Document mZEKy9NoXmoMrj1XBYxxYvQO

Kinder Morgan Tejas Pipeline, LP Texas City Extraction Plant Inspection date: 02/28/2023 - 03/02/2023 Region 6 Enforcement and Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 02/28/2023 - 03/02/2023 Air Clean Air Act (CAA) 112(r) and 40 Code of Federal Regulations (C.F.R.) Part 68 Chemical Accident Risk Management Plan (RMP) Program 3 Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Kinder Morgan Tejas Pipeline, LP Texas City Extraction Plant 900 Grant Avenue Texas City, Texas 77590 P.O. Box 369 Texas City, Texas 77592 Galveston Joe Evans Joe_Evans@kindermorgan.com Operations Supervisor FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: 110043811514 Permit by Rule Registration No. 25506 RMP 1000 0002 9391 21113 - Natural Gas Extraction Personnel participating in inspection: Tony Robledo U.S. EPA Joe Evans Kinder Morgan Bobby Arriola Kinder Morgan Juan P. Lopez Kinder Morgan Jessica Biela Kinder Morgan Gilbert Jimenez Kinder Morgan Jsus Oviedo Kinder Morgan Katrina Chruscik Kinder Morgan Mike McKinney Kinder Morgan Inspector/Enforcement Officer Operations Supervisor Operations Coordinator Operator Operator PSM Specialist Mechanical Integrity Engineer Environmental Health and Safety Staff Engineer Electrical and Controls Technician EPA Lead Inspector Signature/Date ANTHONY ROBLEDO Digitally signed by ANTHONY ROBLEDO DN: c=US, o=U.S. Government, ou=Environmental Protection Agency, cn=ANTHONY ROBLEDO, 0.9.2342.19200300.100.1.1=68001003655529 Date: 2023.03.09 13:25:25 -06'00' Tony Robledo Supervisor Signature/Date SAMUEL TATES Date: 2023.03.09 15:11:03 -06'00' Digitally signed by SAMUEL TATES Samuel Tates 6ENFORM-19-R8.2 (02/12/2020) 1 Kinder Morgan Tejas Pipeline, LP Texas City Extraction Plant Inspection date: 02/28/2023 - 03/02/2023 Section I - INTRODUCTION PURPOSE OF THE INSPECTON I, the Environmental Protection Agency (EPA) Region 6 inspector Tony Robledo, arrived at the Kinder Morgan Tejas Pipeline, LP, Texas City Extraction Plant at approximately 9:00 a.m. on February 28, 2023, for an announced inspection. I met with facility representatives noted above at the opening meeting. I presented my credentials and informed them that this was an EPA inspection to determine compliance with the Clean Air Act (CAA) Sections 112(r)(1) and 112(r)(7). The scope of the inspection was a partial compliance evaluation (PCE) and included evaluation of the compliance with 40 C.F.R. Part 68 - Chemical Accident Prevention Provisions. FACILITY DESCRIPTION The Texas City Extraction Plant is a natural gas treating facility that separates hydrocarbon liquids from the incoming natural gas stream by reducing the temperature and pressure low enough, so that partial liquefaction occurs. The liquids are then separated from the gas stream and further split into an ethane/propane product and a light gasoline/condensate product and removed from the facility by pipeline. The remaining natural gas is also removed by pipeline. The facility handles several regulated flammable chemicals above the RMP threshold quantity that include ethane, isopentane, butane, isobutane, propane, pentane, and methane. Kinder Morgan acquired the facility in 2002. There are eight full-time employees at this Union represented facility. The facility operates 24 hours a day, 7 days a week. Section II - OBSERVATIONS I conducted a walk-through of the facility, accompanied by Kinder Morgan personnel, to observe the facility process equipment, piping, and vessels. I observed that the facility was missing proper markings on piping (Photo No. 1 & 2, located in Appendix #2) e.g., direction of flow, color-coding to identify the hazardous material present, placement of pipe labels, and type and size of letters on pipe labels, as required by the American National Standards Institute (ANSI)/the American Society of Mechanical Engineers (ASME) Standard A13.1 (ANSI/ASME A13.1), Scheme for the Identification of Piping Systems. This standard is considered a recognized and generally accepted good engineering practice for above ground piping systems. I also observed no spills, leaks, or fugitive hydrocarbon emission trails with the Forward Looking Infrared (FLIRTM) Series GF320 optical gas imaging camera. Additional observations and findings are found on the RMP Program Level 3 Checklist, located in Appendix #1. Section III - AREAS OF CONCERN Close-out Meeting - EPA convened a closing meeting on Thursday, March 2, 2023, to discuss the Area of Concern (AOC) noted during the inspection and the inspection completion process, and to answer questions from Kinder Morgan personnel. AOC 1. 40 CFR 68.65(d)(2) Process Safety Information (d) Information pertaining to the equipment in the process. (2) The owner or operator shall document that equipment complies with recognized and generally accepted good engineering practices. 2 Kinder Morgan Tejas Pipeline, LP Texas City Extraction Plant Inspection date: 02/28/2023 - 03/02/2023 Kinder Morgan failed to properly label piping for process equipment associated with the depropanizer reflux drum (V8-601) and piping segments leading to an associated terminal at the facility, as required by American National Standards Institute (ANSI)/American Society of Mechanical Engineers (ASME) Standard A13.1. Section IV - FOLLOW UP No follow up occurred or was necessary after the inspection. Section V - LIST OF APPENDICES Appendix #1 - RMP Program 3 Checklist Inspection Symbol Key: Y - Yes, N - No, N/A - Not Applicable; S - Satisfactory, M - Marginal, U - Unsatisfactory. Appendix #2 - Photo Log 3