Triad Nitrogen, Inc. - Executive Summary

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RMP EXECUTIVE SUMMARY - Louisiana Facility ID: 2245 
 
Triad Nitrogen, Inc. (TNI) is a wholly owned subsidiary of Mississippi Chemical Corporation (MCC). MCC is a major manufacturer of fertilizers, produces and markets all three primary crop nutrients. The company produces nitrogen fertilizer at its facility in Yazoo City, Miss., and TNI facility, in Donaldsonville, La. Mississippi Phosphates Corporation, a wholly owned subsidiary of Mississippi Chemical, produces diammonium phosphate fertilizer at Pascagoula, Miss. Mississippi Potash, Inc., a wholly owned subsidiary of Mississippi Chemical, produces potash fertilizer at its mines and refinery in Carlsbad, N.M. 
 
TNI and its employees have an enduring commitment to protecting health, safety and the environment. In order to document that commitment, the TNI Management Committee has authorized a Health, Safety and Environmental Statement of Policy. This policy is summarized below: 
 
Laws, rules and regulations in the area of health, safety a 
nd 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 pract 
ices. 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 policy 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 Governmen 

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. Through 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, in 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 Triad management is kept informed of all health, safety and environmental matters. 
 
Self-Evaluation 
Triad management, or its designee, shall conduct an annual self-evaluation to assess the Company's status regarding implementation of this policy. 
 
TNI is capable of producing approximately 1,450,000 tons of ammonia and 600,000 tons of urea.  Currently, TNI has two ammonia plants and one urea plant. In the production of ammonia, TNI uses natural gas, air, and water as feedstocks.  The feedstocks are heated to a point that they are broken down into nitrogen, hydrogen, and carbon dioxide. This is in the gas state.  The carbon dioxide is then removed form the gas stream as a by-product, and only nitrogen and hydrogen remain in the gas stream.  The hydrogen and nitrogen is then bonded together to form ammonia (NH3). The ammonia is then cooled to form a liquid at -280F. The ammonia is sent to two 30,0000 ton storage tanks and the urea plant 
.  The urea plant takes some of the ammonia and the carbon dioxide (by-product) from the ammonia plants.  The ammonia and carbon dioxide is then mixed together at approximately 3650F and 2050 psi for approximately 1 hour to form urea.  
 
The processes of making ammonia and urea require the use of cooling water that uses chlorine for purification purposes.  TNI stores approximately 10,000 pounds of chlorine within each covered process. 
 
TNI's worst -case release scenario is a 30,000-ton ammonia storage tank. The selection of the ammonia storage tank for the worst-case release was determined by the regulatory definition of the worst-case release. As defined by the Risk Management Plan regulations, when the entire 30,000 tons of ammonia in 10 minutes is released, produces a scenario with a 3.3-mile distance to the endpoint.  This was determined by the use of a computer air modeling program called DEGADIS. 
 
TNI's alternative scenarios include the release of 2,000 pounds of chlorine and 80 t 
ons of ammonia. The selection of the alternative scenarios 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 ammonia and urea plant operators, supervisors, engineers and managers were conducted in each plant. 
 
TNI uses chlorine in 2,000 pound cylinders for water treatment. The complete failure of one of these cylinders under the regulatory defined parameters produces a scenario with a 0.49 mile distance to the endpoint.  TNI ships ammonia in railcars. By regulation the railcar can not hold more than 80 tons of ammonia. A complete failure of an 80-ton railcar under the regulatory defined parameters produces a scenario with a 0.90-mile distance to the endpoint. The distances to the endpoint for the alternate scenarios were also determined by the use of a computer air modeling program called DEGADIS. 
 
As previously di 
scussed, TNI's commitment to safety and the environment takes priority.  TNI's safety and environmental record reflects this commitment.  TNI receives safety and/or environmental awards on a yearly basis from regulators, insurance companies, and associations for the exemplary performance. The following is a summary of the multiple layers of safety and environmental protection that TNI has in place at our plants to protect our employees and the community: 
 
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 (number of times per year) inspected and tested to make sure it is safe. 
 
7 We have computer monitors and controls throughout our plants to detect potential leaks or releases before they occur. 
 
7 Hazard reviews are done for all changes.  They involve "what if" scenarios where employee teams invest 
igate every possible scenario of a new project and resolve it as part of the design phase of the project. 
 
7 Emergency response, includes employee responders as well as off-site responders like LEPC, State Police and HAZMAT. 
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. 
 
TNI has not had any accidental releases, as defined by the Risk Management Program regulations, for the last 5 years.  The releases that TNI has had in the past 5 years are typically very small release in nature to the air and do not meet the criteria that is stipulated in the regulations. 
 
TNI 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 assistance. 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 TNI's ERP is specifically written for the TNI facility the plan is also part of the parish wide emergency response plan organized with the local LEPC.  All these plans are reviewed with representatives of  
the LEPC, State Police, Sheriff Department, Fire Departments, regulatory agencies and industry. 
 
TNI is striving on a daily basis to try and make the facility as safe as possible for the employees, contractors and the community.  TNI literally has safety and or environmental training going on almost daily, every employee and contractor will attend several safety and/or environmental training meeting annually. TNI 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.
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