Document zzLgyrgNBDE4M2EyQgyqQJQ2g

n EA~UnitcdStotcs ~ Env~runm~nt~l Prototio" '' Agency Region 6 Compliance Assurance and Enforcement Division INSPECTION REPORT Inspection Date(s): Media: Regulatory Program(s) 05/01/2018-05/03/2018 Air Clean Air Act Section 112(r) and 40 C.F.R. Part 68 Chemical Accident Prevention Provisions Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Contact: Targa Midstream Services LP Parent Company: Targa Resources Inc. Mont Belvieu Fractionator and Terminal 10319 Highway 146 North Mont Belvieu, Texas 77580 (same as above) (same as above) Chambers Bryan Crismon I Director of Operations bcrismon@targaresources.com FRS Number: Identification/Permit Number: Media Number: NAICS: 110054864036 Air Title V Permit No: 0-00612 RMP EPA Facility Identifier: 100000062969 211112 = Natural Gas Liquid Extraction Personnel participating in inspection: Tony Robledo US EPA/6EN-AS Bryan Crismon Targa Midstream Services LLC Inspector Director of Operations (214) 665-8182 (281) 385-3122 EPA Lead Inspector Signature/Date - 7CY> 14--t/2 .I Tony Robledo V S"/z'l../tR Date Supervisor Signature/Date .J!.._,.. ,,/) 1~ Samuel Tates s I t.t../ l.OtB Date 6ENFORM-019-R6 (10/6/14) 1 Targa Midstream Services LP, Mont Belvieu Fractionation and Terminal Inspection Date 05/01-03/2018 Section I - INTRODUCTION PURPOSE OF THE INSPECTION United States Environmental Protection Agency (EPA) Region 6 inspector Tony Robledo arrived at the Targa Midstream Services LP (Targa), Mont Belvieu Fractionator and Terminal, at approximately 9:00a.m. on May 1, 2018, for an announced inspection. I conducted an opening meeting with the following persons in attendance as identified in Table 1. Name Bryan Crismon Rick Brummett Ken McGraw Jenen Barillas Brandon Thornhill Brittany Roca Jarrod Gregg Stephen Bland Mike Taylor Tony Robledo Table 1: Opening Meeting Attendance Position . Director of Operations Maintenance Inspector Maintenance Supervisor Environmental Specialist Safety Supervisor Senior Environmental Specialist ESH Manager Gulf Coast Maintenance Manager Operations Manager Inspector & Enforcement Officer EPA Region 6 I presented my credentials to all attendees at the opening meeting, and informed them that this EPA inspection was to determine compliance with Clean Air Act 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 Complex is a facility which receives refinery products and raw natural gas liquids from pipelines, railcars, and trucks and fractionates it into ethane, propane, butanes, pentanes and other liquefied petroleum gas mixtures. The liquids are stored onsite in underground storage caverns and above ground storage tanks and then delivered to market via pipeline, railcars, and transport vehicles. There are no listed toxic substances which exceed their respective threshold quantities stored at this facility. The facility has 250 full-time employees. Section II- OBSERVATIONS I conducted a walk-through of the facility on May 2, 2018, accompanied by Targa personnel to observe the facility process, equipment, storage tanks, and operation. I observed no spills, leaks, or air emissions with the FUR Series GF320 infrared camera. The facility grounds appeared to be well maintained. I did observe the construction of a new fractionation unit called Train 6 which is expected to be completed early next year. 2 Targa Midstream Services LP, Mont Belvieu Fractionation and Terminal Inspection Date 05/01-03/2018 40 C.F.R. Part 68:... CHEMICAL ACCIDENT PREVENTION PROVISIONS Subpart A- General 40 C.F.R. 68.10 Applicability- Targa is an owner and operator of a stationary source that has more than a threshold quantity of regulated flammable substances, listed in 40 C.F.R. 68.130, in a process, and as such is subject to these Chemical Accident Prevention Provisions. Targa listed the NAICS code (211112) natural gas liquid extraction, as the process in its Risk Management Plan (RMP). The Targa facility process is also subject to the Occupational Safety and Health Administration (OSHA) process safety management standard, 29 C.F.R. 1910.119. These factors make the process at the Targa facility a Program 3 subject to 40 C.F.R. 68.10(d). 40 C.F.R. 68.12 General Requirements- Targa re-submitted a RMP five-year update on June 20, 2014. This submittal lists a covered process for Program 3. This requires the facility to develop and implement a management system, conduct a hazard assessment, implement the prevention requirements of 40 C.F.R. 68.65- 68.87, develop and implement an emergency response program, and submit the data elements from 40 C.F.R. 68.175 in their RMP. 40 C.F.R. 68.15 Management- Targa has an established management system to oversee the implementation of the risk management program elements, and has assigned a qualified person or position that has the overall responsibility for the development, implementation, and integration of the risk management program elements. Targa facility personnel provided an organization chart which documents the persons responsible for implementing individual requirements of the RMP as required by this subpart. Subpart B- Hazard Assessment 40 C.F.R. 68.20 Applicability- Targa is an owner or operator of a stationary source subject to this subpart with a Program 3 process that must prepare an offsite consequence analysis as provided in 68.25 of this subpart, complete the five-year accident history as provided in 68.42, and comply with all sections in this subpart for this process. 40 C.F.R. 68.22 Offsite Consequence Analysis Parameters -I requested documentation of the offsite consequences analysis. I reviewed the documentation provided and had a discussion with appropriate Targa facility personnel. Targa applied the offsite consequence analysis parameters as required by this subpart. 40 C.F.R. 68.25 Worst-Case Release Scenario Analysis- Targa identified and reported a worst-case release scenario analysis for the RMP covered flammable substances. I requested documentation of the worst-case release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate Targa facility personnel. Targa selected butane well number 25 for the worst-case release scenario. Targa used EPA's RMP Offsite Consequence Analysis Guidance to determine the distance to the endpoint in the worst-case release scenario. Targa used the proper endpoints for flammables as required by this subpart. 40 C.F.R. 68.28 Alternative Release Scenario Analysis- Targa identified and reported an alternative release scenario for the RMP covered flammable substances. I requested documentation of the alternative release scenario analysis. I reviewed the documentation provided and had a discussion with appropriate Targa facility personnel. Targa selected its propane loading terminal as its alternative 3