspection. Work order being generated to install flame arrestors (enardo valves) on each tank vent Please provide this information by COB tomorrow. If you have any problems with this deadline, please let me know as soon as possible. Thanks, Debbie S. Ford Environmental Scientist U.S. EPA - Region 6 (MC 6EN-AA) 1445 Ross Avenue - Suite 1200 Dallas, TX 75202 2733 (214) 665-7235 (desk) (214) 665-3177 (fax) ford.debbie@epa.gov "This email may contain material that is confidential, privileged and/or attorney work product and is for the sole use of the intended recipient. Any review, reliance or distribution by others or forwarding without express permission is strictly prohibited. If you are not the intended recipient, please contact the sender and delete all copies." Private and confidential as detailed here. If you cannot access hyperlink, please e-mail sender. 2 EPA Inspection Report - Page 41 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 6 SRU H2S Flow Diagram EPA Inspection Report - Page 42 of 237 EPA Inspection Report - Page 43 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 7 MSA Sirius Multigas Detector w/ PID S/N A3-12746 data log for 11/20/13 EPA Inspection Report - Page 44 of 237 EPA Inspection Report - Page 45 of 237 EPA Inspection Report - Page 46 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 8 Site Operating Permit O2940 Issued 9/17/13 - selected pages EPA Inspection Report - Page 47 of 237 Bryan W. Shaw, Ph. D., Clwirmon Toby l3;~kcr, Commissio1wr Zak Covar, ~.\ecttl ive Diredor /..! t:. I I c. ( { T J7.XAS COMMISSION ON ENVIRONMENTAL QUALI'fY Protecli11g Texas by J<educing and l'rcvenling Pnllulicm wiR RLCHAIW REllM VfCE PRESrDENT OPER1\TTONS REGENCY FTELD SERVI CES LLC 6oo N MARlENf.ELD ST STE 700 MIDLAND TX 79701-4395 September 17, 2013 Rc: Effective Sile Operating Permit Approval and Vo id of General Operating Permit Authorization to Operate Initial lssuance Permit Numbers: 02940 (SOP Initial) 0769 (GOP Void) Regency Field Services LLC Keystone Gas Plant Kerm it, Winkler County Regulated l!:nlity Number: R1~100238633 Custo mer Reference Number: CN603263823 Account Number: Wi\1-oou-U Dear Mr. Rehm: The effective federal operating permit (FO P) for Rcgem;y Field Services LLC, Keyslune Gas Plant, is endosccl. This f.OP co nsti tutes authority to opcmte the em ission units identitlecl in the FOP application. All site operating permits are subject to public petition for 6o days following the expimlion of the 45-day U.S . Endronmenlal Protection Agency (EPA) revie" The public petition period for the FOP extends from September 7, 2013 until November 5, 2013. Tf the EPA receives a vali d peti tion and objects to the nbove-rcfcrencecl perm it, you will be noti fi ed promptly hy the Texas Commission on Environmental Quality (TCEQ) . I n addition, the authorization to operate Keystone Gas Plant under the provisions of the Oil and Gas General Operating Perm it (l;OP) Number 514 bas been voided and the renewa l appl ication withdrawn. As required by Title 30 Texas Administrati\'e Code Chapter 122 (30 TAC Chapter 122), you must submit a compliance certification (Form PCC) for the GOP for the period from Lhc dale of the most recent certification to the date of this letter (not to exceed 12 months). This compliance certificat ion must be submitted with in 30 days of this le tter lo the TCEQ lvlid land Regional Office, 9900 \V Interstate 20 Ste 100, ivliclland, Texas 79706-2636. Contact the region<~ I office should you haYc any questions rega rding the compliance cert ifi ca tion process. P.O. Box 13087 Austin, Ttxns 78711-3087 512-2;~9 - 1000 trcq.tcxns.go\' ------ ----- --------- ITow is ou r rus lnmrr sr rvicr? IC't'q.trxas.~OI'/t't tstn t llrrsu t vcy EPA Inspection Report - Page 48 of 237 Mr. Richard Rehm Page 2 September 17, 2013 Tt should be noted that from the dnte of this lelter Regency Field Services LLC, Keystone Gas Plant musl operate in accordance with the requirements of 30 TAC Chapter 122 and the FOP. Some of the terms nnd conditions contained in the FOP include recordkeeping conditions, reporting conditions (which includes deviation reporting), and complianee cert ification conditions. All reports, along with any questions regarding the reports, shall he forwarded to the TCEQ .Midland Regional Office, 9900 W Inlerslate 20 Stc 100, Midland, Texas 79706-2636. Consistent with 30 TAC Chapter 122, Subchapter C, the permit holder shall submit an apJ)lication lo the Air Permits Division (APD) for a revision to an l'OP for those activities at a site which change, mld, or remove one or more FOP terms or cond itions. The perm it holder shall also submit an application to the APD for a revision to a permit to address the follow ing: the adoption of an applicabl e requirement previously designated as federally en forceable only; the promulgation of a new applicable requirement; the adoption of a new state-only requirement; or a change in a slate-only designation. Thank you again for yom cooperation in ll1is matter. Hyou have questions concern ing the review or this notice, please conlacl Mr. Chuck Lowary, P. F.. at (51 2) 239-1263 . This action is taken under authority delegated by the Executive Director of the TCEQ. Sincerely, Michael Wil~on, P.E., Director ;\ir Permits Division Office of Air Texas Commission on Environmental Quality MPvV/E L/el cc: Ms. Maria Valencia, Specialist Environmental Pennilling, Regency Field Ser\'iccs LLC, Midland i\lr. Rart Collins, Senior Regional Operations Director, Regency Field Services LLC, i\1Hdland Air Scclion Manager, Region 7- Midland Enclosure: Effect ive Perm it cc: Air Permit Section Chief, U.S. Em~ronmcntal Protcctio11 Agency, Region 6, D<1llas Project Numbe1 s: 10146 (SOP [nitial) 10171 (GOP Void) EPA Inspection Report - Page 49 of 237 PEDERAL OPERATING PERl\11'1' A FEDERAL OPERATING PERMIT lS HEREBY lSSUED TO R<.:gcncy Field ~crvices LLC 1\UTHORlZING Tl IE OPERATION OF Kr.ystonc I'lan l Crude Petroleum and Natural Gas LOCATED AT Winkler Coun ty, Texas Laliludc ;) 1o 56' 45" Longitude 103 2 ' 33" Regulated Entily Num ber: RNw02;18633 This permit is issued in accordance \dlh and subj ccl to the Texas Clea n Air Act (TCAA), Chapter 382 of the Texas lfca lth and Safety Code and Title 30 Texas t\dminis trali\'C' Code Chapte r 122 (;10 TAC Chapter 122), Federal Operating Permits. Under 30 TAC Chapter 1 2~, th is permit const itutes t he pe rmit holder's authority Lo opemlc Lhe s ilc and emission units listed in this permit. Operations of Lhe s ite and emiss ion units listed in Lhis permil a rc s ubject to all add itional rules or e~ mend cd rules and o rders of th e Commiss ion purs uan t to Lhc TClv\. This permit does nol relieve the permit holder from the r<.!Sponsibility of obta ining New Source Review authorization for new, modified, or existing faci lities in accordance with 30 TAC Chapter u6, Control of Air Pol lu tion hy Permits for New Construct ion or Modificat ion. The s ite a nd emiss ion units authorized by this permit shall be operated in accordance ''~th 30 TAC Chapter 122, the general terms and conditions, spct:iallerms and cond itions, and attachm ents contained herein. This permit shall ex pire five years from the date or issuance. Th e L'CIICWalrcquirPments specified in :10 TAC 122.241 must lw satisfied in order to renew the authorization to opcratr the sile and em ission units. lssunnec Dale: September !7, 20 J3 EPA Inspection Report - Page 50 of 237 Unit Summary U n it / Gr o u p / Process ID No. FL-1 Unit Type FL<\RES FL-1 FLI\RES IGroup/Inclusive SOP Index No. Unit s - N/A R.nn-1 K/A 6oA-1 Regulation Requirement Driver I 30 TAC Chapter 111, Visible Emissions No changing attributes. !o CFR Part 6o, Subpart J No changing attributes. FL-1 FL-2 FL-2 FL- 6 FL-6 AREAFUG AREAFUG ' PROAMI~E DEHI'- FL"\.R5 N/A F:.ARES N/A FLARES :::.jA FL<\RES N/A FL-illES N/A FUGITIVE EMISSIO:::. Y./A urn:rs FCGITIVE E~1ISSION UNITS N/A GAS N/A SWEETENING/SULFUR RECOVERY UNITS GLYCOL DEHYDRATIO~ ~/A 63A-1 R.nn-1 6oA-1 Ruu-1 6oA-I 6oKKK-1 63HH-1 R2007-l 63HH-2 !1o CFR Part 63, Subpart No changing attributes. I 30 TAC Chapte:1n, 1Visible Emissions 40 CFR Part 6o, Subpart A No changing attributes. No changing attributes. 30 TAC Chapter 111, Visible Emissions No chan:;ing attributes. 40 CFR Pmt 60, Subpart ~o changing attributes. A 40 CFR Part 6o, Subpart No changing attributes. I KKK 40 CFR Part 63, Subpart No changing attributes. HH 30 TAC Chapter 112, 1No char.ging attributes. Sulfur Compounds I I~~CFR Part 63, Subpart INo changing attributes. lniti:1l b~tlanct.~ Effective P:~~c 14 EPA Inspection Report - Page 51 of 237 I Unit Gr o up I Pt"OCC$$ Unit Gr oup P:occss IDNo. Type F:..-6 :::u I FL-6 CD AREA ?t:C EC SOP Index No. R111:1 60:\! 6oKKK-t Applicable Requi remen t s Sum mary Pollut::mt IState Rul e or Federal Regulation Name Emission Limitation. Standard or Equipment Specification Citation I I Oi',\Cl7Y 30 T:\C Ch:~ptcr lll. v :sihlc Er:-lission~ I ~ 6o.1S(c) 1!1.1!1 (J)(4)(~\) OPACITY voc .to CFR J>:m 60. Subpart A "!0 Cf-R Pan 6o, Subp:ut KKK 60.18(1>) 6o.13(c)(!) 60.1S(c)(2) 6o.1S(c)(3)(ii) ~ 6o.1S(c)(4)(ii) 6o.tS(c)(6) s6 o. J3 (c) 60.63:!(:1) 6o.tS 6o.4S2-1(:t) ~ 6o-4S2-:(b) 6o.48:Ho(d) 60..)8:'-IO(C) 60-48:!10(m) 1 6o.633C::J Textual Descripti on Mon itor ing (Sec Sp ecial Term And Testing and Co:tdition ~.B.) Req uiremen ts I Visible cmissior.s from J ~ lll.lll(J)(~)(A)(i) procc.<;.~ )!;:ls fbrc sh:Jll nor be ~ lll.lll(:l)(~,)(A)(ii) permitted for more :han fi,e minute;: in :1 nv two-hour period. c.~ccpt fo r emi.-::~io:1 event e:ni"-.~ions os proviclc<l ir. 101.222(b). I J7l:m;.~ $h:Jil comply with p:lr:.l~raphs (c)-(f) of 60.18. 60.18(<1) 6o.1S(f)(1) 60.13(1)(2) 6o.tS(f)(3) 6o.1S(f)(.' Comply with the requirements for flare.~ :1:: $lJtcd in ~6o.4S:!-10 :md 60-4S:!-l(:t). (b) and (d). .:xccpt JS ;>rovidcd in ~60.633- 6o..;Ss(a) [G) 6o..l3:)(c) 6o.~tSs(c) s6o-tSs(c)(2l s 6o.4Ss(C:)(3) 6o.4S5(!) :c:s 6o..1SsW 60.63:!(<1) [G) 60.63:(h) Recordkccping Requirements (3oTAC 122.144) I 1i llt.lll(:l)(4)(A)(ii) I None [GW 6o..,S6(a/ lGJ~ 6o..;S6(d) 6o.~tS6(c) 6o.. t36(c)(I) 60.632(<:~ 60.635(3) I I Reporting Re quirements (30TAC 122 .145) II )-;one r I None I 60..!S7(a) rcH 6o...j~70') (G,, 60-487(c I Is" 0 oIs1-\'CJ' 60.63:!(<!) :GJ 60.636 !\REt\ FVG l Et: ARE.-\ J7UG ~~u I 6oKKK-t 631 !H-I voc ::o CrR l':m 60. Subp:m KKK I 112(P,) !lAPS 40 <.:FR P~rt 63. 3uhr>:Jrt i rrr !i 60.633(1) 63.760(;::)(1) I ReciprO<::lt:ng comprc.~::or:: in wet ;::os service ox c.-<cmpt from the comp!"C$.~Or conrrol ro.-q\lircmc:-~ts of 60.-1S2-3. ~one Mtcr the compli:mcc <l:1tc. ancilbry equipment oncl comp:cssors::ubjcct to this subp:trt and 40 CFR PJrt 6o. subpJ:t KKK ::rc or.ly r~quir~ to comply "ith the None 60.4S6(j) 60.635(:1) 6o.635(c) ~one I 63.774(1>)(9) None I lnicial ~s.;u:tiiC'C'- t:rrcclhc. r:t:,:e 17 EPA Inspection Report - Page 52 of 237 CAM Summary I - Un it/Group/ Pl'occss Infonnation ID Nu.: PROAJ\IINE Control Device ID No.: TGI - IContro~vice Type: Catalytic Incinerator Applicable Rcgulatol'y Rcquitemenl Name: 30 TAC Chapter 112, Sulfur Compounds SOP Index No.: R2007-1 Pollutant: SO:. Mnin Standard: 112.7(<1) Monitoring Inro,malion Indicator: S02 CEMS Minimum Frequency: Four equally-spaced data points from each one-hour period Averaging Period: IIourly ::werage concentrations Deviation Limit: > 182.88lbsjhr S02 CJ\iVI Te:-..1.: The permit holder shall install, calibrate, and maintain a continuous em ission monitoring system (CEMS) to measure and record the in-stack S02 concentrntion from the catalytic incinerator. A. The CElVIS s hall meet the desigll ancl performance specifications, pass the field tests, and meet the installation requirements ami the data analysis and reporting requirements specified in the applicable Performance Specification Nos. 1 through 9, Title 40 Code of Federal Regulation Part 6o (40 CfR Part Go), Appendix B. If there arc no applicable performance specifications in 40 CFR Part 6o, Appendix 13, contact the TCEQ Office of Air, Air Permits Division for requirements to be met. B. Section 1 below appl ies to sourees subject to the quality-assuram:e rcquirenwnts of 40 CFR Part 60, Appendix F; section 2 applies to all other sources: (1) The permit holder shall assure that the CEMS meets the applicable quality-assurance requirements specified in 40 CFR Purl 60, Append ix r, Procedure 1. Relative accuracy excccdanccs, as specified in 40 CFR Pmt 6o, Appendix f, Section :,.2.:1 and any CmvrS downtime shall be reported to the appropriate TCEQ Regional Manager, and necessary corrective nction shall be taken. Supplemental stack concentration measurements may be required at the discretion of Lhc appropriate TCEQ Regional Manager. (2) The system shall be zeroed and spanned daily, and corrective action taken when the 24- hour span drift exceeds two timcs the amounts specified in the applicable Performance Specification Nos. 1Lhrough 9, t [O CFR Pmt 6o, Appendix B, or as specified by the TCEQ if not specified in Appendix B. Zero and span is not required on weekend~ and plant holidays if inslrumcnt technicians arc nol normally scheduled on those days. Each monitor shall be quality-assured allcasl quarterly using Cylinder Gas Audits (CGA) in I ncco rclnnce with 40 CFR Part6o, Appendix F, Procedure 1, Sections.t.?., with the following 1Iexception: u relative aceurncy test audit (RATA) is not required once every fom quarters (i.e., Jnllial h>~mnr,- Effcclivr l'a~c 22 EPA Inspection Report - Page 53 of 237 EPA Inspection Report - Page 54 of 237 New Source Review Auth orization References The New Somce Review aut horizalions listed in the table he1ow are applicable requirements under 30 TAC Chapter 122 and enforceable under this operating permit. TiUc 30 TAC Chapler 116 Permits, Sp ecial Permits, and Other A uthorizations (Othe t Than Permits By Rule, PSD Pcrmits, or NA P ermits) for the Applicatiotl Area. -- Authorization No.: 2724 Issuance Date: 06/03/2007 I - - Authorization No.: 73600 -- Issuance Date: 05/18/2007 Permits By Rule (30 TAC Chapter 1o6) for Llte Application Al'ea r-- - - - -- Number: 106.183 Version No./Date: 06/18/1997 -- - Number: 106.183 Version No.jDale: 09/04/2000 Number: 106.352 Nu mber: 106.352 - Number: 106-492 Version No.jDale : 09/04/2000 Version No.jDatc: 02/27/2011 I Version No./Date: 09/04/2000 Number: 106.511 Version No./Date: 09/04/2000 N u mber: 106.512 -- - Number: 106.512 Version No.jDate: 03/14/1997 Version No./Date: 07/16/1997 Number: 106.512 - Number: 7 Number: 8o Version No./Datc: 06/13/2001 Version No./Date: 05/05/ l976 I Version No./Dalc: 06/07/1996 I l uilial h~uam~- Cffrrlhr l'a::c 28 EPA Inspection Report - Page 55 of 237 New Source Review Authorization References by Emissions Unit The follO\\ing is a list of New Source Review (NSR) authorizations for emission units listed elsewhere in this operating permit. The )JSR authorizations arc applic.blc requirements under 30 TAC Chapter 122 and enforceable under this operatin3 permit. Unit/ Group/Process IDNo. Emission Unit Name/Description AREAFUG 1.'\REA FCGITIVES IB::\T-\1\1\NTK BS-vV"WTK DEHY 210-BBL \\-ASTE v\'ATER DISPOSAL TANK- BASE NORTH 1 210-BBL WASTE WATER DISPOSAL TAJ.'JK- BASE SOUTH G~YCOLDEH)nP~JOR EM ERG 273-HP CLARK TK6HC FSo EMERGENCY ENGINE ENGIOOl 1200-HP CLARK BA-6 COMPRESSOR ENGINE ENG1002 1200-HP CLA.RK BA-6 COMPRESSOR ENGINE ENG1003 IENGJ004 EKG1005 1200-HP CU\RK BA-6 COMPRESSOR ENGINE 11200-HP CLI\RK BA-6 COMPRESSOR ENGI::\TE 1200-HP CLL\RK BA-6 COMPRESSOR E::\TGI).;'E ENG10o6 ' E~G1007 1320-HP CL"\RK HBA-6 COMPRESSOR EKGTNE 1320-HP CL"\RK HBA-6 COMPRESSOR EKGINE ENG1008 1200-HP CLARK BA-6 COMPRESSOR EKGINE I E::\TG1009 11E::-.JG1010 11320-HP CLARK HBA-6 COMPRESSOR ENGINE 1200-HP CLARK BA-6 COMPRESSOR ENGINE ENG1017 jl320-HP CL-\RK HBA-6 COMPRESSOR ENGINE E~G1018 IE:NG1019 1320-HP CLARK HBA-6 COMPRESSOR ENGIKE 1320-IIP CLr\RK HBA-6 COMPRESSOR ENGIKE New Sowce Review Authorization 2724 10 6 .3 5 2 / 0 9 / 0 4 / 2 0 0 0 1106.352/09/04/2000 I' 2724 I ro6.su/09/04/2ooo I173600 73600 73600 I 73600 73600 'I 73600 73600 73600 I 73600 173600 73600 73600 173600 EPA Inspection Report - Page 56 of 237 New Source Review Authorization References by Emissions Unit The following is a list of :.Jew Source Review (~SR) autho:.izations fo:- emission units listed elsewhere in this operating permi:. The NSR aut:lorizations are applicable requirements under 30 TAC Chapter 122 and enforceable under this operating permit. I IDNo. Unit/Group/Process IE)JG1020 1 ENG1021 ENG1022 ENG1023 ENGI024 EKG1o26 ENG1027 ENG1028 ?:NG1HR.~ FL-1 1 1FL-2 FL-6 L-1 L-3 PROAMINE T-13 IT-17 Emission Unit NaroejDescription COOPER BESSEMER SV-250 CO~PRESSOR ENGINE COOPER BESSEMER SV-275 COMPRESSOR ENGINE COOPER BESSEMER SV-275 COMPRESSOR ENGI)JE CATERPILLAR G3608TA COMPRESSOR EKGINE CATERPILLAR G3612TA COMPRESSOR ENGIKE 1340-HP CATERPILLJ.\R G3516LE CO~PRESSOR E~GIKE 1340-HP CATERPILL>\.R G3516LE C0:\1PRESSOR EKGINE 1340-HP CATERPILLAR G3516LE COMPRESSOR ENGINE CLA.RK HRA-6 COMPRESSOR ENGINE ACID GAS FLARE HIGH PRESSURE FLARE LOW PRESSURE FL..I\RE 3000 BBL CONDE::\SATE TAl'\lK 3000 BBL CONDENSATE TAl.'\lK SULFUR RECOVERYUNIT/A.t\1INE u"'NIT (SRU/ S-1) soo BBL SCRUBBER OIL TANK 750 BBL WATER K)JOCKOUT TA.J.~K New Source Review Authorization - II I 73600 I 2724 2724 106.512/07/16/1997 106.512/07/16/1997 I 106.512/06/ 13/ 2001 106.512/06/ 13/ 2001 106.512/06/13/ 2001 73600 I 2724 106-492/ 09/04/ 2000 106-492/09/04/2000 106.352/o2;27I 2011 106.352/o2/27I 2011 2724 106.352/ o2/ 27I 2011 106.352/o2/27I 2011 lnirbl Jssu~ncc Effccrivc P:~:,:c 30 EPA Inspection Report - Page 57 of 237 New Source Review Authorization References by Emissions Vnit The following is a lisl of Kew Source Rc,icw (NSR) aulhorii'...ations for emission units listed elsewhere in this operating permit. The NSR authorization~ arc applic:lblc requirements under 30 TAC Chapter 122 and enforceable under this opc::ating permit. II Unit/Group/Process I IDNo. I Tl\K 1001 1 - Emission Unit Narne/Description 3000-BBL SCRUBBER OIL TA::--J'K G-2 Ne'\-\7 Source Review Authorization I 106.352/09/04/2000 EPA Inspection Report - Page 58 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 9 Update to Initial Site Operating Permit Application dated 9/16/11 - selected pages EPA Inspection Report - Page 59 of 237 /T1-tr -i n .LL:[UJ.) \...cJl.luC'l1 ta" l. L--)- 1~ { v/ l. I(..., Chu::i :..o\\ a:: Tf>-r:: ConlnJiss;o~- o~. l..n,irt;:n!. q:a_ -.u f'enr ts D:\'ls,o:. ::! (I( ?a;t. 3: C1:-de 1,1c:tl ( 'tdt ,.c.;; 8hi!: c L,u;:!1.. T\ -f-'.? iioN> (!..-:: '~.' P.E i..p:ia;, 1~ lnu.::.~! St:o: {);,_ral/1~' tf:mH, Jl,.-,rhca'iiY: ~~~UtJ,~'l; : -,n.,_;~ (;,':U 5.. t' t :"e! l_!,"! l:c'l'."!t-li! (~a.< Plam - lf"illi;l< C,l"l~' SiT,; .._Jp(':rCJ;,,,g hmll. \, 0-294(1 I'Ci:(,) 1N",)111ii _1, ( TfM-(I(IlJ L. CS6(f5(1(t.f6H ?....\",' ,(J~3M33 '->\Jih.:-n!. IDC';i Gm Serv;;-.e-:; Ltc l5i."GS ('\\115- a! lj v:>::ra:c-~ e n:L.i"c 1:(1, _;"'il:-ess:.ng p!G.n: ne:t ~i."IJ!"'L (:>.d~ l~e~ sto:Je CT?.s Plt>J1i ' \\"h1ch i; 1o:::ne-d !n \\"ini:ler Co:.~.nt.' 1he ~ ~ Y!-I<.n e Gtl~ Plant curre-nr:-. ct~tta<e: ~ U11dcr (,;:,,~,.cl Or!:r.nng PeT:!li: t GOP 1~c 5i ;_ Pe-rm :I\:~ (:. 6{1. SUGS subn,inec u1 iwm.J Stt 0;1::r.;tn1~' fLnml (:'OP 1ap?l>:.:atJor:. iJ Mru"h ::'OCI" A!~o ir1t-.1arch 20(P. 1he T~): a~ Comn~issior1 o:. C:win:11r ~:,t~' lJuaii;_, Cl- Q ,...:;-~ ;: GOP f':>:-11.: ''c (1. f.() :o 1'~ '< ..:d .;'l:lr :~~U:! "i::: <:'I 1 h ~ 50? Pe: :l'< ~'c Q . :'<>1(! Th~ 1~:-ii " ,JCaJ -~., !:'\, <' .n. mJ,JC.. ~(I;"I ap;.'liCt:lic!J, We!! ~i a: ::- j on mc. na!!cmcn: d::h1~ c J,jard, :;(t(IS. ~~ndi:,~ ill~ l:lCCrc:>Ct.:.Ii:>-1 : t~-:.:-1--:- :.:-"' -Llf.J~!ir.nc-~ assu:anc ~ i!J(l itr1:in~ ;.,,, n. :\1\P P~~i.: \\"n}, rhi~ r-ub;ninlil s \.~ ,.. :.".!ld m.~ l(li J ~dit l: 1h; l!!.l'ia. SOP applio:lCJo iC I I~W"T'OTdh: chi! I)!!<:~ 01'1(1:' ;;: !1:> ~;;e SL"1r~ th~ in,na; anrh.:~:,o:- ,,..'!.< <.t..i:"lm::..:u r. \1:;r~h ::0~1- L ;-j1~ <1. i.t K~,~wue Ga(. ?l<::nt !:...<!' <:1l Spf_.: i fiC'El})~ i aentifid a.< Off r~rmil ~('\Jr("(;; jr, f ("1-.(_) )!IJl,lil;)~e OO:tlffie"J)H a.n: aS>Ct~lattd fcnn~ aTL il01 :-~"'e-:::iic-o~.~ rdd:e>seJ ir. ch~ llt)jz_;~,. K til~ ''1:1a ~OP <~rillitaiKn. If \OU ha\'~ Hm yu-:s1i<.111~ rep:din& rim iip;:>I!CilllC:1. pleas:: i~e l frt::: 10 .:-.:.11 ci:h..: :\h '''ilmi' \";;len.:Jil \l!t'l ~ cs "-' 1F: 1- ~ 2 9~~(1 <~ ::n" <1t '?-2 6[.: -S (l. sho~J: ~-::ou hc:ve CJ ~ q..!..::..:ion~ ,,. :i ~ t - 1-!:;u:e ?.:15::;::.:::~1 lrlivr;rJ:.1lC':. c~'\-'u.{,(\ l..~c:1 ( tkmal' <:;~- i1 - t>n ....J 1.:1"1 .. ;1 7 ~~( ~ :.::.;-:;,J ~:1: '-'~':t.1ti.!J~ l ':ntu: .\t.,~ln::tti:~ -'~~-.:!; .:!\'- S:t...l:"l:- !:rn r:. j ,1~~ ~:f''h" s LtC i CEO f'l ;l~~ :'" 1''14~ !'c.,::-.t ~:...~~. !:.t:.!ll, ~-. 1n \~ .. \ ,_~ 1= '..~ .1:-..,-. f t- 1( ~:::1 ~ .. :--. \h \1:;-:. \'r~J:::::c_ >L G5 ..:.~:~ ,~t:-:..1 '-. ~t.,-.; J~!y:;tt,n : r:.~ P l ~li EPA Inspection Report - Page 60 of 237 'f~xas Commi~sion <Hl EnYirQomcot.al Qualit y Fcd~ral Opcra t i.n~ t<:rrnit Prog r::~m lndividu:t) tillil S umma ry rorm OP-SU:VJ Table 1 Date: OW I6!20ll ! Re~ulatcd Enlily No.: RNI (l0238G33 J rcrmit f\o.: 02940 -~--~------~-----,----------------------~----------------------~ Compa ny Name: Soulhcrn Cnion GasServices. LLd. jArea Name: Key~tone Gas Plt:mt Unit/Process ID Applicable No. Form Pl,- 1 f- l.-~ Ft-6 rL-J ..... - ENGJ 026 OP-UA7 OP-UA 7 OP-U/\7 \,/ v v "' OP-UA 2 El'G 1027 ......._.. F.l'Gl02 :~ O P-UA2 O P-U A 2 .E~1ERG 'VV.J ,' ,, .,." nr..- "V 1'1 I 1'- I VV.. ... -v v. O'P-lJA2 .._',"' -'~'"'""'-"1. "0....'-( - '-' '""'"'.. v ~\L~'IL ;v ''"''-'... .. .... .. _t}oit Namc!Ocst:ripti.on . . . ....... .. . . ... 1\ci<.l Gns F1<1rc High Prcssur(! Flare Prcc:onstructioo A uthori7..3tions C..\I\T 30 TAC C hapter 116/30 TAC Chnptcr 106 titl~ I - 2724 I 06.492/09/{)4/2000 IJow PrCS!>urc Flore I06.4 92(0 9/0 4/ 200 0 L A' w n o.:.>~\11 o.: r ru r " '"'-"'' '"''- 1340-hp Calcrpillnr G35 I61J!. Compressor f~n~inc: 1340-hp C'atcrpill:u GJS I(it,I; C(lmprc!'sor l~ng.i nc .. 1]40-hp C~tcrpi llre r G35l6 LE (:(lrnrrc~sor 13ng.inc 273-llp C1urk TKl'li-IU P:)O f~ mcrgcncy Bngine .. . .v. ........... '' ')"" ........, ....., "-' ~ ,, .I , , . ,.w.IU ; , ';1. 1\l IVIIVIIJI\J: t ll VIU HLI I II I C.: l' H.:<liCI ~ w. - , -~ , . '" ''- vc v '-\" ' l" "~vo viL~ILIL.: - I VV.'i '!.<.: \J Y>\J'ii.<.\J\HJ ~ I\IVV/VVIV ( '")'"IV ~ ou.512i<)o/l :moo 1 1065 12/{)6/!3/2001 I 06.512!06/\ 3/'200 1 l 06.51 1/09/04/2000 "'" v . vv "" - l 1\1. I V. Jo \1\lr t . I JA " '"~~- .'. '" -'""V --- n Group to No. Plant JD No. ! l (:JRP E N 0 2 - -- - - GI<.J> l~NG2 0 RPI::l\:G2 '-"" '- \,/.VIV ~~~-~-..... '"''- ' """' \.ll~ n ,_,\ JlVI 0 \.II'\ I",_,''-' ......... "' l''l!:!<' I o f 2 EPA Inspection Report - Page 61 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 10 30 TAC 106.492 - Flares EPA Inspection Report - Page 62 of 237 :Texas Administrative Code Page 1 of2 <<Prev Rule TITLE30 PART 1 CHAPTER 106 SUBCHAPTER V RULE 106.492 Texas Administrative Code Next Rule>> ENVIRONMENTAL QUALITY TEXAS COMMISSION ON ENVIRONMENTAL QUALITY PERMITS BY RULE THERMAL CONTROL DEVICES Flares Smoke less gas fl ares which meet the following conditions of this section are permitted by rule: ( 1) design requirements. (A) The flare shall be equipped with a flare tip designed to provide good mixing with air, flame stability, and a tip velocity less than 60 feet per second (ft/sec) for gases having a lower heating value less than 1,000 British thermal units per cubic foot (Btu/ft3 ) or a tip velocity less than 400 ft/sec for gases having a lower heating value greater than I,000 Btu/ft3 . (B) The flare shall be equipped with a continuously bmning pilot or other automatic ignition system that assures gas ignition and provides immediate notification of appropriate personnel when the ignition system ceases to function. A gas flare which emits no more than 4.0 pounds per hour (lb/lu) of reduced sulfur compounds, excluding sulf ur oxides, is exempted fro m the immediate notification requirement, provided the emission point height meets the requirements of l 06.352(4) of this title (relating to Oil and Gas Production Facilities). (C) A flare which burns gases containing more than 24 parts per million by volume (ppmv) of sulfur, chlorine, or compounds containing either element shall be located at least l/4 mile from any recreational area or residence or other structure not occupied or used solely by the owner or operator of the flare or the owner of the property upon which the flare is located. (D) The heat release of a flare which emits sulfur dioxide (S02 ) or hydrogen chloride (HCI) shall be greater than or equal to the following values: Attached Graphic (2) operational conditions. (A) The flare shall burn a combustible mixture of gases containing only carbon, hydrogen, nitrogen, oxygen, sulfur, chlorine, or compounds derived from these elements. When the gas stream to be bwned has a net or lower heating value of more than 200 Btu/ft3 prior to the addition of air, it may be considered combustibl e. (B) A flare which burns gases containing more than 24 ppmv of sulfur, chlorine, or compounds containing either element shall be registered wi th the commission's Office of Permitting, Remediation, and Registration in Austin using Form Pl-7 prior to construction of a new fl are or prior to the use of an existing flare for the new service. (C) Under no circumstances shall liquids be burned in the flare. http://info.sos.state. tx.us/pls/pub/readtac$ext.TacPage?sl= R&app=9&p_dir=&p_rloc=&p_tl... 1/3/20 I4 EPA Inspection Report - Page 63 of 237 EPA Inspection Report - Page 64 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 11 Low Pressure Flare flow meter (KP-19) hours and rate from 10/22/13 - 12/3/13 EPA Inspection Report - Page 65 of 237 EPA Inspection Report - Page 66 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 12 30 TAC 116.110 - New Source Review Permits - Permit Application EPA Inspection Report - Page 67 of 237 : Texas Administrative Code Page 1 of2 <<Prev Rule TITLE 30 PARTt CHAPTER 116 SUBCHAPTER B DIVISION 1 RULE 116.110 Texas Administrative Code Next Rule>> ENVIRONMENTAL QUALITY TEXAS COMMISSION ON ENVIRONMENTAL QUALITY CONTROL OF AIR POLLUTION BY PERMITS FOR NEW CONSTRUCTION OR MODIFICATION NEW SOURCE REVIEW PERMITS PERMIT APPUCATION Applicability (a) Permit to construct. Before any actual work is begun on the facility, any person who plans to construct any new facili ty or to engage in the modification of any existing faci lity wh ich may emit air contaminants into the air of this state shall either: ( I) obtain a permit under 116.111 of this title (relating to General Application); (2) satisfy the conditions for a standard permit under the requirements in: (A) Subchapter F of this chapter (relating to Standard Permits); (B) Chapter 32 1, Subchapter B of this title (relating to Concentrated Animal Feeding Operations); (C) Chapter 332 of this title (relating to Composting); or (D) Chapter 330. Subchapter N of this title (relating to Landfill Mining); (3) satisfy the cond itions for a flexible permit under the requirements in Subchapter G of thi s chapter (relating to Flexible Permi ts); (4) satisfy the conditions for fac ilities permitted by rule under Chapter 106 of this title (relating to Permits by Rule); or (5) satisfy the criteria fo r a de minimis fac ility or source under 116.119 of this title (relating to De Minimis Facilities or Sources). (b) Modifications to existi ng permitted facilities. Modifications to existing permitted facilities may be handled through the amendment of an existing permit. (c) Comp li ance history. For all authorizations listed in subsections (a) and (b) of this section or 116.116 of this title (relating to Changes to Facilities), compliance history reviews may be required under Chapter 60 of this title (relating to Compliance History). (d) Exclusion. Owners or operators of affected sources (as defined in 116.15( 1) of this title (relating to Section ll2(g) Dcfmitions)) subject to Subchapter C of this chapter (relating to Hazardous Air Pollutants: Reg ul ations Governing Constructed or Reconstructed Major Sources (FCAA, ll2(g), 40 Code of Federal Regulations Part 63)) are not authorized to use: ( I) a permit by rule under Chapter 106 of this title; http://info.sos.state.tx.us/pls/pub/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_ rloc=&p_tl. .. I/6/2014 EPA Inspection Report - Page 68 of 237 EPA Inspection Report - Page 69 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 13 Keystone Shutdown Project List for October 14-21, 2013 Turnaround EPA Inspection Report - Page 70 of 237 KEYSTONE SHUTDOWN PROJECT LIST AREA . Air Sys te m LOCATION DESCRIPTION 1l1roughout the plant Instrument air leaks. To be ident ified and repaired by plant operators Boiler I Stea m System Test PSV's on steam sytem. Remove any block valves located below lhe PSV's. Cyrogcnics P rocess Mole Sieve Beds Mole Sieve Beds Chiller Cryo Cryo V-302 & V303 Mol S ieve change out Maintenance on dehy valves (6-10" 600 ANSI and 6-4" 600 ANSI) Sightglass on Chiller changed out. pull insulation and check corrosion in process on Chiller I product lines. Add a trnnsmiuer. Dchy piping inlet I discharge- Do" n stream lilter case. Dew Point moisture analyzer (sample points need fabrication). Connections for lhe probes need to be installed at theTA. the analyzer can be installed after theTA. Clean Exchangers- John Lehman wi ll provide list of (3) exchangers that need cleaning. Project will consist of removing end blinds from shell/tube exchangers and lancing out the tubes(rich side). Replace (3) buttcrlly va lves in unil- Theses are under DCS project- (2) 12" valves & ( I) 6" va lve. Project w ill in clude modifcation or re placement of existing spools as takeout of the new val ves is d ifferent Potential Leaks around brid le on V-302 or V-303. Proj ect will consist of removi ng lhc insula tion. inspecting, making rcpn irs as needed. re-i ns talli ng insul ation. OCS Sys te m ES D Sy~ tc m PLC-DCS tic-ins for chillers New Control Room DCS Block Val,es behind transmitters I instruments Check ESD"s "hen plant is shut- Function Tests Fl:uc System Fuel System LP Flare Repair the ignition system on the LP Flare. C lark inlet compressors Fuel valves to Clark engines arc leaking (9-3" 150 ANS I valves) Cooper Building Fuel li ne to Cooper swrtcrs & Turbo ass ists - Bolt up EPA Inspection Report - Page 71 of 237 EPA Inspection Report - Page 72 of 237 EPA Inspection Report - Page 73 of 237 EPA Inspection Report - Page 74 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 14 LDAR Analysis of Daily Work Record and Semi-Annual NSPS Subpart KKK Reports EPA Inspection Report - Page 75 of 237 EPA Inspection Report - Page 76 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 15 TEAM Industrial Services - Daily Work Record dated 2/13/13 EPA Inspection Report - Page 77 of 237 !Q Team Industrial Services -- \ltJ ~~--~~~~~~~==~~===-~~==~ EMISSIONS CONTROL SERVICES I DAILY WORK RECORD DATE: JOBNO. - - - - 0 voc Customer Name & Location 0 NGPP 0 NSPS Customer Representative 0 NESHAP D MACT r~ D OTHER Customer Address ' I \ ,. Unit/Area Customer P.O. No. Sign: Cusl.v111t::1 A'VI\IIU'vvn::;u~<:> l 111:11" Date: Per Component Fee: Identification Tagging Difficult to tag Identification & lCIYY" 'Y tv1u1 IIlUIII IY Remon itoring Difficult to monitor Identification, tagging & mon1tonng SUBTOTAL: I Quantity Amt. Each ~./{i -Comments Total Per Component Fee: Quantity Amt. Each 1_irl1j)le maintenance I Maintenance . Bagging I Difficult to bag I Leaks 9 Other: Other: Other: TOTAL: J !I Additions: Job -Review Deletions: No Tags: Needs Plugs/Blinds: First Attem_f)t Due Date: Completed Due Date: ....,,y, Technician: Equipment: Technician: ,-: ,... ' ~ Equipment: Vehicle: ',C I I J"~ Total 10/Ser. No: C#' :>. , _r _ ' ~~ r' ~; Amt. Each Total Lunch Job Site Out PAR-0010 EPA Inspection Report - Page 78 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 16 Semi-Annual 40 CFR 60, Subpart KKK Report for October 2012 - March 2013 dated 4/25/13 EPA Inspection Report - Page 79 of 237 SOUTHERN UNION GAS SERVICES An ENERGY TRANSFER Compony 600 N Marienfeld, Suite 700 Midland, Texas 79701 (817) 302-9780 April 25, 2013 Texas Commission on Envirom11ental Quality Region 7 - Midland 9900 W IH-20, Suite 100 Midland, Texas 79706 Re: Semi-AnnuaJ 40 CFR 60, Subpart KKK Report Permit No. 0-0769 Keystone Gas Plant RN I 00238633, CN603004664. WM-00 11-U Southern Union Gas Services, Ltd. (SUGS) owns and operates the Keystone Gas Plant located in Winkl er County, Texas. Attached is the NSPS Subpart KKK Semi-Annual Report for October 201 2 through March 2013. If you have any questions, please call me at the number listed above or at marv ., a l e n c i a 0!SU!l .COm . Sincerely, ,-!(/ r_2;ltI MariaM. Valencia Specialist - Environmental Permits Enclosures EPA Inspection Report - Page 80 of 237 NSP SEMIANNUAL REPORT (40 CFR 60, SUBPART KKK) PART/ COMPANY: PLANT: PROCESS UNIT IDENTIFICATION: REPORTING PERIOD: Southem Union Gas Services, Ltd. Keystone Gas Plant lnlet. Dehy, Amine, C!yogenic Processes and Methanal tank in Ctyo Aea l 0112 throu!!h 03113 PART II No. of pressure rei icf devices for wh ich leaks have been detected No. of pressure relief devices for which leaks have not been repaired No. of valves for which leaks have been detected No. of valves for which leaks have not been repaired No. of pumps for which leaks have been detected No. of pumps for which leaks have not been repaired No. of compressors for which leaks have been detected No. of compressors for which leaks have not been repaired 10/12 3 0 10 3 I 0 2 0 11/12 0 0 7 5 3 1 0 0 12/ 12 0 0 0 0 0 0 0 0 0 1/13 0 0 I 0 I 0 0 0 02/13 0 0 0 0 0 0 0 0 03/13 0 0 0 0 2 0 0 0 EPA Inspection Report - Page 81 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 17 6 Emission Events reported to TCEQ in 2011 EPA Inspection Report - Page 82 of 237 EPA Inspection Report - Page 83 of 237 EPA Inspection Report - Page 84 of 237 EPA Inspection Report - Page 85 of 237 EPA Inspection Report - Page 86 of 237 EPA Inspection Report - Page 87 of 237 EPA Inspection Report - Page 88 of 237 EPA Inspection Report - Page 89 of 237 EPA Inspection Report - Page 90 of 237 EPA Inspection Report - Page 91 of 237 EPA Inspection Report - Page 92 of 237 EPA Inspection Report - Page 93 of 237 EPA Inspection Report - Page 94 of 237 EPA Inspection Report - Page 95 of 237 EPA Inspection Report - Page 96 of 237 EPA Inspection Report - Page 97 of 237 EPA Inspection Report - Page 98 of 237 EPA Inspection Report - Page 99 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 18 4 Emission Events reported to TCEQ since October 2013 EPA Inspection Report - Page 100 of 237 EPA Inspection Report - Page 101 of 237 EPA Inspection Report - Page 102 of 237 EPA Inspection Report - Page 103 of 237 EPA Inspection Report - Page 104 of 237 EPA Inspection Report - Page 105 of 237 EPA Inspection Report - Page 106 of 237 EPA Inspection Report - Page 107 of 237 EPA Inspection Report - Page 108 of 237 EPA Inspection Report - Page 109 of 237 EPA Inspection Report - Page 110 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 19 Permit Number 2724 renewal dated 3/8/04 - selected pages EPA Inspection Report - Page 111 of 237 NAR.15.2004 12:f.l5Pf'l ' AOI111'1/R&D I . ,, ' Kahllcen Ha~tnett \lv'hlte, Chaimwn R. E. "R.llp\1" Marqu~~. QJmmt'sslonar Lan-y R. So\~ard, ('.ommLulnnP,. Margartt Hoffman, Executive Dtreclor C,'.W\m3' TEXAS COMMISSION ON ENVIRONMENTAL QUALITY ._) Pro/acting Te.'Cas by Reducing (md Prevc11llng Pollutlon March 8, 20?4 s..<~ '&c{rreS Mr. Herb Harless Director, Envitonm~ntal, Health, and Safety Sid Richardson Energy Services, Limited 201 Main Street, Suite 3000 Port Worth, Texas 76102 Re: Permit Ret1ewal Pcnnit Number: 2124 Keystone Gas Processing Plant Kem1it, Winkler County Rogul ated Entity Number: RN l 00238633 Customer Reference Number: CN600 131189 "3/! 1-;;,o tt./ :__ _ I ~rc~-v ~ RECEIVED MAR 1 5 2004 EH &SDEPARTMENT Sid Ricllanfson Ctvhoo &Eoo-w Co. ~'"' _ ~:;rtf ~jiaoa Dcnr Ml'. Harless; Thls is in response to your renewal application, Form PI-I R, entitled "Renewal Application,)) concerning the proposed ren.ewal of Permit Number 2724. As indicated in. Title 30 Texas Administrative Code 116.314(a) and based on our review, your pennit is hereby renewed. Enclosed is a penn it for your facility. Also enclosed are new conditions and a maximum allowable emission rates table. We appreciateyour careful review ofthe conditions oftbe permit and assuring that all requirements are consistently met. This ponnit will be in effect for ten years from the date of approval. Please refe~IJce the regulated entity number (RN), customer reference number (CN), and pennit number noted in thls document in all your future conespMdence for tho referenced facility or sito. The RN replaces the former Texas Commission on Environmental Quality account nwnber for the facility (ifportable) or site (if permanent). TheCN is a unique number assigned to the company or col'poration and applies to all facilities and sites ov.rned or operated by this company or corporation. l'.O. I:lox 13087 Austin, Tcx;,s 7S7ll 30S7 512/239-1000 Jnlcrnel address: WW\t.lc:eq.st.lte.t'\.us EPA Inspection Report - Page 112 of 237 .11AR.15.21304 12=06PI1 ADI'1Ir~/R&D NO.'t'00 P.4/12 SPECIAL CONDITIONS Pennit Number 2724 EMISSTQN STANDARDS l, This pennit authorizes emissions only from those points listed in tl1o attached table entitled "Emission Sources- Maximwn Allowable Emission Rates)" and the facilities covered by tltis pennit are authorized to emit subject to the emission rate limits on that table and other 6perating conditions specified in this pennit. 2. Acid gas from these pennitted facilities shall be directed to the sulfur recovery unit and then directed to the catalytic incinerator. The glycol dehydrator tegenerator vent shall be directed to the acid gas flare. .!~t.IU:td}.p,.shutwn, at1d:mllintbJ!AA<r eml~$!01.11~ ~~lht9 ~h~~~~).y,tj,p in9ino,ratqr and aQidsi! 1fiftrro"M 'tiies6p~~~tr&rr:onm~ar~h6talifii"o~~ytiii~~dir ..~. tiditio1f. Glycol flash tank overhead vent flash gas shall be dir~too to the plant Inlet gas for processing. 3. Sulfur fed to the sulfur recovery unit (SRU) shall not exceed 20 long tons per day (LTPD). The minimum sulfur recovery efficiency for this pennit unit shaH be 95.0 percent. The sulfur recovery efficiency shall be determined by calculation as follows: Efficiency "" Where: (S recovered) (100) (S in acid gas) Efficiency "" sulfur recovety efficiency, percetlt S recovered = total sulfur recovered, pounds per hour (lbslhr) Sin acid gas = total sulfur in acid gas stream,lbs!hr Total sulfur recovered shall be calculated as follows: S recovered "" S in acid gas - S in incinerator stack Where: S in incinerator stack ""' total sulfur in tail gas incinerator stack, lbs/hr. EPA Inspection Report - Page 113 of 237 11AR.15 . 2004 12:09PM NO. 700 P.ll/12 I Permit Numb or 2724 Page2 Emission Point No. (I) H-301 II-1402 S-1 S-PIT S-TRUCK F-1 EMISSION SOURCES - MAXlMUM ALLOWABLE EMISSION RATES Source Name (2) Regenerative Heater ~n,cvn-rt I /{e(d c....r l11erminol Heater SRU Stack Sulfur Pit Sulfur Tank Truok Loading Area Process Fugitives (4) AIR CONTAMINANTS DATA Air Contaminant Name(3) En1is~ion Rates Jb/hr IPY** co NO~ PMIO S 02 voc co NOX PM10 so2 voc co H2S NO. PM10 sol voc H1S H2S H2S voc 0.40 0.48 0.04 0.01 0.03 0.25 0.29 0.02 0.01 0.02 0.22 1.87 0.26 0.02 182.88 0.66 0.01 0.01 0.05 1.25 1.76 2.09 0.16 0.01 0.12 1.08 1.29 0.10 0.01 0.07 0.97 8.18 1.16 0.09 801.00 2.90 0.01 0.01 0.23 6.36 (J) Emjssion point identification- either specific equipment designation or emission point number from plot plan. (2) Specific point source name. For fugitive sources use atea name or fugitive source name. (3) CO - carbon monoxide NO. total oxides of nitrogen PM10 - particulate mntter (PM) equal to or less than I0 microns in diameter. Where PM is not listed, lt shall be asswned that no particulate matter greater than 10 microns is emitted. S02 - Stllfur dioxide VOC - volatile organic compounds as defined iu Title 30 Texas Administrative Code 101 .1 H2S - hydrogen sulfide EPA Inspection Report - Page 114 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 20 Title V Permit O-769 Semi-Annual Deviation Report for 7/7/12 - 1/6/13 dated 2/5/13 - selected pages .,.,. EPA Inspection Report - Page 115 of 237 "'!:'J,.. SOUTHERN UNION GAS SERVICES An ENERGY TRANSFER~ 600 N Ma,en!e!d s.ee 700 I M>dland. Texas 79701 (817) 302-9780 ~OPY February 5, 2013 Texas Commission on En~ironmental Quality (TCEQ) Region 7- Midland Air Program 9900 W IH-20, Suite I00 Midland. Texas 79701 Subject: Semi-Annual Deviation Report Permit NO. 0-0769 Keystone Gas Plant CN 60300466./: RN/00238633: WM-001 1-U Southern Union Gas Services, Ltd (SUGS) owns and operates the Keystone Gas Plant located in Winkler County. Texas. Attached is the Semi-Annual Deviation Report for the reponing period of July 7, 2012 through January 6, 2013. If you need additional information. please contact me at the above number or at r.n3~3-~J!c:j~fuug.co11J. Sincerely. MariaM. Valencia Air Qualit) Program EPA Inspection Report - Page 116 of 237 EPA Inspection Report - Page 117 of 237 ,., .~ ,.. TCEQ AlR CO/ RN100238633 IRP Texas Commission on Environmental Quality Federal Operating Permit Deviation Report Form Form Dev Rep (Part 1) ....-- Permit Holdor Name 1- Area Name Report Period Start Date Southern Union Gas Services Ltd. I Keystone Gas Plant 7f7/2012 Report Period End Date 11/612013 - ------ Customer ~umber bN603004664 I ----r~eratlng Permit mber 0-0769 Account -- ,!lumber Report WM-0011-U 2/5/2013 - Submittal Cate Operating Permit Requirement for Which Deviations are Being ID Number UnltiD SRU (S-1) Group ID nla Term& Condition No. GOP condition (b)(7);Permll 2724 Condition 1 and 3 Pollutant -- Regulatory Requirement Citation ~15{b)(2)(G) and (c) Type or Requirement MAERT limits, Sulfur recovery efficiency SOPor GOP Index Number n/a -- .-Dev Item No. 82 STEERS lnctdont Deviation Period No. 1 - Start End No. Date Tim Date Time or e Dev Cause of Deviation nla 10118112 7:oo 10/19/12 7:00 1 Exceeded S-1 S02 emission lim1ts of 182.88 lbs/hr due AM AM to the SRU not meeting efliciency. It was 189.61bs/hr Reported Monitoring Method nla -- Monitoring daily Froquency I ~ Corrective Action Taken to Remedy or Mitigate __ Deviation Situation _ SUGS has been working on getting the SRU back In compliance. SUGS has made numerous repairs to the SRU, most of which have been summarized in emission event reports and affirmative defenses 83 n/a 7/28/12 7:00 am 7/29112 ~ am 1 -r-~--- - - .- --- Failure to maintam 95% SRU efficiency on this day ltwas94.4% submitted to TCEO _ _ SUGS has been workmg on getting the SRU back in compliance. SUGS has made numerous repairs to the SRU. most of which have been summarized 1n em1ss1on event reports and affirmative defenses f-84 nta 8/16/12 - ~00 8/17112 7:00 1 am am Failure to maintam 95% SRU efficiency. It was 94.2% on this day submitted to TCEO. SUGS has been working on getting the SRU back 1n compliance. SUGS has made numerous repa~rs to the SRU. most of which have been summarized in em1ssion event reports and affirmative defenses - submitted to TCEQ. - Page 2 of7 TCEQ-10101 [04/09] Form DevRep: This form for use by Federal Operating Perm1t holders and may be revised periodically. EPA Inspection Report - Page 118 of 237 EPA Inspection Report - Page 119 of 237 EPA Inspection Report - Page 120 of 237 EPA Inspection Report - Page 121 of 237 EPA Inspection Report - Page 122 of 237 EPA Inspection Report - Page 123 of 237 EPA Inspection Report - Page 124 of 237 EPA Inspection Report - Page 125 of 237 EPA Inspection Report - Page 126 of 237 EPA Inspection Report - Page 127 of 237 Regency Field Services LLC / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 21 Title V Permit O-769 Semi-Annual Deviation Report for 1/7/13 - 7/6/13 dated 8/5/13 - selected pages EPA Inspection Report - Page 128 of 237 EPA Inspection Report - Page 129 of 237 EPA Inspection Report - Page 130 of 237 EPA Inspection Report - Page 131 of 237 EPA Inspection Report - Page 132 of 237 EPA Inspection Report - Page 133 of 237 EPA Inspection Report - Page 134 of 237 EPA Inspection Report - Page 135 of 237 EPA Inspection Report - Page 136 of 237 EPA Inspection Report - Page 137 of 237 EPA Inspection Report - Page 138 of 237 EPA Inspection Report - Page 139 of 237 EPA Inspection Report - Page 140 of 237 EPA Inspection Report - Page 141 of 237 Regency Field Services / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 22 Risk Management Plan dated 8/16/11 EPA Inspection Report - Page 142 of 237 EPA Inspection Report - Page 143 of 237 EPA Inspection Report - Page 144 of 237 EPA Inspection Report - Page 145 of 237 EPA Inspection Report - Page 146 of 237 EPA Inspection Report - Page 147 of 237 EPA Inspection Report - Page 148 of 237 EPA Inspection Report - Page 149 of 237 EPA Inspection Report - Page 150 of 237 EPA Inspection Report - Page 151 of 237 EPA Inspection Report - Page 152 of 237 EPA Inspection Report - Page 153 of 237 EPA Inspection Report - Page 154 of 237 EPA Inspection Report - Page 155 of 237 EPA Inspection Report - Page 156 of 237 EPA Inspection Report - Page 157 of 237 EPA Inspection Report - Page 158 of 237 EPA Inspection Report - Page 159 of 237 EPA Inspection Report - Page 160 of 237 EPA Inspection Report - Page 161 of 237 EPA Inspection Report - Page 162 of 237 EPA Inspection Report - Page 163 of 237 EPA Inspection Report - Page 164 of 237 EPA Inspection Report - Page 165 of 237 EPA Inspection Report - Page 166 of 237 Regency Field Services / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 23 Material Safety Data Sheet - Propylene EPA Inspection Report - Page 167 of 237 EPA Inspection Report - Page 168 of 237 M.A.TER IAL SAFETY DATA SHEET Propylene (Polymer Grade, Unodorized) Vers1on 1 2 Revision Date 2011-03-24 ------------ ------------ 1. IDENTIFICATION OF THE SUBSTANCE/MIXTURE AND OF THE COMPANY/UNDERTAKING Product information Trade name Maten al Propylene (Po'ymer Grade. Unooonzed) 1103433 1102933,1021731 1015413, 1026827.1029232 Use Company Chemical intermediate Chevron Phillips Chem1cal Company LP 10001 S1x Pmes Drive The Woodlands, TX 77380 Emerg ency telephone: Health 866 442 9628 (North America) 1 832 813 4984 (International) Tran sport North Amenca CHEMTREC 800 424 9300 or 703.527.3887 Asia. +800 CHEMCALL (+800 2436 2255) Chma 0532.8388 9090 EUROPE BIG +32 .14 584545 (phone) or +32.14583516 (telefax) Chemcare ASia Tel +65 6848 9048 - Mob: +65 8382 9188 - Fax. +65 6848 Sou th Amenca SOS-Cotec lns:de Brazil: 0800 111 767 Outside BraziL +55 19.3467 1600 Responsible Department E-ma address Webstte Product Safely and Toxicology Group MSDS@CPChem. com WNW.CPChem.com 2. Ht~ZARDS IDENTIFICATION r--- Emergency Overview -- ------------, Phy sical state Gaseous Color. Colorless Odor. Sweet ::>SHA Hazards Flammable Gas I 3HS Classification Flammable gases. Category 1 GHS -L ab e l i n g Symbols) :3ignal Word Hazard Statements PrecautiOnary Statements MSDS Number: 100000010916 Danger H220 Extremely flammable gas Prevention : P21 0 Keep away from heaVsparkslopen flames/hot surfaces 1/11 EPA Inspection Report - Page 169 of 237 EPA Inspection Report - Page 170 of 237 EPA Inspection Report - Page 171 of 237 EPA Inspection Report - Page 172 of 237 EPA Inspection Report - Page 173 of 237 EPA Inspection Report - Page 174 of 237 EPA Inspection Report - Page 175 of 237 EPA Inspection Report - Page 176 of 237 EPA Inspection Report - Page 177 of 237 EPA Inspection Report - Page 178 of 237 EPA Inspection Report - Page 179 of 237 Regency Field Services / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 24 Material Safety Data Sheet - Natural Gas Liquids EPA Inspection Report - Page 180 of 237 EPA Inspection Report - Page 181 of 237 EPA Inspection Report - Page 182 of 237 EPA Inspection Report - Page 183 of 237 EPA Inspection Report - Page 184 of 237 MATERIAL SAFETY DATA SHEET NATURAL GAS LIQUIDS 1 13. DISPOSAL CONSIDERATIONS Revised June 20 11 Regu lations covering the disposal or treatment of hydrocarbon containing wastes vary by the agency having th e jurisdiction over the site or type of operation and possibly from state to state. The responsibility for proper handling of waste materials is that of the owner. Consult federal, state, and local waste regu lations to determine appropriate waste characterization of material and allowable disposal method(s). 114. TRANSPORTATION INFORMATION Revised June 20 11 DOT PROPER SHIPPING NAME: Petroleum Gas, Liquefied HAZARD CLASS/I.D. NO/PACKING GROUP: 2.1, UN 1075 LABEL: Flammable Gas I.M.O . PROPER SHIPPING NAME: Petroleum Gas, Liquefied HAZARD CLASS/1.0. NO/PACKING GROUP: 2. 1, UN 1075 LABEL: Flammable Gas I.C .A.O. /I.A.T. A PROPER SHIPPING NAME: Petroleum Gas, Liquefied HAZARD CLASS/1.0. NO/PACKING GROUP: 2.1, UN 1075 LABEL: Flammable Gas, Cargo Aircraft Only EPA Inspection Report - Page 185 of 237 MATERIAL SAFETY DATA SHEET II NATURAL GAS LIQUIDS I l 15. REGULATORY INFORMATION Revised June 2011 U.S. FEDERAL REGU LATORY INFORMMATION: Any releases of this product, including an y substantial threat of a release, may be subject to federal reporting requirements. CERCLA SECTION 103 AND SARA SECTION 304 (RELEASE TO THE ENVIRONMENT): The CERCLA definition of hazardous substances contains a "petroleum exclusion" clause, which exempts natural gas usable for fuel, and any indigenous components of such. However, other federal reporting requirements under the Toxic Substances Control Act {TSCA) and the Emergency Planning and Community Right-To-Know Act of 1986 EPCRA; also known as SARA Title Ill), Section 304 may still apply. SARA SECTION 311/312 HAZARD CLASSES ACUTE HEALTH : YES FIRE: YES SUDDEN RELEASE OF PRESSURE: YES SARA SECTION 313 SUPPLIER NOTIFICATION: This product does not contain any toxic chemicals subject to the Emergency Planning and Commun ity Right-To-Know Act (EPCRA) of 1986 and of 40 CFR 372: STATE REGULATORY INFORMATION: Any release of this product may be subject to state and/or local reporting requirements. This product and/or its constituents may also be subject to other regulatio ns at the state and/or local level. Consult those regulations that are applicable to your facility and/or operation. j 16. OTHER INFORMATION Revised June 2011 Hazard Rating: NFPA Hea lth--1 Fire-- 4 Reactivity--1 Specific Hazard N/A HMIS Health --2 Flammabil ity- -4 Reactivity--0 PPE--N/A ABBREVIATIONS: AP = approximate <= less than ppm = part per million N/A = not applicable > = greater than N/D =not determined EPA Inspection Report - Page 186 of 237 EPA Inspection Report - Page 187 of 237 EPA Inspection Report - Page 188 of 237 EPA Inspection Report - Page 189 of 237 EPA Inspection Report - Page 190 of 237 EPA Inspection Report - Page 191 of 237 Regency Field Services / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 25 Offsite Consequence Analysis - map EPA Inspection Report - Page 192 of 237 EPA Inspection Report - Page 193 of 237 Regency Field Services / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 26 Incident Report dated 3/1/09 EPA Inspection Report - Page 194 of 237 EPA Inspection Report - Page 195 of 237 EPA Inspection Report - Page 196 of 237 EPA Inspection Report - Page 197 of 237 Regency Field Services / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 27 Incident Report dated 1/24/11 EPA Inspection Report - Page 198 of 237 SOUTHERN UNION GAS SERVICES INCIDENT INVESTIGATION Report completion/distribution date Date of Event EVENT INVESTIGATION REPORT 6/3/11 Event# 01/24/2011 Time of Event Date Investigation started 01/24/2011 Time investigation started Facility Keystone Department Location/area involved Caterpillar Building Specific process components involved #24 Caterpillar 2nd Stage Discharge Hazardous chemicals of involved Process: Natural Gas / Hydrogen Sulfide Gas Keys012411 3:00 P. M. 6:00 P.M. Operations PERSONNEL INVOLVED IN EVENT NAME TITLE/ORGANIZATION Randy Rossell I and E Technician ( Electrician) / SUGS Tony Stark Utility Man / SUGS Sammy Castaneda Repairman "C" Jerry Hunt Repairman "B" John Drinkard Engine Operator "A" Sonny Orona Utility Man / SUGS DESCRIPTION OF EVENT (what occurred) Unit #24's 2nd stage discharge piping experienced an internal explosion causing a gas release into the Caterpillar (Cat) compressor building. The accumulated gas flashed injuring a SUGS employee and causing damage to the building. EPA Inspection Report - Page 199 of 237 Severity of Event (check all that apply) Facility Injury/lost workday X Injury/first aid X Explosion Large release of HHC X Small release of HHC Fire X Near miss (no release or harm) Injured person (s) if applicable: Randy Rossell Likelihood: E Consequence: 5 1. Insignificant. No injuries, low financial implications 2. Minor. Possible injury not more than first aid treatment, medium financial loss 3. Moderate. Possible injuries would require medical treatment, high financial loss 4. Major. Extensive injuries possible, major financial loss 5. Catastrophic. Death is clearly possible, huge financial implications CONSEQUENCE LIKELIHOOD Insignificant 1 Minor 2 Moderate 3 Major 4 Catastrophic 5 Almost certain A H H E E E Likely B M H H E E Moderate C L M H E E Unlikely D L L M H E Rare E L L M H H Legend: E - extreme risk (immediate action required, eg. Do not proceed with activity until the level of risk is reduced) H - high risk (senior management attention required M - moderate risk L - low risk (manage by routine procedures) EPA Inspection Report - Page 200 of 237 CAUSAL FACTORS CONTRIBUTING TO EVENT (how & why) On January 23, 2011, Unit #24 (Cat Compressor) was shut down for repairs. Employees opened and/or closed valves and blow downs to isolate the unit. SUGS lock out/tag out procedure was not utilized during this process. Following repairs to the compressor, valves and blow downs were reopened and/or closed in preparation to restart the compressor. SUGS purging and lock out/tag out procedures were not utilized during this process. Vent lines on the suction piping remained in an open position allowing natural gas and compressed air to be comingled in the suction line during the attempt to re-start the compressor. An internal piping explosion occurred followed by natural gas migrating into the Caterpillar building and igniting when it reached an ignition source, resulting in the fire. CORRECTIVE ACTIONS SUGGESTED BY INVESTIGATION TEAM Suggested Action Retrain all applicable plant personnel on following procedures: o Lock Out/Tag Out (LOTO) o Start Up and Shut down procedures Review plant specific procedures (Startup and Shutdown, Purging, etc.) so they are current and provide sufficient details and site-specific information to safely perform the required task. Resolution A new LOTO procedure has been implemented at all facilities that include initiating the LOTO procedure with the work order. Operating procedures are being rewritten in a new format. SUGS has implemented a mandatory fire retardant clothing (FRC) requirement throughout the company. The program was initiated prior to the event however the vendor selection for the FRC had not been completed. SUGS has completed the distribution of FRC throughout the company. Report Circulation & Posting (i.e., with whom & how to share) Lou Soldano, Bob Milam, Herb Harless, Jacob Krautsch, John Crossman, Michael Magee, David Maness, and Dwight Bennett. After approval from the above stated, the report will be posted so that all employees will have access to this report and its findings. This incident will also be reviewed during a monthly safety meeting. EPA Inspection Report - Page 201 of 237 Team Member Bob Milam Jake Krautsch Michael Magee David Maness Dwight Bennett John Crossman Jim Payne Hector Sanchez Donnie Forest Cody Baker Jack Birden Ross Boyd Approved By Lou Soldano Rich Rehm Bob Milam Jake Krautsch Michael Magee David Maness Dwight Bennett Herb Harless John Crossman Investigation Team and Approvals Title/Organization V.P Operations/Engineering Director of EHS PSM Compliance Specialist Director of Plant Operations Plant Manager Supervisor, Safety and Health EHS Associate EHS Associate EHS Plant Representative Mechanical Integrity Inspector EHS Plant Representative Engineering Manager Title/Organization V.P & Chief counsel for EHS V. P. Supply and Marketing V.P Operations/Engineering Director of EHS PSM Compliance Specialist Director of Plant Operations Plant Manager Corporate Director EHS Supervisor, Safety and Health Date 6/3/11 6/2/11 6/2/11 6/2/11 6/2/11 6/2/11 6/2/11 6/2/11 6/2/11 6/2/11 6/2/11 6/2/11 Date 6/3/11 6/3/11 6/3/11 6/3/11 6/2/11 6/2/11 6/2/11 6/2/11 6/2/11 EPA Inspection Report - Page 202 of 237 Regency Field Services / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 28 Emergency Response Plan Manual dated 11/6/13 EPA Inspection Report - Page 203 of 237 Emergency Response Procedure Manual Regency Energy Partners West TX Processing Plants Keystone Plant E-book November 6, 2013 EPA Inspection Report - Page 204 of 237 Personnel List Table of Contents Emergency #'s Tools Contractors Facilities - Cryogenic Plant Revision Log Section 1 Section 2 Section 3 Section 4 Section 5 Section 6 EPA Inspection Report - Page 205 of 237 Personnel Lists Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 206 of 237 Personnel Lists Personnel List Name Thomas Johnson - Manager Brent Garymartin - Hourly Field A/Lead Richard S Rehm - EVP Michael B Collins - Sr Director Jacob S Krautsch - Sr Director Kelly D Jamerson - Director Johnny Crossman - Supervisor Maria Valencia - Sr Specialist Jimmy Payne - Tech Specialist - Field Hector J Sanchez - Tech Specialist - Field Orville Birden - Tech Specialist - Field Office # 817-302-9854 817-302-9430 817-302-9789 817-302-9426 817-302-9782 817-302-9715 817-302-9780 817-302-9721 817-302-9719 817-302-9723 Cell # 432-631-2344 817-247-6488 432-634-7861 817-964-2169 432-488-9186 432-940-5074 432-940-1939 432-940-5123 432-238-6465 432-208-0947 2 Regency Energy Partners West TX Processing Plants Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 207 of 237 EMERGENCY PHONE #s Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 208 of 237 EMERGENCY RESPONSE PHONEBOOK Control Room Keystone Plant Control Room (817) 302-9876 Regency Energy Partners West TX Processing Plants Control Room Personnel Regency Energy Partners West TX Processing Plants 2 Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 209 of 237 EMERGENCY RESPONSE PHONEBOOK Emergency Phonebook by County Winkler , TX *911 WILL CONTACT ANY EMERGENCY SERVICE IF DIALED* National Response Center 1-800-424-8802 TCEQ (Midland Region 7) 432 570-1359 Texas Railroad Commission (District 8-Midland Texas) 432-684-5581 State Emergency Response Committee (Austin) (512) 239-2507 or (512) 463-7727 LEPC - Bonnie Leck (432) 586-3461 Winkler Co. Police Dept. (432) 586-2577 Winkler Co. Sheriff Dept. (432) 586-3462 Winkler Co. Fire Dept. (432) 586-2577 Winkler Co. Ambulance (432) 586-2577 Winkler Co. Memorial Hospital (432) 586-8299 Keystone Plant Control Room (817) 302-9876 Regency Energy Partners West TX Processing Plants Keystone Plant 3 Published : 11/06/2013 EPA Inspection Report - Page 210 of 237 Tools & Equipment Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 211 of 237 Tools & Equipment Emergency Tools & Equipment Qty Description 1 -- Breathing Air Trailer 9 -- Scott Air Packs 1 -- Breathing Air Work Carts (4 masks w/egress 3 -- Bendix Pumps 2 -- Four Gas Pump Monitor 34 -- Personal Four Gas Monitors 2 -- Plant Pick-Up Truck 2 -- UTV Vehicles 1 -- Flatbed Truck with Gin Pole Comment In addition to this equipment, the plant maintains a continuous inventory of personal protective equipment, such as rubber boots, gloves, safety glasses, dust masks, gas detectors, hard hats, and various other types of personal protective equipment and safety equipment including ropes, safety belts, harnesses, and supplied air hose line respirators. Emergency/Inventory Pipe No emergency or inventory pipe entered. 2 Regency Energy Partners West TX Processing Plants Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 212 of 237 Contractors Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 213 of 237 Contractors Description Holloman ConstructionCo. 96 5005 010 Merryman Construction Rapid Transport, Inc. Phone Number/Email (432) 381-2000 (575) 395-3110 432-586-2027 Address 190 South East Loop 338 Odessa, Texas 79766 HWY 18 & Merryman Dr. Jal, New Mexico 88252 South Hwy. 18 Kermit, Texas 79745 2 Regency Energy Partners West TX Processing Plants Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 214 of 237 Facilities Cryogenic Plant Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 215 of 237 Facilities Driving Directions - Keystone Plant 2 Regency Energy Partners West TX Processing Plants Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 216 of 237 Facilities Driving Directions - Keystone Plant 9 miles NE of Kermit on CR 301 Latitude 31.94575 Longitude -103.04425 Regency Energy Partners West TX Processing Plants 3 Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 217 of 237 Facilities Facility Details - Keystone Plant Facility Name: Keystone Plant Facility Type: Cryogenic Plant GPS: N 31.94575 W -103.04425 Address: 6297 Co. Rd 301 , Kermit , Winkler , Texas , 79745 Mile Post: EMERGENCY NUMBERS: *911 will contact any emergency service if dialed! LEPC - Bonnie Leck - (432) 586-3461 National Response Center - 1-800-424-8802 State Emergency Response Committee (Austin) - (512) 239-2507 or (512) 463-7727 TCEQ (Midland Region 7) - 432 570-1359 Texas Railroad Commission (District 8-Midland Texas) - 432-684-5581 Winkler Co. Ambulance - (432) 586-2577 Winkler Co. Fire Dept. - (432) 586-2577 Winkler Co. Memorial Hospital - (432) 586-8299 Winkler Co. Police Dept. - (432) 586-2577 Winkler Co. Sheriff Dept. - (432) 586-3462 No contact numberes entered. 4 Regency Energy Partners West TX Processing Plants Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 218 of 237 Facilities A. PROCEDURE FOR NOTIFICATION OF AN EMERGENCY SITUATION In the event of an emergency situation, affected employees are to be notified by an alarm signal, telephone, radio, or by mouth. The Plant Manager, Lead Operator or the "A" Operator in charge of the plant at the time will oversee actions taken during the emergency. B. EMERGENCY RESPONSE AND EVACUATION PROCEDURES Refer to the site map on Sec. 5 Pg 8 for designated evacuation routes, evacuation (safe) areas and potential danger areas. Incidents Controllable by Plant Personnel - No Evacuation Required Incidental or minor spills, releases or fires that can be safely neutralized or controlled by plant employees, with no need for evacuation, are not considered to be emergencies governed by this Emergency Response Plan. Uncontrolled Incidents That Require Evacuation In the event of a major spill, release, fire, or other hazardous situation that warrants a full plant evacuation or danger area evacuation, plant personnel are required to evacuate in accordance with evacuation procedures. Employees are not permitted to remain in or re-enter evacuated areas to assist in handling UNCONTROLLED chemical spills. If evacuation is ordered and an uncontrolled chemical spill is involved, only outside emergency responders, e.g. firemen, emergency medical or rescue teams, or clean-up contractors are allowed to enter the evacuation area until the chemical is controlled and/or neutralized, or determined to be non-hazardous. One exception to this restriction would be if control of an emergency situation could be safely undertaken outside the emergency evacuation area by danger-reducing actions, such as the opening or closing of valves, switches, breakers, vents, pipes, etc. Another exception would be voluntary first-aid treatment or rescue operations performed by an employee, provided the employee has taken proper precautions to avoid falling victim to the emergency himself; i.e., a respirator and other appropriate protective equipment should be used as needed. Regency Energy Partners West TX Processing Plants 5 Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 219 of 237 Facilities Critical Operations Personnel The Plant Manager, Lead Operator and the "A" Operator as applicable are the designated Critical Operations personnel. Only those employees designated as Critical Operations personnel are authorized to make decisions on actions to be taken during full plant evacuation. Critical Operations personnel duties include: 1. Providing back-up notification to employees to evacuate in case audible evacuation alarms malfunction or cannot be heard. 2. Remaining in the control room and plant office, as long as it is safe to monitor the emergency. 3. Notifying outside emergency response agencies as necessary. 4. Implementing operational control processes to correct or lessen the emergency situation. The decision to declare an evacuation will be made after the Lead Operator or the "A" Operator, with concurrence from the Plant Manager whenever possible, has determined that a clear and immediate danger exists that could jeopardize the life or health of affected plant personnel and/or contract personnel. Full Plant Evacuation In the unlikely event that the need to completely evacuate the plant becomes necessary, employees will be alerted by a continuous series of very short, manually operated blasts on the control room air horn or the engine room air whistle . All non-critical employees will then immediately proceed to safe areas by utilizing the appropriate designated evacuation route as shown on the plant site map on Sec. 5 Pg 8. Critical employees will evacuate, if necessary, after performance of the duties listed above. Evacuation from Danger Areas Danger area evacuations, as opposed to evacuation of the entire plant, are usually triggered by an automatic alarm (such as one of the Klaxons for H2S releases), manual alarm or through employee recognition of a potentially dangerous circumstance and subsequent notification to other employees in the danger area to evacuate the area. No authorization from Critical Operations personnel is needed to initiate a danger area evacuation, although these personnel must be promptly notified after evacuation begins. Some plant-specific danger areas are discussed below: 1. Hydrogen Sulfide (H2S) Release H2S is a very deadly gas that can kill within minutes. The greatest concentrations of H2S (and therefore the greatest potential for catastrophic release) are located in the general vicinity of the sulfur plant and amine recovery units. The subject of H2S, its characteristics and hazards are discussed in detail in the facilities H2S Contingency Plan and the Texas Railroad Commission's Statewide Rule 36 Safety Publication. (See publication in back of facility H2S Contingency Plan). If H2S concentrations reach 10 ppm, an automatic Local Klaxon alarm will be triggered, thus signaling employees in the release area monitored by the H2S sensor to evacuate, moving crosswind to a designated safe area. The H2S alarm consists of a Hi-lo sound from the local alarm. An amber-colored strobe light is located at each sensor and is activated in any alarm condition. Employees are not allowed back into the area unless they have donned an approved air pack or the Klaxon H2S alarm has shut off, thus signifying that the H2S level has been controlled by Operations or dispersed naturally and dropped below 10 ppm. NOTE: The Klaxon alarm cannot be manually reset and will remain sounding until the H2S level is below 10 ppm. Also when H2S concentrations reach 10 ppm or more in any given plant location, the main plant alarm horn at the control room will be triggered. This alarm is recognizable as a very loud series of long, intermittent blasts. Upon hearing this alarm, the Operations Supervisor or supervisor in charge is alerted to immediately proceed to or contact the control room via two-way radio to further assess the level of H2S danger and take necessary corrective action to control the release or make the decision to evacuate the plant if the release appears to be uncontrollable. This alarm horn can be reset (silenced) at the control room. 6 Regency Energy Partners West TX Processing Plants Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 220 of 237 Facilities 2. Flammables The potential for fire in a gas processing plant is probably the most inherent danger that exists. There are numerous areas of the plant where highly volatile hydrocarbons are stored or utilized in processing operations. The "Engine Rooms" or "Compressor Buildings" are of particular concern due to the ignitability potential posed by engine backfires and high temperatures. Other areas where flammables are stored or utilized are the tank farm, the process area, the gas pump west of the maintenance shop, the gas tank outside the firehouse, the product pipeline and the gas cooling tower. Should a fire break out in any area of the plant, personnel in the affected area must immediately notify the control room or engine room. Employees will be alerted that there is a fire by a series of three intermittent blasts on either the control room air horn or the engine rooms whistle. See Sec. 5 Pg 9 of this plan for a discussion to determine in-plant -vs.- outside-agency firefighting. Should a fire escalate to a point where full plant evacuation is ordered by the Plant Manager or his designee; the horn or whistle will change to the continuous short blast as described on Sec 5 Pg 6. All non-critical employees must evacuate the plant per the procedures described below. Controllable Releases - H2S and Flammables Relatively small releases of flammables and hydrogen sulfide that are controllable probably will not require evacuation and can thus be dealt with by on-site employees using appropriate personal protective equipment and other appropriate safeguards, including a full facepiece supplied-air respirator and impervious clothing. However, any controllable leak of flammable or toxic substances must be carefully assessed, before control attempts are started, since improper handling of leaking valves or piping can lead to larger and uncontrollable releases that could threaten health or life and would thus require evacuation. Uncontrollable Releases, Real or Threatened If there is a real or threatened occurrence of an uncontrollable leak or spill, a need may occur to classify that section of the plant downwind of the spill area as a danger zone to prevent exposure of workers to concentrations of hazardous substances that could cause injury or death. Should it be determined that an uncontrollable leak or spill has occurred or is likely, an evacuation of some or all of the plant becomes necessary, Company employees are not allowed to remain in an evacuation zone for any reason. The single exception to this rule is when the acid gas flare goes out, in which case necessary Operations personnel will remain to re-ignite the flare. If the acid gas flare goes out, evacuation of non-essential personnel will be to a location outside the circle marked 100 on the map on page 5. Once evacuation of any area(s) takes place, no employee can re-enter until the Plant Manager or his designated alternate determines that the concentration of hazardous substances in the area(s) is at a safe level and gives an "all clear" indication to the workers. In summary, employees are not allowed to work in or around an uncontrollable release of hazardous substances in a manner that might cause them to become exposed to that chemical. Any attempts to control such a release must be done from a remote, unexposed location or by outside emergency response companies and/or agencies, including fire departments, police, emergency medical responders, and private spill control contractors. Evacuation Procedure for Flammables and Hydrogen Sulfide 1. Immediately alert and evacuate personnel downwind from the release site. 2. Personnel are to proceed crosswind from the site to safe areas utilizing the appropriate designated evacuation route. 3. Provide or obtain first aid for any employees who are in distress from exposure to hydrogen sulfide, or who otherwise need medical assistance. Follow emergency notification procedures on Sec 5 Pg 5 of this plan. 4. The personnel listed in this plan's Procedure of Notification Sec 1 Pg 2 will be responsible for notifying all emergency and environmental agencies. . Regency Energy Partners West TX Processing Plants 7 Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 221 of 237 Facilities Accounting for Personnel When an evacuation takes place for any reason, the Plant Manager or his designated alternate will be responsible for ensuring that each person in the plant is accounted for. Emergency search and rescue procedures will be initiated for any persons who have not been accounted for, with help from outside emergency responders as needed. Entry into hydrogen sulfide-contaminated areas requires use of protection for the skin, eyes, and respiratory tract, including a full facepiece supplied-air respirator. All Clear Personnel will be notified that it is safe to re-enter the evacuated area by only those employees designated as "Critical Operations Personnel" (see page 6) who will get the all-clear notification from the Plant Manger or his designee. Under no circumstance will employees rely on second-hand notification by other than Critical Operations personnel. Muster/Rally Point - Keystone Plant The Keystone Plant has (3) Emergency Assembly Areas. Primary Meeting Area is at the parking lot South of the Main Office. The South Secondary Meeting Area is at the intersection of FM 1218 & FM 874, North Secondary Meeting Area is .5 miles Northwest of plant on FM 1218 C. TRAINING REQUIREMENTS Critical Operations personnel have been trained to assist in the safe and orderly emergency evacuation of employees. Critical Operations personnel are responsible for ensuring that the contents of this Emergency Action Plan be discussed with and understood by all plant employees at each of the following times: 1. Initially when the plan is developed. 2. Whenever the plan is changed. 8 Regency Energy Partners West TX Processing Plants Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 222 of 237 Facilities 3. Whenever the employee's responsibilities or designated actions under the plan change. 4. During new employee orientation. 5. Annually PART II - PLANT SPECIFIC EMERGENCY RESPONSE ELEMENTS A. TYPES OF EMERGENCIES Fire, explosions or chemical release may present a degree of hazard that requires protection of the perimeter and evacuation of those who may become exposed to the danger. These dangers may exist without the presence of smoke, flames, or fumes. Chemical Spill or Release Hazard Communication Standard chemical lists and material safety data sheets on each chemical in the plant are kept in SDS binders. The SDS binders are located at the maintenance shop and the office library. SDS chemical sheets are also located electronically on the Company web site. Most chemical spills or releases that might occur can be quickly controlled and handled by plant personnel and will not require notification of emergency response agencies, except for possible instances of having to notify federal or state agencies as a requirement of law, although the need for emergency action would probably remain unnecessary. 1) Hydrogen Sulfide Information Hydrogen sulfide is a colorless and transparent gas, is flammable, heavier that air and may accumulate in low places. At low concentrations (<10 ppm) it has an unpleasant "rotten egg" odor but is considered safe to work in over an eight-hour period. Higher concentrations (>100 ppm) can actually kill the sense of smell in three to fifteen minutes, thus preventing further sensory warnings should concentrations increase. Dizziness followed by breathing failure can occur at levels between 200 and 500 ppm. If necessary, alert and/or evacuate people downwind from the actual or potential release site. Depending on the actual or potential release rate involved, it may be necessary to alert or evacuate people residing off site. In such cases the sheriff, police and fire agencies should be called. Remove exposed persons to clean air, provide first aid if needed and transport exposed persons to a hospital quickly if symptoms do not clear up promptly. Refer to the SDS for H2S for additional information. If rescue is necessary, a self-contained breathing apparatus with a full face-piece must be worn in the release area. 2) Fire In many cases, plant personnel can handle small fires. In the event a fire becomes too large or dangerous for plant personnel to maintain safe control, the Kermit Fire Department should be contacted and the notification process should be implemented. Most fires in the plant can be controlled by cutting off the fuel supply. Likewise, most fires at this plant can be extinguished with in-plant fire lines, process water lines or plant fire extinguishers. Fires that cause release of toxic chemicals, vapors or smoke could create the need to stage full or partial evacuation of the plant, as could possible exposure of employees to flames of the fire. . . . Regency Energy Partners West TX Processing Plants 9 Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 223 of 237 Facilities 3) Tornado The remoteness of the Keystone Plant precludes being part of the Kermit municipal emergency warning system. The threat of a tornado will be monitored by radio and by eye as observable weather conditions deteriorate. The Plant Manager or his designee will make the decision as to what course of action to take; e.g. operation control safeguards, plant evacuation, etc., should a tornado be imminent. MISCELLANEOUS EMERGENCY INFORMATION First Aid Anytime that plant volunteers cannot provide adequate first aid for injured persons, the Kermit Emergency Medical Service should be contacted immediately. Kermit Emergency Medical Service (EMS) 911 Public Relations All news releases, statements to the press, briefings, and information dealing with any aspect of the emergency at hand are to be issued by the Plant Manager or his designated alternate --- NO EXCEPTIONS. Traffic Should the necessity for roadblocks arise, the Winkler County Sheriff's Department and the Department of Public Safety will be responsible for the roadblocks. Regency Energy Partners will provide personnel for the roadblocks only if an immediate danger is presented to passersby, in which case Regency Energy Partners employees will detour traffic until the Department of Public Safety or Sheriff's Department arrives. C. EMERGENCY ARLARM SYSTEM Low H2S Alarm This alarm consists of a series of Hi-Lo, repeated tones on the local alarms. These alarms are local to each zone only. This audible alarm is accompanied by the amber-colored strobe light at the sensor location. If you hear this alarm, go to the nearest plant exit that is upwind and wait for instruction. (10 ppm) Also when H2S concentrations reach 10 ppm or more in any given plant location, the main plant alarm horn at the control room will be triggered. This alarm is recognizable as a very loud series of long, intermittent blasts. Fire This alarm consists of a series of three interrupted blasts on either the control room air horn or the engine room whistle. If you hear this alarm, exit the plant immediately, crosswind and upwind from the area involved in the fire. As quickly as you can, go to the gathering places and wait for instruction. If wind conditions prohibit gathering at one of the gathering places, go to one of the other designated gathering places, contractors are never expected to fight fire. Evacuation This alarm consists of a continuous series of very short, manually operated blast on the control room air horn or the engine room air whistle. If you hear this alarm, EXIT THE PLANT IMMEDIATELY, crosswind and upwind. Proceed to safe areas by utilizing the appropriate designated evacuation route Report any missing personnel to the immediate supervisor! . 10 Regency Energy Partners West TX Processing Plants Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 224 of 237 Facilities MEDIA CONTACT Primary Vicki Granado Office: 214-599-8785 Cell: 214-498-9272 Home: 214-827-0771 email: vicki@granadopr.com Secondary Lyndsay Hannah Office: 214-599-8785 Cell: 214-409-2328 email: lyndsay.hannah@Regencygas.com Regency Energy Partners West TX Processing Plants 11 Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 225 of 237 Revision Log Keystone Plant Published : 11/06/2013 EPA Inspection Report - Page 226 of 237 Revision Log Revision Date Details 4/3/2012 Subject: Edit Contact : Hospital Comments: Better name description 3/29/2012 Subject: Edit Contact : Sheriff Comments: Brief Description 10/7/2013 Subject: Contact deleted from master list. Comments: Delete Duplicate Keystone Control Room Contact Revised By Approved On Approved By Hector Sanchez 8/26/2013 John Crossman Hector Sanchez 8/26/2013 John Crossman Jessica Sanders 2 Regency Energy Partners West TX Processing Plants All Locations Published : 11/06/2013 EPA Inspection Report - Page 227 of 237 Regency Field Services / Keystone Gas Plant Inspection Date 11/20/2013 Appendix 29 e-Mail from John Rider dated 12/13/13 with attachments EPA Inspection Report - Page 228 of 237 From: To: Subject: Date: Attachments: Rider, John (David) Duplechain, Dominique Keystone RMP Friday, December 13, 2013 6:40:24 AM image002.png 10383 Keystone Gas Plant WCS_ARS topo.pdf 10383 Keystone Gas Plant WCS_ARS aerial.pdf RMP and ARS Calculations 12092013.pdf Dominique, Good Morning! I apologize for the slow response. I have been out sick for most of the week. I have however tried to contact you by phone to discuss some items that we are still unsure of and have had no luck and no call back. I have attached the updated Maps and calculations as requested. After our review of the 3/01/2009 Incident, quantities and new maps, we have made the decision to gather all the required information and re-submit the RMP for the Keystone Plant as a level 3. We appreciate your guidance and patience with us as we move to insure we are in compliance. Please contact me at your convenience and we can discuss this in more detail and/or let me know if this covers everything. Thanks for your time, David Rider PSM/RMP Manager 301 Commerce Street, Suite 700 Fort Worth, Texas 76102 Cell - 817-487-9148 Office - 817-302-9457 Fax - 817-302-9350 Private and confidential as detailed here. If you cannot access hyperlink, please email sender. EPA Inspection Report - Page 229 of 237 C C 0.1 0.05 0 0.1 Miles Legend C Industrial !( NGL Tank Alternate Release Scenario 0.16 mile Radius Worst Case Scenario 0.32 mile Radius C C !( Propylene Tank C Pipe Laydown Yard Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community REGENCY FIELD SERVICES, LLC DALLAS, TEXAS KEYSTONE GAS PLANT WORST CASE SCENARIO & ALTERNATIVE RELEASE SCENARIO (AERIAL PHOTOGRAPH) WINKLER COUNTY, TEXAS DRAWN BY: CHECKED BY: ADB KLR APPROVED BY: GRM Date: 12/12/2013 PROJECT NO. 10383 FIGURE 1 EPA Inspection Report - Page 230 of 237 C C 0.1 0.05 0 0.1 Miles Legend C Industrial !( NGL Tank Alternate Release Scenario 0.16 mile Radius Worst Case Scenario 0.32 mile Radius NGS USA Topographic Maps C C !( Propylene Tank C Pipe Laydown Yard Copyright: 2013 National Geographic Society REGENCY FIELD SERVICES, LLC DALLAS, TEXAS KEYSTONE GAS PLANT WORST CASE SCENARIO & ALTERNATIVE RELEASE SCENARIO (TOPOGRAPHIC MAP) WINKLER COUNTY, TEXAS DRAWN BY: ADB CHECKED BY: KLR APPROVED BY: GRM Date: 12/12/2013 PROJECT NO. 10383 FIGURE 1 EPA Inspection Report - Page 231 of 237 Weighted Average Heat of Combustion Component Methane Ethane Propane i-Butane n-Butane i-Pentane n-Pentane Hexane Plus Heat of Combustion1 (kjoule/kg) 50029 47509 46333 45719 45719 44697 44697 44736 NGL (Vol%) 0.9729 43.1942 31.6224 4.2627 11.0844 2.5522 3.2136 3.0839 Weighted Average Heat of Combustion 46632.8 Note: 1. Heat of Combustion for Methane, Ethane, Propane, i-Butane, n-Butane, i-Pentane and n-Pentane are from the Offsite Consequence Analysis Guidance Document, Appendix C, Exhibit C-1. Hexane Plus Heat of Combustion is from the Engineering Data Book, Volume II, Sections 17-26, Gas Processors Association, 1994. EPA Inspection Report - Page 232 of 237 Regency Field Services LLC Keystone Gas Plant C-K Project No. 10378 Worst-Case Scenario - NGL Storage, 11,099 Gallons Distance to Endpoint Calculation Given: Tank Capacity = Weight = 11,099 gallons (based on capacity provided by client) 64,652 lbs Basis/Equation: D= {17*[0.1*W*(HCm/HCTNT)]1/3}*0.00062(2) Where: Distance to endpoint (D) Weight of Flammable Mixture (W) Heat of Combustion of Flammable Mixture (HCm) Heat of Combustion of Trinitrotoluene (4,680 kjoules/kg) (HCTNT) Component Flammable Liquid Mixture (NGL) W(lbs/2.2) 29,387 HCm(kjoules/kg)(3) 46,633 D(miles) 0.32 (1) Weight of NGL is based on site specific provided information. Specific gravity of NGL (0.6984) was provided by D. Rider with Regency Field Services LLC (Manley Gas Testing, Inc. Test # 10937). Tank capacity provided by D. Rider with Regency Field Services LLC. (2) Offsite Consequence Analysis Guidance Document (EPA 550-B-99-009, Equation C-1). (3) A weighted average HCm was used - see Weighted Average HC Table (Offsite Consequence Analysis Guidance Document, Appendix C, Exhibit C-1). EPA Inspection Report - Page 233 of 237 Regency Field Services LLC Keystone Gas Plant C-K Project No. 10378 Worst-Case Scenario - Propylene Refrigerant Tank, 9,000 Gallons Distance to Endpoint Calculation Given: Tank Capacity = Weight = 9,000 gallons (based on capacity provided by client) 38,133 lbs Basis/Equation: D= {17*[0.1*W*(HCm/HCTNT)]1/3}*0.00062(2) Where: Distance to endpoint (D) Weight of Flammable Mixture (W) Heat of Combustion of Flammable Mixture (HCm) Heat of Combustion of Trinitrotoluene (4,680 kjoules/kg) (HCTNT) Component Propylene Refrigerant W(lbs/2.2) 17,333 HCm(kjoules/kg)(3) 45,762 D(miles) 0.27 (1) Weight of propylene is based on site specific provided information. Specific gravity of propylene (0.508) was provided by D. Rider with Regency Field Services LLC. Tank capacity provided by D. Rider with Regency Field Services LLC. (2) Offsite Consequence Analysis Guidance Document (EPA 550-B-99-009, Equation C-1). (3) Propylene HCm was used (Offsite Consequence Analysis Guidance Document, Appendix C, Exhibit C-1). EPA Inspection Report - Page 234 of 237 EPA Inspection Report - Page 235 of 237 EPA Inspection Report - Page 236 of 237 EPA Inspection Report - Page 237 of 237 Regency Field Services LLC Keystone Gas Plant C-K Associates' Project No. 10378 Release Rate for ARS Calculation Basis/Equation: QR = HA*P*1/SQRT(T)*GF Where: QR = Release Rate (lbs/min) HA = Hole or Puncture Area (in2) P = Pressure (psia) T = Temperature (K) GF = Gas Factor Weight of flammable substance after 10-minute release (W) W = QR * 10 minutes Component NGL HA (in2) 3.14 P (psia) 214.7 (1) Gas Factor for propane was used. T (K) 311 GF(1) 22 QR (lbs/min) 841.44 W (lbs) 8,414 Distance to Endpoint Calculation Given: W= 8,414 lbs Basis/Equation: D= {17*[0.1*W*(HCm/HCTNT)]1/3}*0.00062(1) Where: Distance to endpoint (D) Weight of Flammable Mixture (W) Heat of Combustion of Flammable Mixture (HCm) Heat of Combustion of Trinitrotoluene (4,680 kjoules/kg) (HCTNT) Component NGL W (lbs/2.2) 3,825 HCm(kjoules/kg)(2) 46,633 D(miles) 0.16 (1) Offsite Consequence Analysis Guidance Document (EPA 550-B-99-009, Equation C-1) (2) A weighted average HCm was used - see Weighted Average HC Table (Offsite Consequence Analysis Guidance Document, Appendix C, Exhibit C-1).