The process at the Facility involves the separation of propane, butane, ethane and isobutane from the incoming natural gas using compressors and a process skid. The separated gases are stored together in a 10,000-gallon storage tank, which when full weighs 67,000 pounds, for transportation off-site. The National Fire Protection Administration’s Code 58, Liquefied Petroleum Gas Code, 2011 Edition, (“NFPA 58”) applies to the storage, handling, transportation, and use of liquefied petroleum gas at the Facility. The inspection revealed a number of concerns at the Facility:
- Inspectors noted that piping to the liquefied petroleum gas (“LPG”) storage tank in the outside process area at the Facility was partially buried. The piping was not protected or coated in accordance with subsection 6.16.1 of NFPA 58, which requires that “[a]ll metallic equipment and components that are buried or mounded shall be coated or protected and maintained to minimize corrosion.”
- Inspectors noted that piping to the LPG storage tank in the outside process area was partially aboveground and was not protected against corrosion. Subsection 6.9.3.11 ofNFPA 58 requires that “the portion of aboveground piping in contact with a support or a corrosion-causing substance shall be protected against corrosion.”
- Inspectors noted excessive vibration of the refrigeration compressor skid and its associated piping. Inspectors determined that the vibration was caused by the improper support of the skid. Subsection 6.17.3.1 ofNFPA 58 requires that compressors be installed in accordance with manufacturer’s installation instructions. Subsection 6.17.3.2 ofNFPA 58 requires that the “Installation shall be made so that the compressor housing is not subjected to excessive stresses transmitted to it by the suction and discharge piping.” Subsection 6.9.3.9 ofNFPA 58 requires that “Piping systems, including the interconnection of permanently installed containers, shall compensate for expansion, contraction, jarring, vibration, and settling.”
- During the inspection, Respondent provided process information for the storage tank, but did not provide process safety information for all of the process equipment or associated piping.
- The most recent Process Hazard Review (“PHR”), which was presented to inspectors during the inspection, was conducted on Jupe 29, 2005 for the storage tank only and did not review all of the process equipment at the Facility, including the process equipment skid, compressor skids, piping, etc.
- As ofthe date of the inspection, Respondent had not updated or revalidated the PHR (dated June 29, 2005) every five years.
- During the inspection, Respondent did not provide operating procedures for all of the process equipment at the Facility, which are required to be prepared by 40 C.F.R. § 68.52. Respondent provided operating procedures for the storage tank, but not for the process skid, piping or the compressors or for activities related to the process equipment.
- During the inspection, Respondent did not provide any evidence of training and/or refresher training of employees in the operating procedures required by 40 C.F.R. § 68.54, which states that employees must be trained in all of the operating procedures that pertain to their duties.
- As of the time of the inspection, periodic maintenance of compressors at the Facility was performed by contractors; day-to-day maintenance of compressors and other equipment was performed by Facility personnel. During the inspection, Respondent did not provide documentation of maintenance procedures, maintenance training and process equipment inspections, required to be undertaken in accordance with 40 C.F.R. § 68.56.
- During the inspection, Respondent provided no documents demonstrating that compliance audits were conducted on all process equipment at the Facility. Compliance audits are required by 40 C.F.R. § 68.58 to be conducted every three years.
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