Respondent owned and operated a Natural Gas Processing facility, which produces, processes, stores, or handles more than 10,000 pounds of a flammable mixture, including pentane, isobutate, isopentane, butane, propane, and ethane in the form of natural gas, natmal gas liquids, condensate, and/or crude oil. Pentane, isobutate, isopentane, butane, propane, and ethane are identified at 40 C.F.R. § 68.130 as regulated flammable substances with a threshold quantity of 10,000 pounds. On December 3, 2015 (“the day of the incident”), the Facility experienced a fire and secondary explosion as described below.
Special NOTE: Facility was cited because their HW permit did not require the “object to be worked on” be identified and a review of closed permits indicated the permits were vague and did not identify the objects upon which HW was performed
The Facility receives inlet gas that is not dehydrated in the field via six pipelines. On the day of the incident, the inlet gas passed through a series of slug catchers to remove liquids. The gas was then processed, compressed, and sent to sales, while the natural gas liquids were removed from the stream and trucked off-site.
- On the day of the incident, and because the inlet gas is not field dehydrated, the Facility used two upstream systems to prevent the formation of ice or gas hydrates.
- On the day of the incident, the first ice/hydrate prevention system was a line heater. Currently, the only ice/hydrate prevention system is a methanol injection system.
- On November 23, 2015, the line heater was struck by hydrate formed upstream in the pipe and removed from service
- On the morning of the day of the incident, a partial ice or hydrate restriction formed in the LCV-1151 control manifold.
- On the day of the incident, the restriction likely formed due to a drop in ambient temperature, combined with a pressure drop across the control valve, resulting in a downstream auto-refrigeration effect.
- On the day of the incident, facility personnel had no way to monitor whether the methanol injection system was operational.
- On the day of the incident, facility personnel blocked in the LCV-1151 control valve manifold in a hydrocarbon liquid full condition by closing an upstream manual block valve and a downstream shutdown valve, then facility personnel applied hot water from a heated pressure washer directly to the closed piping system in an attempt to remove the suspected hydrate or ice. The application of heat to the closed system likely resulted in a rapid and significant increase in pressure, potentially greater than 4,500 psig, due to thermal expansion of the liquid. This increase in pressure compromised the integrity of the level control valve and/or the control valve manifold piping, both of which had design pressures of 1,440 psig. When control room personnel reopened the downstream shutdown valve and attempted to verify flow using bypass valves on the LCV -1151, the compromised valve and associated pipe system was re-pressurized. As pressure increased above that of the downstream vessel, a loss of primary containment occurred, and the released hydrocarbons ignited immediately.
The source of ignition was likely the heated pressure washer.
The control room operator initiated an emergency shutdown and ordered the evacuation of all personnel from the facility.
Because the bypass valves on the LCV -1151 control manifold were still open and the downstream shutdown valve was closed, the piping manifold quickly pressurized to the inlet slug receiver area’s (also known as the HARP unit area) operating pressure, and volatile hydrocarbon liquids flowed uncontrolled through the partially opened bypass valve into the compromised level control valve manifold and then to atmosphere.
The fire burned for approximately twenty-five minutes before the occurrence of a secondary explosion at or near the inlet slug receiver area.
The HARP unit was full of hydrocarbon liquids at the time of the explosion, resulting in the release of approximately 1,500 barrels of volatile and pressurized (1000 psig) natural gas liquids in the explosion.
There were no known injuries as a direct result of the fire or the secondary explosion, but during the evacuation, facility personnel experienced two recordable injuries and three non-recordable injuries which required first aid treatment.
Three County Roads were closed to protect the general public.
On June 29-30, 2016, EPA Region 6 personnel conducted an on-site inspection of Respondent’s Facility to determine compliance with CAA 112(r)(7), 42 U.S. C. § 7412(r)(7), and 40 C.F.R. Part 68. During the inspection, EPA personnel reviewed the Facility’s RMP, as well as hot work permits issued by the facility.
- The inspection revealed that hot work permits issued by the facility were often general and unspecific, failing to identify the object on which hot work is to be performed.
- The inspection also revealed that Respondent failed to update its RMP to reflect a change in emergency contact information within one month of changing that information.
VIOLATIONS
Count 1 – Failure to Design and Maintain a Safe Facility
Pursuant to Section 112(r)(1) of the CAA, the owners and operators of stationary sources producing, processing, handling or storing listed or other extremely hazardous substances have a general duty to identify hazards which may result from such releases using appropriate hazard assessment techniques, to design and maintain a safe facility taking such steps as are reasonably necessary to prevent releases, and to minimize the consequence of accidental releases which do occur.
On the day of the incident, Respondent failed to maintain the line heater it had in place to prevent the formation of ice or hydrate.
Respondent’s failure to design and maintain a safe facility constitutes a violation of Section 112(r)(1) of the CAA, 42 U.S.C. § 7412(r)(1).
Count2 – Failure to Develop and Implement a Safe Procedure
Pursuant to 40 C.F.R. § 68.69(a), the owner or operator shall develop and implement written operating procedures that provide clear instructions for safely conducting activities involved in each covered process. Such operating procedures shall include safety and health considerations related to the properties of and hazards presented by the chemicals used in the process, precautions necessary to prevent exposure, and any special or unique hazards.
The procedure put in place on December 3, 2015, to use the heated pressure washer to eliminate ice or hydrates failed to consider the consequences of pressurizing a closed system, ultimately leading to a loss of primary containment, fire, and a secondary explosion.
Respondent’s failure to develop and implement a safe procedure for the removal of ice or hydrates constitutes a violation of 40 C.F.R. § 68.69(a).
Count 3 – Failure to Properly Document Hot Work Permits
Pursuant to 40 C.F.R. § 68.85(a), owners and operators shall issue a hot work permit for hot work operations conducted on or near a covered process. Pursuant to 40 C.P.R. § 68.85(b ), each hot work permit shall document that the fire prevention and protection requirements in 29 C.P.R.§ 1910.252(a) have been implemented prior to beginning the hot work operations, shall indicate the date(s) authorized for hot work, and shall identify the object on which hot work is to be performed.
Respondent used generally-issued hot work permits, which failed to identify the object on which hot work was to be performed.
Respondent’s failure to properly issue its hot work permits constitutes a violation of 40 C.F.R. § 68.85(b).
Count4 – Failure to Update Emergency Contact Information
Pursuant to 40 C.F.R. § 68.195(b), within one month of any change in the emergency contact information required under § 68 .160(b)(6), the owner or operator shall submit a correction of that information. Respondent failed to update its emergency contact information within the timeline required by 40 C.F.R. § 68.195(b). This failure to update the emergency contact information constitutes a violation of 40 C.F.R. § 68.195(b).
CIVIL PENALTY AND TERMS OF SETTLEMENT
Pursuant to the authority granted in Sections ll3(d) of the CAA, 42 U.S.C. § 7413(d), and taking into consideration 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, the seriousness of the violation, and other factors as justice may require, the parties agree that two hundred twenty-six thousand dollars ($226,000) is an appropriate penalty to resolve this matter.
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