Document re0wgqw1Rejbrqdn42y7R7L0r
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region6 1445 Ross Avenue, Suite 1200
Dallas, Texas 75202 - 2733
JAN -6 2015
CERTIFIED MAIL - RETURN RECEIPT REQUESTED: 7014 0150 0000 2453 3481
Ms. Nancy Bryant Regulatory Manager 5416 Highway 290 W Brenham, Texas 77833
Re: GeoSouthem Energy Corporation, Docket No. CAA-06-2015-3303
Dear Ms. Bryant:
Enclosed are the Administrative Order on Consent (AOC) and the Consent Agreement and Final Order (CAFO) that will be filed with the Regional Hearing Clerk.
As provjded in the CAFO, GeoSouthem Energy Corporation is required to pay the civil penalty
of $30,000.00 within thirty (30) days from the effective date of the CAFO.
As provided in the AOC, GeoSouthem Energy Corporation shall comply with the general .duties to identify hazards, design and maintain a safe facility, and mitigate releases that do occur as identified in paragraph 20 of the AOC.
If you have any questions regarding this AOC and CAFO, please contact Jeffrey Clay, Assistant Regional Counsel, at (214) 665-7297.
Enclosure
Director Compliance Assurance and
Enforcement Division
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UNITED STATES
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ENVIRONMENTAL PROTECTION AGENCY- '
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REGION 6 DALLAS, TEXAS
REGION..ti.. i.';._f"" .rc\111:"Jur "\..'...-~otiftr\ EP ll. REGION VI _,_
In the Matter of:
GeoSouthem Energy Corporation
The Woodlands, Texas
Respondent
EPA Docket No. CAA-06-2015-3305
CONSENT AGREEMENT AND FINAL ORDER The Director ofthe Compliance Assurance and Enforcement Division of the United States Environmental Protection Agency ("EPA"), Region 6 ("Complainant") and GeoSouthem Energy Corporation ("Respondent") in the above-referynced proceeding, hereby agree to resolve this matter through the issuance of this Consent Agreement and Final Order ("CAFO").
I. PRELIMINARY STATEMENT
1. This proceeding for the assessment of civil penalties is brought by EPA pursuant to sections 113(a)(3) and 113(d)(l)(B) of the Clean Air Act, as amended ("Act" or "CAA"), 42 U.S.C. 7413(a)(3) and 7413(d)(l)(B), and is simultaneously commenced and concluded through the issuance of this CAFO pursuant to 40 C.F.R. 22.13(b), 22.18(b)(2) and{3), and 22.34.
2. For-purposes of this proceeding, Respondent admits the jurisdictional allegations contained herein; however, Respondent neither admits nor denies the specific factual allegations contained in this CAFO.
Docket No. CAA-06-2015-3305
3. Respondent explicitly waives any right to contest the allegations and its right to appeal the proposed Final Order set forth herein, and waives all defenses, which have been raised or could have been raised to the claims set forth in this CAFO.
4. Compliance with all the terms and conditions of this CAFO shall only resolve Respondent's liability for federal civil monetary penalties for those violations and facts alleged in this CAFO.
5. Respondent consents to the issuance of this CAFO and to the assessment and payment of the stated civil penalty in the amount and by the method set forth in this CAFO.
II. ALLEGATIONS
6. Respondent is a privately held company authorized to do business in the State of Texas.
7. Respondent owns a natural gas processing well site named Oro Negro Unit 2#1H ("Facility") located near the city of Westhoff, Texas.
8. The Respondent operates a natural gas well at the Facility, which includes a separator used for separating well fluids produced from the natural gas well into gaseous and liquid components and a tank battery which consists of interconnected storage tanks situated to receive output from the natural gas well and separator.
9. Natural gas is a highly flammable gaseous hydrocarbon mixture containing methane, ethane, propane and butane, which are extremely hazardous substances listed in Table 3 of 40 CFR 68.130 that may ignite, flashback or explode when exposed to a source of ignition.
10. On Monday, February 3, 2014, multiple maintenance projects were underway at the Facility.
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Docket No. CAA-06-2015-3305
11. A coil tubing job was underway on one part of the Facility. Cuttings and crude oil from the coil tubing job were placed in the water storage tank for storage.
12. A welder and assistant were tasked with connecting a two inch water line running from the water tank.
13. Hydrocarbon vapors collected in the two inch line due to the offloading of cuttings and crude oil that had been placed in the water tank from a coil tubing job.
14. Crude oil, and associated hydrocarbon vapors, is an extremely hazardous substance.
15. When the welder struck an arc on the two inch line, the flammable vapors ignited and traveled down the two inch line until they reached the water tank, which then exploded.
16. The welder was working without a hot work permit and failed to realize that the two inch line and the water tank contained flammable hydrocarbon vapors.
17. As a result of the fire and explosion the entire production tank battery, production vessels, and production piping had to be demolished.
18. The hazards associated with welding in and around piping that contains flammable or explosive substances are well established as are the standards for preventing or minimizing fires while welding in such areas.
19. Pursuant to section 112(r)(l) of the CAA, 42 U.S.C. 7412(r)(l), an owner/operator of a stationary source producing, processing, handling or storing substances listed pursuant to section 112(r)(3) of the CAA, 42 U.S.C. 7412(r)(3), or any other extremely hazardous substance, has a general duty to: (1) identify hazards which may result from accidental releases of such substances using appropriate hazard
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