EPA RMP citations @ speciality chemical plant (C3H6O, NH3, C6H13N & $27K)

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Respondent is the owner and/or operator of the Facility and has developed an RMProgram accidental release prevention program for the Facility. On July 23, 2019 – July 25, 2019, the EPA conducted an on-site inspection of the RMProgram related records and equipment for the purpose of assessing the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP) for its covered processes at its Facility.

At its Facility:

  • Respondent operates chemical manufacturing processes.
  • Respondent has on-site for use 1,400,000 pounds of vinyl methyl ether, 260,000 pounds of ammonia, and 130,000 pounds of cyclohexylamine.
  • Respondent has RMProgram level 3 covered processes, which store or otherwise use vinyl methyl ether, ammonia, and cyclohexylamine in amounts exceeding their applicable thresholds of 10,000 pounds, 10,000 pounds, and 15,000 pounds, respectively.

At the time of the inspection, the documented process safety information (PSI) “Process Safety Information:

  • Building 211 Sub Py Unit; Updated: 3/15/2015″ for the substituted pyrrolidones process was missing a safe upper limit value for a trip/alert point for a high-level alarm.
    • When the inspection team compared the piping and instrument diagram (P&IDs) with the process equipment in the field, the following inaccuracies were observed:
      • Ammonia storage tank (tank 335/3101) P&ID (D-C335-1001; Rev. 37):
        • The P&ID incorrectly showed the placement of thermal well (TW) and temperature transmitter (TT) 0002, pressure transmitter (PT) 0018, and pressure safety valve (PSV) 0006 on Line 3″-AL-104- 3Ll-C leading from the bottom of the tank to the ammonia pumps 335/3901 and 335/3902.
        • The P&ID showed these instruments and devices in the order of PSV-0006, PT- 0018, and TW/TT-0002 from upstream to downstream. However, the EPA inspection team observed the placement order to be TW/TT-0002, PT-0018, and PSV-0006 from upstream to downstream.
        • The P&ID incorrectly showed the placement of the unlabeled pressure gauge (PG) on line 1-1/2″-AL-105-3Ll-N. The P&ID showed the PG upstream of the junction of the discharges of the two pumps, but the EPA inspection team observed the PG downstream of the junction of the discharges of the two pumps, upstream of flow element (FE) / flow transmitter (FT) 0003.
      • At the top of the tank, the EPA inspection team observed a ¾”-line with a valve and line connector that was upstream of PT-0002 and was not shown on the P&ID.

 

  • Substituted pyrrolidones reaction section (211/3303 & 3305) P&ID (D- C21 l- 1001; Rev. 29):
    • The P&ID incorrectly showed the placement of PSV-0050, PSV- 0049A, and PSV-0049B. The P&ID showed the placement order to be PSV-0050, PSV-0049B, and PSV-0049A from upstream to downstream. However, the EPA inspection team observed the placement order to be PSV-0050, PSV-0049A, and PSV-0049B from upstream to downstream.
    • The P&ID showed a local PG, PG-0049B, upstream of PSV- 0049B. However, the EPA inspection team did not observe PG- 0049B in the field.
    • The P&ID stated that PSVs in this section relieved “To Atm at a safe location.” However, these PSVs relieved at an adjacent pipe rack, which is not a safe location.

 

  • Substituted pyrrolidones condenser and surge tank (211/3879, 3216) P&ID (D-C211-1006; Rev. 27):
    • The P&ID stated that the PSV on the accumulator (211/3887) overhead line, 211PSV-6220 relieved “to safe location.” However, this PSV relieved at ground level, which is not a safe location.

 The documented PSI “Process Safety Information:

  • Building 211 Sub Py Unit; Updated: 3/15/2015″ for the substituted pyrrolidones process was missing some relief system design bases. The sizing basis was missing and listed as “TBD” for the following PSVs: PSVs-0045A, 0045B, 0046, 0047, 0049A, 0049B, and 0050.

The inspection team observed the following equipment, that did not comply with RAGAGEP:

  • The EPA inspection team observed PSVs 211PSV-0022 and 211PSV-0022A on the substituted pyrrolidones reactor effluent line to relieve towards an adjacent pipe rack and the PSV 211PSV-6220 (on the substituted pyrrolidones accumulator) to relieve at grade from a pipe opening no greater than approximately two inches above the ground, neither of which met the following standard: ASME Boiler and Pressure Vessel Code (BPVC) Section VIII Division 1: Rules for Construction of Pressure Vessels; – 2017; Section UG-135(f), which states:

“Discharge lines from pressure relief devices shall be designed to facilitate drainage or shall be fitted with drains to prevent liquid from lodging in the discharge side of the pressure relief device, and such lines shall lead to a safe place of discharge. The size of the discharge lines shall be such that any pressure that may exist or develop will not reduce the relieving capacity of the pressure relief devices below that required to properly protect the vessel, or adversely affect the proper operation of the pressure relief devices.”

  • The ammonia storage tank (335/3101) did not have the required marking on at least two sides. ANSI/CGA G-2.1-2014, Section 6.6 states, “Each container or group of containers shall be marked on at least two sides, which are visible with the words, ANHYDROUS AMMONIA, or CAUTION-AMMONIA, in sharply contrasting colors with letters not less than 3.9 in (100 mm) high. “
  • The piping associated with the ammonia storage tank (335/3101) did not display a consistent system of labeling and coloring as specified in ASME A13.1-2015.

The EPA inspection team reviewed the “Sub-Py Area 211 Process Hazard Analysis” (PHA) conducted in October 2014 (report dated April 17, 2015).

  • The Facility siting checklist portion of the PHA identified that PSVs 211PSV-0022A and 211PSV-0022 relieved at a pipe bridge (another term for a pipe rack) and that PSV 211PSV-6220 relieved at ground level. These findings were given a risk level “next opportunity” for resolution. The PHA recommendations tracking sheet “Risk Action Progress” marked these actions as “closed.” However, the EPA inspection team observed in the field that PSVs 211PSV-0022 and 211PSV- 0022A still relieved at the pipe bridge and 21lPSV-6220 still relieved at ground level. The recommendations were not implemented and were overdue.

ALLEGED VIOLATIONS

Based on EPA’s compliance monitoring investigation, the EPA alleges that the Respondent violated 40 C.F.R. Part 68, the codified rules governing the Act’s Chemical Accident Prevention Provisions and Section 112(r) of the Act, 42 U.S.C. § 7412(r), when it:

  1. Failed to compile written PSI for the technology of the process which included safe upper and lower limits for such items as temperatures, pressures, flows or compositions as required by 40 C.F.R. § 68.65(C)(1)(iv);
  2. Failed to compile written PSI for the equipment in the process which included a P&ID as required by 40 C.F.R. § 68.65(d)(l)(ii);
  3. Failed to compile written PSI for the equipment in the process which included relief system design and design basis as required by 40 C.F.R. § 68.65(d)(l)(iv);
  4. Failed to document that equipment complies with RAGAGEP as required by 40 C.F.R. § 68.65(d)(2); and
  5. Failed to establish a system to promptly address the team’s findings and recommendations; assure that the recommendations were resolved in a timely manner, and that the resolution was documented; document what actions were to be taken; and complete actions as soon as possible; develop a written schedule of when these actions were to be completed; and communicate the actions to operating, maintenance and other employees whose work assignments were in the process and who may have been affected by the recommendations or actions as required by 40 C.F.R. § 68.67(e).

TERMS OF PAYMENT

Respondent consents to the payment of a civil penalty, which was calculated in accordance with the Act, in the amount of $26,872 which is to be paid within thirty (30) calendar days of the Effective Date of this CAFO.

 

CLICK HERE for the CAFO

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