EPA RMP citations after 19K pound NGL release (NGL & $42K)

A cryogenic natural gas liquid (“NGL”) facility with capacity to process approximately 1.0 billion cubic feet per day of raw natural gas while recovering around 1.4 gallons per million cubic feet of NGL product in the ethane rejection mode of operation suffered a release of approximately 19,000 pounds of NGL at the truck loading area on 10/9/2014. In the aftermath of the Release, EPA conducted an investigation pursuant to Section 114 of the CAA, to determine whether Respondent was in compliance with the Chemical Accident Prevention Provisions at 40 C.F.R. Part 68. EPA sent four information requests to Respondent to which Respondent responded with letters. Based on the information obtained in Respondent’s responses to the information requests, EPA determined that the truck loading area includes four 70,000-gallon NGL storage tanks and two NGL truck loading skids which consists of pumps, piping and instrumentation. The NGL consists of a mixture of highly flammable liquids. The flammable mixture consists of at least 1 % each of propane, pentane, isobutane, butane, isopentane, methane and ethane. All of these chemicals comprising the NGL constitute regulated substances pursuant to Section 112(r)(5) of the CAA, listed in 40 C.F.R. § 68.130, Table 3. The weight of the liquids in each 70,000-gallon storage tank containing NGL is greater than 10,000 pounds, at approximately 1,166,200 to 1,526,060 pounds.

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