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Region 6 Compliance Assurance and Enforcement Division
INSPECTION REPORT
Inspection Date(s): Media: Regulatory Program(s)
Company Name: Facility Name: Facility Physical Location :
August 20-23, 2018 Air Clean Air Act Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions
Chevron Phillips Chemical Company LP Pasadena Plastics Complex 1400 Jefferson Rd
(city, state, zip code)
Pasadena, TX 77506
Mailing address: (city, state, zig code)
County/Parish: Facility Contact:
1400 Jefferson Rd Pasadena , TX 77506 Harris Gary Piana- (713)475-3666
I Plant Manager
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FRS Number: Identification/Permit Number: Media Number : NAICS: SIC:
110000462730
EPA Facility Identifier: 100000126375 325211 Plastics Material and Resin Manufacturing 2869 Plastics Material and Resin
Personnel participating in inspection:
Gary Pia na
Chevron Ph illips Chem ical
Jeff Nicki
Chevron Phillips Chemical
Paula Wiley
Chevron Phillips Chemical
James Allred
Chevron Phillips Chemical
Michael Dykhouse
Chevron Phillips Chemical
Pam Colon
Chevron Phillips Chemical
Joe Reynolds
Chevron Phillips Chemica l
Blake Sieminski
US EPA
Area Manager EHS&S PSM Supervisor Asset Integrity Manager Operations Manager Training Supt. Emergency Response/Security Coordinator Inspector/ Enforcement Off.
(713)475-3666 (713)475-3666 (713)475-3666 (713)475-3666 (713)475-3666 (713 )47 5-3 6 6 6 (713)475-3666
(214)665-8062
EPA Lead Inspector Signature/Date
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
Blak/ Sieminski
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Supervisor Signatu re/ Date
Samuel Tates
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Date
I or /!1-J/bt/1
Date
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GENFORM-019-RG (10/6/14)
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Chevron Phillips. I Pasadena Plastics Complex
Inspect ion Date 8/ 20-23/ 2018
Section I - INTRODUCTION
PURPOSE OF THE INSPECTION
United States Environmental Protection Agency (EPA) Region 6 inspector Blake Sieminski arrived at the Pasadena Plastics Complex at approximately 2:00 .PM on Monday August 20, 2018 for an announced inspection. I met with Jeff Nicki, Paula Wiley, and Gary Piana and multiple Chevron Phillips Company (CPC) employees. I presented my credentials and informed them that this was an EPA inspection to determine compliance w ith the facility's Chemical Accident Prevention Provisions program. The scope of the inspection is a partial compliance evaluation (PCE) and included evaluation of the compliance of t he facility with the Clean Air Act (CAA) Section 112(r) and the Chemical Accident Prevention Provisions (40 C.F.R. Part 68). The Pasadena Plastics Complex (PPC) is listed as a Risk Management Plan (RMP) Program three {3) facility. The Pasadena Plastics Complex is a union facility. The Texas Co.m;.;..;.;m..;.;.i;..s:..s;:..i:.o:..:.n...:..o-=..n.;.;.._ _ __ _ _ _ __ Environmental Quality was notified of this PCE inspection.
Gary Piana Cathy Gill Jeff Nicki Mark A. Garza Joe Reynolds
Lisa Moseley Trey Griffin Paula Wiley Krista Boone
Craig Peikert James Allred Cory Miller Michelle Gates Paul Waite Jason Wright . Vasser Qutub Trish Badall Michael Dykhouse Anthony N. Jackson Chad Thomas Manzoor Khan Chris Hunt Travis Hensley Blake Sieminski
Table 1: Opening Meeting Attendance; Monday August 20, 2018
Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical
Chevron Phillips Chemica l Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical
Chevron Phillips Chemica l Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemica l Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical
Plant Manager EH&S/ Tech Manager EHS&S Superintendent Environmental Supervisor Emergency Response/Security Coordinator Procurement Manager QA Superintendent PSM Supervisor Projects and Engineering Team Lead I.T. Manager Asset Integrity Manager Safety Supervisor Fi nance Manager P&S SOPT. Reliability Lead Process and Controls lead Fixed Equipment lead
Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phillips Chemical Chevron Phi llips Chemica l Chevron Phillips Chemical U.S. EPA
Operations Manager Maintenance Manager PEG OPS Supt. PES OPS Su pt. IEC Superintendent PE7 OPS Supt. Inspector/ Enforcement Off.
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Chevron Phillips. I Pasadena Plastics Complex
Inspection Date 8/20-23/20 18
FACILITY DESCRIPTION
Chevron Phillips ChemicallP operates a plastics material and resin manufacturing facility. The facility is located in Pasadena, Texas. PPC is a facility which receives and/or stores various regulated flammable chemicals by trucks, and pipelines. The products onsite include propane, isobutane (propane, 2methyl), and ethylene (ethene). The facilit y employs approximately 340 employees and 75 contractors.
Section II- OBSERVATIONS
On Wednesday August 22, 2018, Jeff Nicki, Michael Dykhouse and I conducted a site drive-through of the facility to observe the covered process, equipment and operations. The facility has three (3) Polyethylene Plants known as PE6, PE7 and PES. We toured worst case scenario reactor 8-1 which is a reactor in PES due to proximity to the neighboring Calpine steam plant and walked t hrough the control room of PE7 and saw hydrocarbon unloading.
40 C.F.R. Part 68- CHEMICAL ACCIDENT PREVENTION PROVISION
Subpart A- General
40 C.F.R. 68.10 Applicability -I observed that PPC is a stationary source, with a CAA Title-V permit (ID 0 -01315) that has more than a threshold quantity of regulated substances in their process. PPC resubmitted a RM P (5-year update 40 CFR 68.190 (b)(1)) on May 31, 2018, that described the process containing flam mables held at more than a threshold quantity. PPC is a RMP Program 3 facility. PPC is subject to the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Standard (29 CFR 1910.119).
40 C.F.R. 68.12 General requirements- I reviewed there-submission of PPC's RMP that was resubmitted on May 31, 2018, that lists flammable chemicals for a Program level 3 process.
40 C.F.R. 68.15 Management- PPC developed a management system to oversee t he implementatio n of the risk management program elements. The organizational chart that was provided to me outlined the positions to implement the individual elements of the RMP as required by this subpart.
Subpart B- Hazard Assessment-
40 C.F.R. 68.20 Applicability- PPC is a Program 3 stationary source subject to this part. The facility is required to prepare an offsite consequence analysis and complete the five-year accident history.
40 C.F.R. 68.22 Offsite consequence analysis parameters- I reviewed the offsite consequence analysis and supporting documentation. I reviewed the documents and discussed with Paula Wiley to assure the data was accurate and t o confirm the parameters used by PPC to document this data.
40 C.F.R. 68.25 Worst-case release scenario analysis- PPC ident ified and documented a worse-case release scenario analysis for the RMP covered flammable substances. The distance to endpoint for f lammable substances was calculated using RMP*Comp'M.
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