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Cotton Valley Refinery

Parent Companies:
Calumet Specialty Products Co., L.P.
EPA Facility ID:
100000102603
Other ID:
71018KRRMCLA75
Facility DUNS:
0
Parent Company DUNS:
39049408

Location:

Address:
1756 Old Highway 7
Cotton Valley, LA 71018
County:
WEBSTER
Lat / Long:
32.801, -93.413 (Get map)
Method:
Interpolation - Map
Description:
Center of Facility
Horizonal accuracy:
12.2 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:
24000

Owner/Operator:

Name:
Calumet Specialty Products Co., L.P
Phone:
(318) 832-4232
Address:
P.O. Box 97
Cotton Valley, LA 71018
Foreign Address:

Person responsible for RMP implementation:

Name:
Charles Cost
Title:
Plant Manager

Emergency contact:

Name:
Charles M. Cost
Title:
Plant Manager
Phone:
(318) 832-4236
24-hour phone:
(318) 832-4236
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(318) 832-4236
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Webster Parish LEPC
Full-Time Equivalent Employees:
67
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
3080-00010-V9
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
June 13, 2017
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

LLSR Storage Tank T-1
RMP ID:
1000081313
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
210,000
No
Public OCA Chemical
0
No
Petroleum Spirits T-37&38
RMP ID:
1000081314
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
310,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
CK Associates
Address:
2001 East 70th Street Suite 503
Shreveport, LA 71105
Foreign Address:

Phone:
(318) 797-8636

Latest RMP Submission:

Date:
July 25, 2017
Type:
Resubmission
Reason:
Regulated substance present above TQ in new (or previously not covered) process (40 CFR 68.190(b)(4))
Registered:
Yes
RMP ID:
1000064837

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

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 LLSR Storage Tank T-1)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Blast walls
Public OCA Chemical (in Petroleum Spirits T-37&38)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • 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 LLSR Storage Tank T-1)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • 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

LLSR Storage Tank T-1, Petroleum Refineries (32411)
Prevention Program ID:
1000068431
Safety Review Date
June 21, 2017, since latest RMP submission
PHA Update Date
June 21, 2017, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 25, 2017, since latest RMP submission
Training Review Date
July 17, 2017, since latest RMP submission
Maintenance Review Date
May 15, 2017, since latest RMP submission
Maintenance Inspection Date
Feb. 20, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 1, 2016
Management of Change Review Date
March 16, 2017
Pre-startup Review Date
Feb. 20, 2017
Compliance Audit Date
Oct. 29, 2014
Compliance Audit Change Completion Date
Nov. 2, 2014
Incident Investigation Date
Jan. 3, 2015
Incident Invest. Change Completion Date
Jan. 7, 2015
Participation Plan Review Date
Nov. 3, 2016
Hot Work Review Date
March 15, 2017
Contractor Safety Review Date
June 6, 2017, since latest RMP submission
Contractor Safety Eval. Date
July 9, 2017, since latest RMP submission
Petroleum Spirits T-37&38, Petroleum Refineries (32411)
Prevention Program ID:
1000068432
Safety Review Date
June 21, 2017, since latest RMP submission
PHA Update Date
June 21, 2017, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 24, 2017, since latest RMP submission
Training Review Date
July 17, 2017, since latest RMP submission
Maintenance Review Date
May 15, 2017, since latest RMP submission
Maintenance Inspection Date
Oct. 19, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
March 16, 2017
Pre-startup Review Date
June 30, 2017
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Nov. 3, 2016
Hot Work Review Date
March 15, 2017
Contractor Safety Review Date
June 6, 2017, since latest RMP submission
Contractor Safety Eval. Date
July 9, 2017, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
June 30, 2017
Local Response Agency:
Local Response Agency Phone:
(318) 832-4231
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES



The Cotton Valley Refinery has a long-standing commitment to workers 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 the facility's processes. The Calumet 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.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES



Calumet operates the Cotton Valley Refinery located in Webster Parish, Louisiana. The Cotton Valley Refinery is a small specialty solvents plant capable of refining about 8,000 barrels per day (bbls/day) of sweet crude into various aliphatic solvents using both distillation and hydrotreating processes. These specialty solvents are transported offsite via rail, truck, and pipeline. As evidenced in the ensuing text and based on criteria outlined in the Accidental Release Prevention Program (ARP), the Cotton Valley Refinery is a Program 3 process.



The Cotton Valley Refinery was evaluated to determine if any regulated flammable or toxic substances were present in the process and if they exceeded the threshold quantity. All equipment and vessels are considered to be connected and/or co-located; consequently, for the purposes of the ARP Program, all equipment and vessels are part of a single process. The identification of even a single vessel exceeding threshold quantities of a regulated flammable or toxic substance would subject a process to threshold determination for offsite consequence analysis.



Calumet identified two regulated flammable substances and zero regulated toxic substances along with the largest single vessel quantity stored. Light Lean Straight Run (LLSR) and Petroleum Spirits were identified in two separate processes as
exceeding the RMP flammables threshold. The identification of these exceedances indicated that the Cotton Valley Refinery has two covered processes with regulated substances subject to the Accidental Release Prevention.



FIVE YEAR ACCIDENT HISTORY



The Cotton Valley Refinery has not had any accidental releases during the past five years that meet the criteria for an accidental release as discussed in 40 CFR 68.42.



LOCAL EMERGENCY RESPONSE COORDINATION



The Cotton Valley Refinery has coordinated its emergency response activities with the local emergency planning and response agencies as required in 40 CFR 68.90.



GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM



The following is a summary of the accident prevention program in place at the Cotton Valley Refinery. Because plant processes are subject to EPA's RMP regulations and to OSHA's PSM standards, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.



Employee Participation



The Cotton Valley Refinery actively encourages all levels of employees and contract employees to participate in creating a safe work environment. This participation begins with well established mechanisms of communication with all employees regarding covered process information. Employees are involved in maintaining PSM rule compliance based on their knowledge, skill, job responsibilities, and experience. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the plant.



Process Safety Information



The Cotton Valley Refinery maintains written information intended to provide a foundation for identifying and understanding the process hazards. This information addresses chemical properties, inventories, and associated hazards, as well as key process parameter limits and equipment design basis/configuration information. Specific department
s within the plant are assigned responsibility for maintaining up-to-date process safety information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in the material safety data sheets (MSDSs). This information is supplemented, when required, by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. In addition, the plant has documented safety-related limits for specific process parameters and ensures limit maintenance by using highly trained personnel, process controls, and monitoring and protective instrument systems.



The refinery also maintains documentation that provides information about the design and construction of process equipment. Equipment information includes construction materials, design pressure, and temperature and electrical ratings. This information also 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 Cotton Valley Refinery 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 Cotton Valley Refinery primarily uses the hazard and operability (HAZOP) study to perform these evaluations. A HAZOP uses a highly structured approach where process parameters such as flow and temperature are examined for deviations from their intended design. Deviation effects are considered in order to determine resulting potential hazards while preliminary recommendations for improvement are proposed.



The PHA team findings are promptly and systematically addressed. The Cotton Va
lley Refinery assures that the recommendations are documented and resolved in a timely manner. This documentation includes the actions to be taken and a written schedule of completion dates. The plant also provides proof of communication with operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations.



To help ensure that the process controls and/or process hazards do not eventually deviate from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years by the PHA team.



Operating Procedures



The Cotton Valley Refinery maintains written procedures that address various modes of process operations, such as (1) initial startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) emergency operations, (6) normal shutdown, and (7) startup following a turnaround or after an emergency shutdown. These procedures can be used as a reference by experienced operators and provide a consistent training basis for new operators. Operating procedures are periodically reviewed and certified as current. When a process change occurs, operating procedures are revised as necessary through the management of change process.



Training



To complement the written process operation procedures, the Cotton Valley Refinery has implemented a comprehensive training program for all employees. New employees receive job specific basic training in plant operations. Employee training includes emphasis on safety and health hazards, emergency shutdown operations, and safe work practices. Operators demonstrating adequate knowledge to safely perform duties and tasks are allowed to work independently.



Hot Work Permit



The Cotton Valley Refinery issues a hot work permit for all hot work operations conducted on or near a covered process. Procedures for issuing a hot work pe
rmit are clearly outlined in Calumet's Safety Manual. The Cotton Valley Refinery provides Hot Work Permit training to all plant employees. Copies of issued work permits are maintained in Operations and Maintenance for a period of 1 year following completion of work.



Contractors



The Cotton Valley Refinery periodically uses contractors to perform maintenance or repair, turnaround, major renovations, or specialty work on or adjacent to a covered process. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) are trained in the work practices necessary to safely perform his/her job, (2) have received and understood the training required and carry a training document card while on location, (3) follow the safety rules of the location including the safe work practices, (4) advise the plant of any unique hazards presented by the contractor, and (5) notify the facility of all illnesses and injuries that occur in the process areas.



Pre-Startup Safety Reviews (PSSRs)



The Cotton Valley Refinery conducts a PSSR for any facility modification that requires a change in the 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 an additional check to make sure that construction and equipment are in accordance with design specification, that adequate safety, operating, maintenance, and emergency procedures are in place, and that training of each employee involved in operating the process or equipment has been completed. A standard checklist is used to document compliance.



Mechanical Integrity



The Cotton Valley Refinery has well-established programs, procedures and practices that are required to ensure that equipment used to process, store, or handle lightly hazardous chemicals and/or flammable gas or liquid is designed,
constructed, installed, and maintained to minimize the risk of a release. Equipment examples include vessels, storage tanks, piping systems, and relief and vent systems with associated emergency shutdown systems and controls (i.e., monitoring devices, sensors, alarms, and interlocks).



Maintenance personnel receive training on (1) an overview of the process, (2) a review of the process hazards, and (3) the procedures applicable to the employee's job tasks to ensure that the employees can perform the job tasks in a safe and satisfying manner. Process equipment inspection and testing follows recognized and generally accepted good engineering practices. Equipment deficiencies that are outside of acceptable limits are corrected before further use or in a safe and timely manner when necessary means are taken to ensure safe operation.



Management of Change



The Cotton Valley Refinery has a comprehensive system to manage and document changes to all covered processes. A systematic approach is followed to control and manage facility changes in order to minimize the possibility that such changes will have an adverse impact on personnel safety, equipment, or the environment. Employees involved in process operations and maintenance and contract employees whose job tasks might be affected by process changes are informed of and trained in the change prior to process start-up.



Incident Investigation



The Cotton Valley Refinery 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. An incident investigation is initiated as promptly as possible to thoroughly investigate and analyze the incident. This investigation is lead by an incident investigation team consisting of those with appropriate knowledge and experience in the process. The findings and recommendations made by the incident investigation team are promptly addressed an
d resolved in a timely manner. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings.



Emergency Planning and Response



The Cotton Valley Refinery retains a written site specific formal emergency response plan which includes the designated actions the company and all personnel will take to ensure personal safety from fire and other emergencies. The plan outlines actions that company technicians and contract employees are to take when there is an unwanted release of highly hazardous chemicals. The intent of this plan is to facilitate the prompt evacuation of employees when necessary and to account for all personnel. The emergency plan also includes procedures for handling small releases.



Compliance Audits



To help ensure that the accident prevention program is properly functioning, the Cotton Valley Refinery 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. The audit team includes those knowledgeable in the process, operations personnel, and at least one person trained in audit techniques and practices. The audit team develops findings and corrective actions are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.