The West Fertilizer Accident: Road Map of AN and NH3 Regulations
EPA: AIR QUALITY STANDARDS
EPA regulates air emissions from stationary and mobile sources. Among other things, this law authorizes EPA to establish National Ambient Air Quality Standards (NNH3QS) to protect public health and public welfare and to regulate emissions of hazardous air pollutants.
Under Section 112(r) of the Clean Air Act, ag retailers with more than 10,000 lbs of NH3 must develop a risk management plan that documents and describes a facility's hazard assessment and response plan. That hazard assessment mandates that facilities document the worst case scenario for a chemical accident and the consequences of that scenario and implement accident prevention and emergency response programs.
STANDARDS: ANSI AND NFPA
The NFPA has developed a code for storage of AN. By itself, AN is not combustible. However, AN is an oxidizer, and it can accelerate the burning of fuels when it is involved in a fire. Code 490 applies to the storage of AN, which includes storage in containers, storage in bulk, contaminants and fire protection. NFPA 490 recommends that should a fire break out where AN is stored, emergency responders should apply large volumes of water as quickly as possible.
According to the ANSI Standard for Storage andHandling of NH3, the conditions favorable for ignition are seldomencountered during normal operations due to the high ignition temperature required.
PARTNERSHIPS THAT MATTER
Just recently, ARA forged a partnership with the FBI and has been working with them on security education and outreach efforts. FBI representatives have made presentations at ARA meetings and exhibited at the 2012 ARA Conference.
Several years ago, ARA joined The Fertilizer Institute (TFI) in putting together the “Know Your Customer” Campaign. This campaign was initiated to prevent the misuse of nitrate-based fertilizer and provides retailers with suggested guidelines to follow regarding the sale of these products.
Additionally, tools like the Asmark Security Vulnerability Assessment (SVA) help ag retailers identify and evaluate potential security threats, risks and vulnerabilities. ARA has been working with Asmark, TFI and CropLife America on this program since 2003, and it was set up well before the DHS CFATS program was established.
ARA also participates in the Fertilizer Institute Security Task Force that works with the Joint IED Defeat Organization leading Department of Defense efforts to defeat the use of improvised explosive devices (IEDs) through counter-IED (C-IED) efforts.
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