Document x5dMn36zYGrXMdjY2rm19MRRQ
Region 6 Enforcement and Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
05/24/2022 - 05/26/2022 Air Clean Air Act Section 112(r) and 40 Code of Federal Regulations (C.F.R.) Part 68 Chemical Accident Risk Management Plan (RMP)
Company Name: Facility Name: Facility Physical Location:
(city, state, zip code) Mailing address:
(city, state, zip code) County/Parish: Facility Contact:
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS:
Energy Transfer GC NGL Fractionators LLC/Energy Transfer Company
Mont Belvieu Division Frac 6, 8
8774 FM 1942
Baytown, Texas 77521
12353 Eagle Pointe Drive
Mont Belvieu, Texas 77535
Chambers
Norman Rokyta
Senior Operations Manager
Norman.Rokyta@energytransfer.com
110070507074 / Standard Permit 148115 RMP 1000 0024 0759 32419 Other Petroleum and Coal Products Manufacturing Produce
Personnel participating in inspection:
Tony Robledo
U.S. EPA
Norman Rokyta
Energy Transfer Company
Jason Delafield
Energy Transfer Company
Miguel Salinas
Energy Transfer Company
Timothy Baker
Energy Transfer Company
Jose Lopez
Energy Transfer Company
Ray Orzabal
Energy Transfer Company
Terry Pool
Energy Transfer Company
Isaac Jackson
Energy Transfer Company
Adam Torpey
Energy Transfer Company
Rodrick Nunez
Energy Transfer Company
Kathie Harryman
Energy Transfer Company
Keegan Farrell
Energy Transfer Company
Robert Owens
Energy Transfer Company
Benson Sheffield
Energy Transfer Company
Lionel Cortinas
Energy Transfer Company
Benoit Lamarche
Energy Transfer Company
Kale Morris
Energy Transfer Company
Ethan Dillon
Energy Transfer Company
Inspector/Enforcement Officer Senior Operations Manager Supervisor Senior Safety Lead Frac Controller A Lead Frac Controller A PSM Manager Mont Belvieu Region Project Manager Mechanical Integrity Project Manager Mechanical Integrity Senior PSM Specialist Manager Audits Senior PSM Specialist Senior PSM Coordinator Senior Analyst Maintenance Planning Operation Manager Director Mechanical Integrity Senior Specialist Environmental Fractionation Operator B Fractionation Operator A
EPA Lead Inspector Signature/Date
Digitally signed by ANTHONY ROBLEDO
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: 2022.07.06 11:49:48 -05'00'
Tony Robledo
Supervisor Signature/Date
Tates, Samuel Date: 2022.07.06 12:23:32 -05'00' Digitally signed by Tates, Samuel
Samuel Tates
Energy Transfer Company/Mont Belvieu Division Frac 6, 8 Inspection Dates: 05/24/2022 - 05/26/2022
Section I - INTRODUCTION PURPOSE OF THE INSPECTION
I, Environmental Protection Agency (EPA) Region 6 inspector Tony Robledo, arrived at Energy Transfer GC NGL Fractionators LLC/Energy Transfer Company (ETC) at approximately 9:00 a.m. on May 24, 2022, for an announced inspection. I met with ETC managers and staff 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 Mont Belvieu Division Frac 6, 8 plant involves activities related to extraction and fractionation of products from raw Y-Grade natural gas liquids feed. The plant currently consists of one unit (Frac 6) started on February 19, 2019, and capable of processing approximately 150,000 barrels per day (BPD) of Y-Grade feed. When completed in 2024, Frac 8 will be essentially identical to the Frac 6 and will also be rated at 150,000 BPD. Y-Grade feedstock is delivered to Mont Belvieu via pipeline. Frac 6 and Frac 8 (when commissioned) are designed to produce purity ethane, propane, n-butane, isobutane, and national gasoline products. The facility handles regulated flammables above their threshold quantities. There are 24 full-time employees at this non-union facility. The plant operates 24 hours a day, 7 days a week.
Section II - OBSERVATIONS
I, as an EPA inspector, conducted a walk-through of the facility, accompanied by ETC personnel, to observe the facility process, equipment, and pressure vessels. I observed no spills, leaks, or fugitive hydrocarbon emission trails with the Forward Looking Infrared (FLIRTM) Series GF320 camera. Additional observations and findings are found on the RMP Program Level 3 Checklist, located in Appendix #1.
Section III - AREAS OF CONCERN
Closing Meeting - I convened a closing meeting on Thursday, May 26, 2022, to discuss the Areas of Concern (AOC) noted during the inspection, the inspection completion process, and to answer questions from ETC personnel.
AOC 1 - 40 C.F.R. 68.69(c) Operating Procedures
(c) The operating procedures shall be reviewed 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. The owner or operator shall certify annually that these operating procedures are current and accurate.
ETC provided a certification document that its operating procedures were current and accurate for the year 2021, but not for the year 2020.
On June 6, 2022, ETC provided a certification document that its operating procedures were current and accurate for the year 2020.
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AOC 2 - 40 C.F.R 68.79(d) Compliance Audits
Energy Transfer Company/Mont Belvieu Division Frac 6, 8 Inspection Dates: 05/24/2022 - 05/26/2022
(d) The owner or operator shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.
ETC conducted a compliance audit on January 25-26, 2022, with the compliance audit report completed on February 15, 2022. ETC failed to promptly document that corrective action had been initiated for two deficiencies. ETC noted that the two deficiencies are scheduled to be completed by December 31, 2022.
On June 6, 2022, ETC provided an email that stated a notice of recommendations, due dates for an operations management review, and a notice of communication to affected employees were all issued on May 4, 2022. ETC also stated that a Management of Change #6289 was created on May 19, 2022, for initiating a plan of action to resolve the findings from the compliance audit, and that procedures are currently under review with the operations unit.
AOC 3 - 40 C.F.R. 68.96(b)(1)(i) Emergency Response Exercises
(i) As part of coordination with local emergency response officials required by 68.93, the owner or operator shall consult with these officials to establish an appropriate frequency for field exercises.
ETC failed to document and establish, as part of its coordination with the local emergency response officials, an appropriate frequency for field exercises.
On June 17, 2022, ETC provided in an email that stated its Emergency Response Plan establishes, "the annual frequency of the drill and coordination with the local LEPC (Local Emergency Planning Committees)." ETC further noted in the email that, "due to COVID restrictions in place, per CDC mandates, a drill was not performed for the 2020 year." ETC also provided a document dated December 15, 2021, that states it provided its Emergency Response Plan to the Baytown LEPC.
AOC 4 - 40 C.F.R. 68.96(b)(1(ii) Emergency Response Exercises
(ii) Field exercises shall involve tests of the source's emergency response plan, including deployment of emergency response personnel and equipment. Field exercises should include: Tests of procedures to notify the public and the appropriate Federal, state, and local emergency response agencies about an accidental release; tests of procedures and measures for emergency response actions including evacuations and medical treatment; tests of communications systems; mobilization of facility emergency response personnel, including contractors, as appropriate; coordination with local emergency responders; emergency response equipment deployment; and any other action identified in the emergency response program, as appropriate.
ETC failed to conduct emergency field exercises in the years 2020 and 2021.
On June 6, 2022, ETC provided a full report of the emergency response plan tabletop drill that it conducted on May 24, 2021, and that the Local Emergency Planning Committee was notified.
On June 17, 2022, ETC provided in an email that stated, "due to COVID restrictions in place, per CDC mandates, a drill was not performed for the 2020 year."
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Section IV - FOLLOW UP
Energy Transfer Company/Mont Belvieu Division Frac 6, 8 Inspection Dates: 05/24/2022 - 05/26/2022
There were no additional records requested and no additional follow up for this 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.
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