Houston Ammonia Terminal - Executive Summary |
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Houston Ammonia Terminal L. P. (HAT) is a joint venture between Mississippi Chemical Corporation (MCC) and Potash Corporation of Saskatchewan, Incorporated. Both of these companies are major manufacturers of fertilizers. HAT is committed to safety and the environment and stands behind the commitment with the following company policy. HAT and its employees have an enduring commitment to protecting health, safety and the environment. In order to document that commitment, the company has authorized a Health, Safety and Environmental Statement of Policy. Laws, rules and regulations in the area of health, safety and the environment impose responsibilities on the Company and its employees. An additional purpose of this policy is to set forth the principles, under which those responsibilities are to be fulfilled, thereby providing appropriate protection for employees, as well as the Company. Employee Health and Safety Workplace health and safety are of paramount concern. The Company and its employees are expected to be aware of and adhere to laws, regulations, company policy and procedures designed to ensure safe and healthy workplace conditions and practices. Contractors and Visitor Health and Safety All contractors working in the Company facility or visitors to Company facilities are expected to be aware of and adhere to all company health, safety and environmental policies and procedures. The Company may conduct, or require proof of, appropriate training. Environment In all its activities, the Company will remain sensitive to environmental concerns and the need for sound environmental practices. The Company and its employees are expected to be aware of and adhere to laws, regulations, company policy, and company procedures designed to ensure that the Company's activities are in compliance with all federal, state and local environmental laws and regulations. Minimization of Risks and Releases to the Environment and Conservation of Natural Resources It is the poli cy of the Company to minimize the environmental, health and safety risks to its employees and the communities in which it operates, to minimize releases to the environment, to conserve natural resources through efficient use and careful planning, to recycle materials whenever technically and economically feasible, and to dispose of wastes in a manner determined to be environmentally sound. Compliance with Laws The activities of the Company and its employees are expected to be in full compliance with all applicable laws, rules and regulations relating to health, safety and the environment. Assistance to Government It is the policy of the Company to participate with all levels of government in the development of equitable and effective health, safety and environmental laws, rules and regulations. Employee Training It is the Company's continuing policy to inform and educate each employee regarding health, safety and environmental laws and regulations applicable to his or her job. Throu gh such training, the employee is responsible for learning and maintaining knowledge of the health, safety and environmental duties of his or her job. Internal Reporting by Employees Employees must be alert to the presence of unsafe conditions or violations of environmental law and shall report these to designated managers. It is the policy of the Company that no retaliatory action will be taken against any employee for good faith reporting consistent with this policy. Compliance Compliance with this policy is an ongoing duty of each employee and compliance will be monitored. Each employee is obligated to report immediately to designated managers any failure to comply with this policy. Employees who violate this policy are subject to disciplinary action, up to and including discharge. Full compliance with the intent and purpose of this policy requires that employees be diligent within the scope of their responsibilities. Employees will be evaluated and compensation will be based, i n part, on their effectiveness in implementation of this policy. The Company will defend and indemnify any employee charged with health, safety or environmental offenses when the Company determines that the employee has acted in good faith to comply with this policy. Disclosure It is the policy of the Company to make relevant disclosure, consistent with all laws, regulations and this policy, to its employees, and to the public, of incidents relating to its operations that cause environmental harm or pose health or safety hazards. Commitment of Resources The Company will commit resources to implement this policy and to monitor and sustain a process to ensure that the Triad Management Committee is kept informed of all health, safety and environmental matters. Self-Evaluation The Company, or its designee, shall conduct an annual self-evaluation to assess the Company's status regarding implementation of this policy. HAT consists of two 15,000-ton atmospheric ammonia storage tanks, ass ociated refrigeration equipment and transfer equipment. The terminal receives, by barge and ship, approximately 175,000 tons of anhydrous ammonia each year, which is stored and transferred by truck and pipeline to various end users. The terminal operates 7 days per week and 24 hours per day. Operational and maintenance personnel constantly monitor and maintain process equipment. The terminal conducts drills and personal hygiene monitoring to maintain emergency response readiness. HAT maintains the ongoing integrity of the process equipment through preventive maintenance and inspections. Strict guidelines have been established, through the Process Safety Management Regulations, to maintain equipment in accordance with applicable federal, state, and local codes and regulations. HAT's worst -case release scenario is the failure of a 15,000-ton ammonia storage tank. The selection of the ammonia storage tank for the worst-case release was defined by the regulatory definition of the worst -case release. As defined by the Risk Management Plan regulations, when the entire 15,000 tons of ammonia is released in 10 minutes. This produces a scenario with a >25-mile distance to the endpoint. This was determined by the use of EPA's RMP*Comp. HAT's alternative scenario is the release of 36,000 pounds of ammonia. The selection of the alternative scenario was based on researching information sources for release data. The EPA Emergency Response Notification System (ERNS) database and publications from the AIChE Ammonia Safety Symposia were reviewed. Informal interviews with terminal operators, supervisors, engineers and managers were conducted. This scenario produces a 0.5-mile distance to the endpoint. This was determined by the use of a computer based modeling program named DEGADIS. HAT's safety and environmental exemplary record reflects this commitment. We have multiple layers of safety and environmental protection in place at our plants to protect our employees and the co mmunity. The following covers some of these layers of protection: 7 Managing risks is something we do on a daily basis. 7 We have worked for many years to reduce risks at our site and to be prepared for emergencies. 7 Our employees are highly skilled and well trained. 7 Our equipment is routinely inspected and tested to make sure it is safe. 7 We have computer monitors and controls in the process throughout our plants to detect potential leaks or releases before they occur. 7 Hazard reviews add another layer of protection. They involve "what if" scenarios where employee teams investigate every possible scenario of a new project and resolve it as part of the design phase of the project. 7 Hazard reviews are also conducted at the terminal. 7 Emergency response, including employee responders as well as off-site responders like LEPC, State Police and HAZMAT, add another layer of protection to the community. 7 We work closely with the police and fire departments, and we conduct routine drills. 7 In the event of an emergency, we are prepared to respond. HAT has not had any accidental releases, as defined by the Risk Management Program regulations, for the last 5 years. The releases that HAT has had in the past 5 years are typically very small releases in nature to the air and do not meet the criteria that is stipulated in the regulations. HAT has an extensive emergency response program both within the facility and within the community. Within the facility there is a written Emergency Response Plan (ERP). The ERP is designed as a guide to help in determining the magnitude of an incident, the steps needed to bring the incident under control, and the requirements to ensure that all the federal, state, and local laws are complied with. The ERP is a definitive plan that assigns responsibilities, defines several different methods of communication, assigns control centers and safe havens, designates evacuation procedures, and coordinates with outside a ssistance. The plan has detailed action plans that specifically address incidents concerning chemical spills, fire, acts of nature, civil strife, area risks from outside the facility, personnel injury or fatality, and equipment failures. The plan also designates the type and frequency of training that each person is required to have depending on their responsibilities. Furthermore, the plan commits the management team to devote the necessary resources to prepare, implement and audit the ERP. Although HAT's ERP is specifically written for the HAT facility, the plan is also part of the countywide emergency response plan organized with the local LEPC. All these plans are reviewed with representatives of the LEPC, State Police, Sheriff's Department, Fire Departments, regulatory agencies and industry. HAT is striving on a daily basis to make the facility as safe as possible for the employees, contractors and the community. HAT literally has safety and/or environmental training going on almost daily. Every employee and contractor will attend numerous safety and/or environmental training meetings annually. HAT and its employees have an enduring commitment to protecting health, safety and the environment and our success is accomplished by research, innovation and the use of good common sense. |