EPA has announced two Clean Air Act settlements with a natural gas processor in which the company has agreed to pay a total of $316,000 in penalties for violating Risk Management Plan provisions at natural gas plants in Casper and Douglas, Wyoming. In addition, the company has agreed to establish new operating procedures, improve equipment maintenance, and perform integrity tests on pressure vessels to reduce the possibility of an accidental release of hazardous chemicals at both facilities. UPDATED with specific citations…
from the FINAL ORDER:
The alleged violations are:
Management System
40 C.F.R. §68.15 provides that the owner or operator shall develop a management system to oversee the risk management program elements. An up-to-date management system with the names or positions of individuals responsible for risk management program elements was not available during the EPA inspection. This is a violation of 40 C.F.R. § 68.15.
Maintenance Procedures
40 C.F.R. §68.73(b) provides that the owner or operator shall establish written procedures to maintain the on-going integrity of process equipment. Furthermore. the owner or operator shall comply with the requirements of 40 C.F.R. part 68 no later than the dates listed in 40 C.F.R. §68.10. Written procedures to maintain the on-going integrity of process equipment were not established on or before the date which a regulated substance was first present above a threshold quantity in a process. This is a violation of40 C.F.R. § 68.73(b).
MI Inspection/Testing RAGAGEP
40 C.F.R. §68.73(d)(2) provides that inspection and testing procedures shall follow recognized and generally accepted good engineering practices. Inspections and testing procedures performed on multiple process vessels including, but not limited to:
- process vessel 16.17 (demethanizer)
- process vessel 16.26 (demethanizer surge tank)
- process vessel 721-95-37 (propane accumulator)
- process vesse l 721-95-41 (propane storage tank)
- process vessel 95-45 (low temp separator)
- process vessel 95-38 (deethanizer feed tank)
- process vessel 95-6 (high pressure NGL storage vessel)
did not follow recognized and generally accepted good engineering practices (RAGEGEPs).
- Condition Monitoring Locations were not in accordance with the American Petroleum Institute’s (API) Pressure Vessel Inspection Code (510).
- Construction and design information was not available for review in accordance with API 510.
- The name of the person performing the inspection andlor examination was not documented in the inspection reports. in accordance with API 510.
This is a violation of 40 C.F.R.§ 68.73(d)(2).
MI Inspection/Testing Manufactuer’s Recommendation
40 C.F.R. §68.73(d)(3) provides that the frequency of inspections and tests of process equipment shall be consistent with applicable manufacturers’ recommendations and good engineering practices.
- The frequency of inspections and tests performed on multiple process vessels including, but not limited to,
- process vessel 16. 17 (demethanizer)
- process vessel 16.26 (demethanizer surge tank)
- process vessel 721-95-37 (propane accumulator)
- process vessel 721-95-41 (propane storage tank)
- process vessel 95-45 (low temp separator)
- process vessel 95-38 (deethanizer feed tank) and
- process vessel 95-6 (high pressure NGL storage vessel)
were not consistent with good engineering practices. Inspection frequencies for external inspection, internal inspection, and/or nondestructive examination were not in accordance with API 510. This is a violation of 40 C.F.R. §68.73(d)(3).
MI Equipment Deficiencies
40 C.F.R. §68.73(e) provides that the owner or operator shall correct deficiencies in equipment that are outside acceptable limits before further use or in a safe and timely manner when necessary means are taken to assure safe operation.
Process vessel 72 1-95-37 (propane accumulator) had deficient shell thickness readings that were below minimum wall thickness requirements, as calculated by the Respondent. At the time of the EPA inspection this deficiency was not addressed. This is a violation of 40 C.F.R. §68.73(e).
CLICK HERE (pdf) to see the Final Order