EPA RMP GDC Citations @ NG Plant (Hotwork and $35K)

A hotwork fire at a natural gas processing plant occurred while installing the 4 inch weld-a-let. Sweet dehydrated natural gas was released and ignited, causing a flash fire that lasted for approximately one second. As a result of the flash fire, hot gases and radiant heat were released through the 4 inch hole, burning the welder’s assistant on the neck and face. The welder’s assistant was transported by helicopter to a hospital for treatment.  The hazards associated with welding in and around piping that contains flammable or explosive substances are well established as are the standards for preventing or minimizing fires while welding in such areas.  

The processes at the Facility include compressor engines to pressurize the gas, and treatment to remove carbon dioxide, hydrogen sulfide and water from the natural gas, whereby sweet dehydrated natural gas liquids and natural gas are produced.

Natural gas is a flammable mixture containing methane, ethane, propane and butane, which are extremely hazardous substances listed in Table 3 of 40 CFR § 68.130 that may ignite, flashback or explode when exposed to a source of ignition. Pursuant to section 112(r)(1) of the CAA, 42 U.S.C. § 7412(r)(l), an owner/operator of a stationary source producing, processing, handling or storing substances listed pursuant to section 112(r)(3) of the CAA, 42 U.S.C. § 7412(r)(3), or any other extremely hazardous substance, has a general duty to: (1) identify hazards which may result from accidental releases of such substances using appropriate hazard assessment techniques; (2) design and maintain a safe facility, taking such steps as are necessary to prevent releases; and (3) minimize the consequences of accidental releases that do occur.

The release of natural gas at the Facility on May 17,2013, constituted an “accidental release” as that term is defined by section 112(r)(2)(A) of the CAA, 42 U.S.C. § 7412(r)(2)(A). Respondent failed to design and maintain a safe facility and did not take such necessary steps to prevent accidental releases by not ensuring safety during hot welding. Respondent’s failure constitutes a violation of the general duty clause in section 112(r)(1) of the CAA, 42 U.S.C. § 7412(r)(1).

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