At the Facility, Respondent produces, processes, stores, or handles more than 10,000 pounds of ethylene oxide. On November 3, 2019, the Glycol 2 Production Unit experienced a release of ethylene oxide. Respondent’s Glycol 2 Production Unit experienced an ethylene oxide release involving the knockout pot D-410 of the Ethylene Oxide Scrubber Process. In response to level fluctuations in acid scrubber T-410, the control system shutdown the ethylene oxide vents to D-410. In response to the low pressure on T-4l0, the operator manually opened the automated D-410 valve for a few seconds in an effort to maintain enough pressure on T-410. Based on the high level of acid in T-410, this effort resulted in an undesired backflow of 5% sulfuric acid from T-410 into the overhead line for D-410 when flow was reestablished. Once the acid and liquid ethylene oxide mixed in D-410, the reaction resulted in an immediate overpressure and burst of the drum D-410, which resulted in the release of 28.8 pounds of ethylene oxide. Facility Emergency Services were notified of a ruptured vessel, the lines were isolated, and the release stopped.
VIOLATION
Operating Procedures 40 C.F.R. § 68.69(a)(1)(vii)
40 C.F.R. § 68.69(a)(1)(vii) requires the owner or operator to develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements. (1) Steps for each operating phase: …
(vii) Startup following a turnaround, or after an emergency shutdown.
Respondent’s effort to control the pressure in the scrubber by manually opening an automatic valve led to the introduction of sulfuric acid with liquid ethylene oxide in D-410, which burst the vessel, was the cause of the release and a violation of 40 C.F.R. §68.69(a)(1)(vii).
CIVIL PENALTY AND TERMS OF SETTLEMENT
Upon consideration of the entire record herein, and upon consideration (in addition to such other factors as justice may require) of the size of the business, the economic impact of the penalty on the business, the violator’ s full compliance history and good faith efforts to comply, the duration of the violation, payment by the violator of penalties previously assessed for the same violation, the economic benefit of noncompliance, and the seriousness of the violation, the parties agree Thirty-eight thousand and five hundred dollars ($38,500.00) is an appropriate penalty to resolve this matter.
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