Document kya0OOExNOZOmeMkoRMn5MVq
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
02/27/2023 - 03/03/2023 Air RMP
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Phone Number Facility Contact:
Invista Propylene, LLC Invista Propylene, LLC 9822 La Porte Freeway Houston, TX 77017 9822 La Porte Freeway Houston, TX 77017 Harris County (713) 740-3911 Jake Marek Jake.marek@invista.com
Health, Safety and Security Manager
FRS Number: Identification/Permit Number: Media Identifier Number: 32511 SIC:
110000461107 Air Operating Permit ID: O1381 100000211825 32511 - Petrochemical Manufacturing 2869 - Industrial Organic Chemicals, Note Elsewhere Classified
Personnel participating in inspection:
Larry House
Invista
Terry Johnson
Invista
Chris Hull
Invista
Bryan Wooten
Invista
Andrew Gowdy
Invista
Jake Marek
Invista
Richard Wood
Invista
Daren Knowles
Invista
Benji Maxwell
Invista
Andrew Gowdy
Invista
Site Manager Health and Safety Engineering Global PSM Leader Operations Manager Technical Manager Health and Safety Manager Health, Safety, and Security Manager Asset Management Environmental Manager Technical Manager
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
KAYLA BUCHANAN
Kayla Buchanan
SAMUEL TATES
Samuel Tates
Digitally signed by KAYLA BUCHANAN Date: 2023.06.12 17:12:20 -05'00'
Digitally signed by SAMUEL TATES Date: 2023.06.12 12:42:19 -05'00'
Date Date
6ENFORM-019-R8.2 (02/12/2020)
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Invista Propylene, LLC Inspection Date 02/27/2023 - 03/03/2023
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION U.S. Environmental Protection Agency (EPA) Region 6 inspector Kayla Buchanan arrived at Invista Propylene, LLC at 9:00 AM on February 27,2023 for an announced inspection. EPA convened an opening conference and met with several representatives from the facility (notated on page 1). Kayla Buchanan presented her credentials to the opening conference attendees and informed them that this was an EPA inspection to determine Invista Propylene's compliance with the Clean Air Act Section 112r (1) and (7), the General Duty Clause and 40 C.F.R. Part 68 requirements, respectively. Invista Propylene is a nonunion facility.
FACILITY DESCRIPTION Invista Propylene is a manned facility located at 9822 La Porte Freeway, Houston, Texas, 77017. Invista Propylene is a chemical plant that converts propane into propylene using propane dehydrogenation technology. The maximum inventory of regulated flammable and toxic substances at the facility are above the RMP threshold quantities. Therefore, this site is required to maintain a Risk Management Plan (RMP) and its process is classified as a Program Level 3. The RMP regulated substances are consumed, used, or manufactured in the dehydrogenation of propane to propylene. At any one time, the maximum amounts of the RMP regulated substances are: flammable mixture - 2,052,000 lbs., and aqueous ammonia (30%) 130,000 lbs. The flammable mixture contains the following substances above 1 wt.%: Propane, Propylene, I-butane and I-butylene. Approximately 100 full time employees work at the facility. There is no union present.
Section II - OBSERVATIONS At the time of inspection, Invista Propylene's RMP process unit was shut down for turnaround activities, therefore, EPA did not tour the unit.
SUBPART A - General
40 C.F.R. 68.10 Applicability - Invista Propylene, LLC is the owner/operator of a stationary source that has more than the threshold quantities of one flammable (flammable mixture) and toxic (aqueous ammonia) one regulated substance in its processes; therefore, the RMP regulations are applicable. Invista Propylene has a Clean Air Act (CAA) Title V permit and an Air Operating Permit and is classified under the North American Industrial Classification System (NAICS) Code 32511 (Petrochemical Manufacturing). In addition, this facility is subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 C.F.R. 1910.119), which categorizes Invista Propylene as a Program Level 3 facility. Invista Propylene last submitted a RMP registration update to EPA on August 26, 2020, which describes process containing the regulated substances at more than threshold quantities.
40 C.F.R. 68.12 General requirements - The owner or operator of a stationary source subject to this regulation shall submit a single RMP, as provided in 40 CFR 68.150 to 68.185. The RMP shall include a registration that reflects all covered processes. EPA reviewed the re-submission of Invista Propylene's RMP. It listed the flammable regulated chemicals and the eleven associated Program 3 processes.
40 C.F.R. 68.15 Management - Invista Propylene developed a management system to oversee the implementation of the risk management program elements. It assigned a qualified person or position that has overall responsibility for the development, implementation, and integration of the risk
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Invista Propylene, LLC Inspection Date 02/27/2023 - 03/03/2023
management program elements. Responsibility for implementing individual requirements of this part was assigned to persons other than the person identified, so the names or positions of these people were documented, and the lines of authority were defined through an organization chart or similar document.
SUBPART B - Hazard Assessment - 40 C.F.R. 68.20 - 40 C.F.R. 68.42
EPA did not note any areas of concerns for any of the elements in this subpart.
SUBPART D - Program 3 Prevention Program - 40 C.F.R. 68.65 - 40 C.F.R. 68.87
EPA noted areas of concern for the following elements within this subpart:
40 C.F.R. 68.69 - Operating Procedures Invista Propylene is required to review its operating procedures as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to stationary sources. Invista Propylene must certify annually that these operating procedures are current and accurate. The facility was could not locate documentation of annual operating procedures certification prior to 2022 (Appendix #1) [AOC #1: 40 C.F.R. 68.69(c)].
40 C.F.R. 68.71 - Training Invista Propylene is required to train each employee involved in operating a process in an overview of the process and in the operating procedures. Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process must be trained. In addition to initial training, employees must undergo refresher training at least every three years.
EPA randomly selected operators from the process area and reviewed the training records for the selected operators. Of the seven operators selected for training records review, four were overdue for refresher training (Appendix #2) [AOC #2: 40 C.F.R. 68.71(b)].
SUBPART E - Emergency Response - 40 C.F.R. 68.90 - 40 C.F.R. 68.96
EPA noted areas of concern for the following elements within this subpart:
40 C.F.R. 68.95 - Emergency Response Program Invista Propylene is required to develop and implement an emergency response program for the for the purpose of protecting public health and the environment. The program must include procedures for the use of emergency response equipment and for its inspection, tesing, and maintenance. EPA reviewed inspection, testing and maintenance records for the annual testing of the facility's deluge fire sprinkler system. Repeat findings were noted on the 2020 and 2021 records, indicating that necessary repairs were not made (Appendix #3) [AOC #3: 40 C.F.R. 68.95(a)(2)].
Section III - AREAS OF CONCERN EPA Region 6 inspector Kayla Buchanan conducted a closing conference at Invista Propylene LLC at on March 3, 2023, for the inspection. During the closing conference, Kayla reviewed the three Areas of Concern noted during the inspection.
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Invista Propylene, LLC Inspection Date 02/27/2023 - 03/03/2023
AOC #1: Operating Procedures - 40 C.F.R. 68.69(c): Invista Propylene failed to annually certify that its operating procedures are current and accurate.
AOC #2: Training - 40 C.F.R. 68.71(b): Invista Propylene failed to ensure its employees received refresher training at least once every three years. Of the seven operators selected for training records review, four were overdue for refresher training.
AOC #3: Emergency Response Program - 40 C.F.R. 68.95(a)(2): Invista Propylene failed to ensure its emergency response equipment was properly maintained. Repeat findings were noted on the 2020 and 2021 records, indicating that necessary repairs were not made.
Section IV - FOLLOW UP No additional information was requested by EPA after exiting the Facility on March 3, 2023. Section V - LIST OF APPENDICES The Appendices are not included in the online published inspection report. CBI Appendices include documents that are claimed CBI by the facility. Sensitive Appendices may include appendices that will not be posted but are not explicitly CBI. These could include Personally Identifiable Information (PII) or Homeland Security sensitive information.
Appendix 1 - INV-PRO-OP01 - SOP Annual Certification Appendix 2 - INV-PRO-TR02 - Operator Training Dates Appendix 3 - INV-PRO-ER01 - INV-PRO-ER03 - 2020-2022 Deluge System Inspection Records
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