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Calumet Gas Plant

Parent Companies:
Tejas Gas Processing, LLC
Tejas Natural Gas Liquids, LLC
EPA Facility ID:
Other ID:
Facility DUNS:
Parent Company #1 DUNS:
Parent Company #2 DUNS:


10 miles West of Morgan City
Calumet, LA 70392
Lat / Long:
29.691, -91.343 (Get map)
Interpolation - Other
Center of Facility
Horizonal accuracy:
Horizontal reference datum:
Source map scale:


Shell Western E&P Inc.
(504) 728-7920
P.O. Box 299
Patterson, LA 70392 -0299
Foreign Address:

Person responsible for RMP implementation:

J. Douglas Kotar
Plant Manager

Emergency contact:

J. Douglas Kotar
Plant Manager
(504) 728-7920
24-hour phone:
(504) 728-7920
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:


Local Emergency Planning Committee:
St. Mary Parish LEPC
Full-Time Equivalent Employees:
Covered by OSHA PSM:
EPCRA section 302:
CAA Title Air Operating Permit:
CAA Permit ID#:
OSHA Star/Merit Ranking
Last Safety Inspection Date:
Inspecting Agency:
Never had one
Using Predictive Filing:


Unspecified process
CBI claimed:
Program Level:
Oil and Gas Extraction (21111)
Chemical name
Quantity (lbs.)
Flammable Mixture
Flammable Mixture
Flammable Mixture
Flammable Mixture
Public OCA Chemical
Public OCA Chemical
Public OCA Chemical
Public OCA Chemical
Public OCA Chemical

RMP Preparer:


Foreign Address:


Latest RMP Submission:

Feb. 8, 1999
First-time submission


Effective Date:
Other Reason:

2. Toxics: Worst-case


3. Toxics: Alternative release


4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Unspecified process)
CBI claimed:
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Unspecified process)
CBI claimed:
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

, Oil and Gas Extraction (21111)
Prevention Program ID:
Safety Review Date
June 1, 1994, since latest RMP submission
PHA Update Date
June 1, 1994, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Reduced Inventory
  • Process Controls
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
May 25, 1998, since latest RMP submission
Training Review Date
Jan. 11, 1999, since latest RMP submission
Maintenance Review Date
Jan. 7, 1999, since latest RMP submission
Maintenance Inspection Date
Jan. 8, 1999, since latest RMP submission
Equipment Tested
Management of Change Most Recent Date
Jan. 8, 1999
Management of Change Review Date
Jan. 8, 1999
Pre-startup Review Date
Oct. 24, 1996
Compliance Audit Date
Jan. 18, 1998
Compliance Audit Change Completion Date
Feb. 28, 1998
Incident Investigation Date
Aug. 26, 1996
Incident Invest. Change Completion Date
Aug. 27, 1996
Participation Plan Review Date
Dec. 4, 1997
Hot Work Review Date
Dec. 30, 1998
Contractor Safety Review Date
Jan. 12, 1998, since latest RMP submission
Contractor Safety Eval. Date
Feb. 23, 1998, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Facility Own Response Plan:
Specific Facility Response Plan:
Inform. Procedures in Response Plan:
Emergency Care in Response Plan:
Plan Review Date:
Response Training Date:
Dec. 17, 1998
Local Response Agency:
Local Response Agency Phone:
(504) 380-4617
Subject To - OSHA EAP:
Subject To - CWA:
Subject To - RCRA:
Subject To - OPA:
Subject To - State EPCRA:
Subject To - Other:

Executive Summary

1.0 Calumet Gas Plant Risk Management Plan: Executive Summary


The Calumet Gas Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of facility's processes. The Shell Western E&P Inc. (SWEPI) policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to, control, and contain the release.


SWEPI operates the Calumet Gas Plant located in St. Mary Parish, Louisiana. Tejas Gas Processing, LLC is the owner of this facility. The Calumet Gas Plant is a refrigerated lean oil absorption plant which extracts natural gas liquids from an inlet stream of produced natural gas. The plant recovers natural gas liquids from the American Natural Resources (ANR) and Trunkline Pipeline Companies. Products are transported from the facility via pipeline and truck.

The Calumet Gas Plant was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, SWEPI identified the regulated substances and quantities kept on site. These are the quantities maintained in process vessels and piping at normal operating conditions and does not necessarily represent maximum capacities of the equipment.

Listed flammable substances which are stored above threshold quantities at the Calumet Gas Plant are condensate, rich/lean oil, propane, natural gas liquids, natural gas and sponge oil. However, SWEPI has determined that condensate has an NFPA flammability hazard rating of 3, which exempts this mixture from threshold determination. Based on worst-case analysis, the distance to the endpoint exceeds the distance to public r
eceptors. In addition, the Calumet Gas Plant is subject to OSHA PSM. Therefore, the Calumet Gas Plant is classified as a Program 3 process under the Accidental Release Prevention (ARP) program.


Flammable Substances - Worst-Case Scenario

The endpoint for worst-case release of flammable substances is 1 psi overpressure (i.e., 15.7 psia), resulting from a vapor cloud explosion. The ARP Program requirement for flammables assumes an instantaneous release and vapor cloud explosion. A yield factor of 10 percent of the available energy released in the explosion shall be used to determine the distance to the explosion endpoint. Since the worst-case release scenario for a flammable substance is based on the assumption that the entire quantity of the substance in a vessel forms a vapor cloud, passive mitigation systems are not applicable. The worst-case distance calculations were based on the largest vessel of each substance at 100% capacity. Natural gas liquids is the worst-case flammable release with a 0.53-mile distance to the endpoint.

Flammable Substances - Alternative-Case Scenario

A single alternative release scenario for all flammable substances is required under the ARP program. A hypothetical, but likely to occur, release scenario has been identified for propane as follows. A 2-inch pipe on the truck rack is sheared during loading, causing the entire contents to empty from the truck tank. The propane will vaporize and may ignite in a vapor cloud explosion with an endpoint of 1 psi overpressure or a vapor cloud fire with an endpoint of the lower flammability limit (LFL) for propane. The alternative-case release of propane resulted in a 0.28-mile distance to the 1 psi overpressure endpoint.

Toxic Substances

The Calumet Gas Plant does not have any toxic substances held above the threshold quantity. Therefore, analysis of worst-case or alternative release scenarios for toxic substances are not required.

The following is a summary of the of the accident prevention program in place at the Calumet Gas Plant. Because the processes at the plant that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulations are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.

Employee Participation

Active employee participation and involvement in the development and implementation of the Calumet Gas Plant's PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Employee involvement will help to ensure that all perspectives regarding PSM are considered, and that the best ideas are implemented. Open communications are encouraged between supervisors and employees regarding all safety and health issues.

The Calumet Gas Plant strongly promotes employee involvement in safety issues through existing programs. These programs include Unit Safety Teams (which are made up of a cross section of employees and supervision), regularly scheduled safety meetings, tail-gate safety meetings, Hazard Communication, Safety Suggestion Forms, "near-miss" reporting, and special training programs (emergency response training, first aid, etc.).

The Calumet Gas Plant actively seeks employee involvement in the development and conduct of all accident prevention activities through the appropriate existing safety programs. Accident and release prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments, or suggestions.

s Safety Information

Complete and accurate written process safety information (PSI) concerning process chemicals, process technology, and process equipment is essential to effective PSM and RMP programs and to completing and maintaining a process hazard analysis (PHA). The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans. Process safety information is readily available to all employees.

The Calumet Gas Plant keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.

Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs).

The gas plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.

Process Hazard Analysis (PHA)

The Calumet Gas Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.

The Calumet Gas Plant primarily uses the hazard and operabilit
y (HAZOP) and What-if/Checklist method analysis technique to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when they believe such measures are necessary.

The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained.

To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.

Operating Procedures

The Calumet Gas Plant maintains written procedures that address various modes of process operations, such as; (1) startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures provide guidance for experienced operators and also provide the basis for training new operators. Operating procedures are periodically reviewed and
annually certified as current and accurate. The review and certification process involves both operators and technical staff.

The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities. To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees. Operating procedures are specific instructions or details on what steps are taken or followed in caring out the stated procedures. The specific instructions include the applicable safety precautions and appropriate information on safety implications.


In addition to training on operating procedures, the Calumet Gas Plant has a comprehensive training program for all employees involved in operating the process. New employees receive basic training in plant operations. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator including the means used to verify that the operator understood the training.


The Calumet Gas Plant uses contractors during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the gas plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have appropriate knowledge and skills, (3) are aware of the hazards of their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site specific safety rules, and (6) inform gas plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with an orientation session that cover
s (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to beginning their work. In addition, the Calumet Gas Plant evaluates contractor safety programs and performance during the selection of a contractor. Gas plant personnel periodically monitor contract performance to ensure that contractors are fulfilling their safety obligations.

Pre-startup Safety Review (PSSR)

The Calumet Gas Plant conducts a PSSR on any new facility or facility modification that requires a change in process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with design specification and that all-supporting systems are operationally ready. The PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.

Mechanical Integrity

The Calumet Gas Plant has well established practices and procedures for maintaining process equipment. The basic aspects of this program include (1) training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting equipment deficiencies, when identified, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process.

Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner.

Another integral part of mechanical integrity program is quality assurance. The Calumet Gas Plant incorpo
rates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.

Safe Work Practices

The Calumet Gas Plant has long standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping and equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.

Management of Change

The Calumet Gas Plant has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.

Incident Investigation

The Calumet Gas Plant promptly investigates all incidents that resulted in or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental
loss, or personal injury. The goal of each investigation is to gather the facts, determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendation to prevent a recurrence, and forwards these results to the business management team for resolution.

Compliance Audits

To help ensure that the accident prevention program is functioning properly, the Calumet Gas Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Calumet Gas Plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.


The processes at the Calumet Gas Plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility.

Universal Prevention Activities

The accident prevention program summarized previously is applied to all RMP-covered processes at the Calumet Gas Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.

Specialized Safety Features

The Calumet Gas Plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes:

Release Detection

1. Hydroca
rbon detectors with alarms

Release Containment/Control

1. Process relief valves that discharge to a flare to capture and incinerate episodic releases
2. Valves to permit isolation of the process (manual or automated)
3. Automated shutdown systems for specific process parameters (e.g., high temperature)
4. Curbing or diking to contain liquid releases
5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)
6. Atmospheric relief devices

Release Mitigation

1. Fire suppression and extinguishing systems
2. Deluge system for specific equipment
1. Personnel trained in emergency procedures
3. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus)


The Calumet Gas Plant has an excellent record of accident prevention. Over the past 5 years there have been no accidental releases.


The Calumet Gas Plant maintains a written emergency procedure, which is in place to protect worker and public safety as well as the environment. The procedures are for the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address notification of local emergency response agencies if a release occurs, and post incident cleanup and decontamination requirements. Employees receive training in emergency procedures. The emergency procedure is updated when necessary based on modifications made to the Calumet Gas Plant. The emergency procedure changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes.

The overall emergency procedure program for the Calumet Gas Plant is coordinated with the St. Mary Parish, Louisiana, Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local go
vernment officials, and industry representatives. The Calumet Gas Plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Calumet Gas Plant conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the Calumet Gas Plant provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the plant.