Document k9jVr3nmyjqY9mwOLQ80qXQ6D

Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 10/24/2018- 10/25/2018 Air Clean Air Act Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: DCP Midstream LP Okarche Gas Plant 30398 N. 2760 Road Okarche, Oklahoma 73762 (same as above) (same as above) Kingfisher Jason P. Dean JPDean@dcpmidstream.com I Plant Supervisor FRS Number: Identification/Permit Number: Media Number: I NAICS: 110007161533 Air Title V Permit No: 2013-1S57-TVR2 (M-3) RMP EPA Facility Identifier: 1000000131S7 211112 =Natural Gas Liquid Extraction Personnel participating in inspection: Tony Robledo US EPA/6EN-AS Jason P. Dean DCP Midstream LP Inspector Plant Supervisor (214) 665-8182 (580) 273-1066 EPA Lead Inspector Signature/Date (A- Tony Robledo ,l) 2 IJ,j_ g--o ' 1/-2.7-l'i Date Supervisor Signature/Date 1ek _,.. Samuel Tates 12-/ + h o t f l Date 6ENFORM-019-R6 (10/6/14) 1 DCP Midstream LP, Okarche Gas Plant Inspection Date 10/24/2018- 10/25/2018 Section I -INTRODUCTION PURPOSE OF THE INSPECTION I, United States Environmental Protection Agency (EPA) Region 6 Inspector, Tony Robledo arrived at the DCP Midstream LP's (DCP) Okarche Gas Plant at approximately 9:00a.m. on October 24, 2018, for an announced inspection. Oklahoma Department of Environmental Quality (ODEQ) inspectors, Jon Livermore, and Curtis Mitchell also participated in this inspection. I conducted an opening meeting with the following people in attendance identified in Table 1. Table 1: Opening and Close Out Meeting Attendance Name Jason P. Dean Bryant McDowell Patrick Schuman Tyler Carroll Lonnie Covalt Jon Livermore Curtis Mitchell Tony Robledo Position DCP Plant Supervisor DCP Health Safety/ Process Safety Management Manager DCP Health Safety/ Process Safety Management Manager DCP Process Safety Management Coordinator DCP Environmental Principal ODEQ Environmental Protection Specialist IV ODEQ Environmental Protection Specialist I EPA Inspector I presented my credentials to all attendees at the opening meeting and informed them that this EPA inspection was to determine compliance with Clean Air Act Sections 112(r)(1) and 112(r)(7). The scope of the inspection was a partial compliance evaluation (PCE) and included an evaluation of the compliance with 40 C.F.R. Part 68- Chemical Accident Prevention Provisions. FACILITY DESCRIPTION The Okarche Gas Plant is a natural gas processing plant that extracts hydrocarbon liquids from raw natural gas streams. The raw natural gas streams received from surrounding booster stations are combined and processed to produce four product streams: a high methane-content residue gas stream for sale as natural gas; a natural gas liquids product stream for sale; a slop oil stream which is sold to refineries; and a wastewater stream. There are no listed toxic substances, only flammable substances, which exceed their respective threshold quantities stored at this facility. The facility produces approximately 160 million cubic feet per day of natural gas. The facility has four full-time employees. Section II- OBSERVATIONS I conducted a walk-through of the facility on October 25, 2018 and was accompanied by DCP and ODEQ personnel to observe the facility process, equipment, storage tanks, and operation. I observed no spills, leaks, or unpermitted air emissions with the FUR'" Series GF320 infrared camera. 2 DCP Midstream LP, Okarche Gas Plant Inspection Date 10/24/2018 -10/25/2018 40 C.F.R. Part 68- CHEMICAL ACCIDENT PREVENTION PROVISIONS Subpart A- General 40 C.F.R. 68.10 Applicability- DCP is an owner and operator of a stationary source that has more than a threshold quantity of regulated flammable substances, listed in 40 C.F.R. 68.130, in a process, and is subject to the Chemical Accident Prevention Provisions. DCP listed the NAICS code (211112) natural gas liquid extraction, as the process in its Risk Management Plan (RMP). The DCP facility process is also subject to the Occupational Safety and Health Administration (OSHA) process safety management standard, 29 C.F.R. 1910.119. These factors make the process at the DCP facility a Program 3 and subject to 40 C.F.R. 68.10(d). 40 C.F.R. 68.12 General Requirements- DCP re-submitted a RMP five-year update on AprilS, 2016. This submittal lists a covered process for Program 3. This requires the facility to develop and implement a management system, conduct a hazard assessment, implement the prevention requirements of 40 C.F.R. 68.65- 68.87, develop and implement an emergency response program, and submit the data elements from 40 C.F.R. 68.175 in their RMP. 40 C.F.R. 68.15 Management- DCP has an established management system to oversee the implementation of the risk management program elements and has assigned a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements. DCP facility personnel provided an organization chart which documents the persons responsible for implementing the individual requirements of the RMP required by this subpart. Subpart B- Hazard Assessment 40 C.F.R. 68.20 Applicability- DCP is an owner or operator of a stationary source subject to this subpart with a Program 3 process that must prepare an offsite consequence analysis which is described in 68.25 of this subpart, complete the five-year accident history as provided in 68.42, and comply with all sections in this subpart for this process. 40 C.F.R. 68.22 Offsite Consequence Analysis Parameters -I requested documentation of the offsite consequences analysis. I reviewed the documentation provided and had a discussion with appropriate DCP facility personnel. DCP applied the offsite consequence analysis parameters as required by this subpart. 40 C.F.R. 68.25 Worst-Case Release Scenario Analysis- DCP identified and reported a worst-case release scenario analysis for the RMP covered flammable substances. I requested documentation of the worst-case release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate DCP facility personnel. DCP selected two inlet receiving pressure vessels (numbered 95-2a and 95-2b) for the worst-case release scenario. DCP used EPA's RMP*Comp to determine the distance to the endpoint in the worst-case release scenario. DCP used the proper guidance endpoints for flammables as required by this subpart. 40 C.F.R. 68.28 Alternative Release Scenario Analysis- DCP identified and reported an alternative release scenario for the RMP covered flammable substances. I requested documentation of the alternative release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate DCP facility personnel. DCP selected its propane unloading terminal as its alternative 3