Anhydrous ammonia monitoring

[Queen B]

Really could use some advice here.

Anhydrous Ammonia is a popular product in the fertilizer business. Although it was believed that it was highly regulated product when the Planning Commission approved it's use, close to a town with a population of 5000. This last summer the plant was experiencing some releases during the reaction of the Anhydrous and different acid bases. (as I understand the process which is not saying much.) We have found since then that its transportation is highly regulated but once delivered there is no agency directly involved with its use.

So can anyone provide any insight as to what direction we could go to either find an agency to help us or what kind of monitoring to require? We have a Conditional Use Permit, but basically the motion for approval says that it is a highly regulated product and the planning commission approves it. No particular conditions were placed on it.

Can any of you weigh in on this topic?

[Tarf]

Wouldn't that be regulated by the regional water quality control board, as required by the Clean Water Act? I'm not too familiar with agricultural operations (since I more frequently convert agricultural uses to other uses), but if I understand correctly they'd need to file for an NPDES permit prior to operation, and would be required to implement BMPs to reduce runoff - including runoff containing that fertilizer.

Consider that more a question than an answer

[JNA]

under SARA Title III - local LEPC should have been notified if they have a reportable quantity on site (Tier 2)
http://www.kdheks.gov/radiation/resourcesrtk.html

Anybody else serve on the fair community's LEPC ?

[Queen B]

Tarf, so far it is not a water issue but an air quality.
JNA, our Emergency Manager is on the LEPC as well as the business owner that is releasing it. We have spoken to KDHE but they have not offered any solutions or help. The state emergency managers contacted EPA. EPA has inspected but the report has not yet come back. Department of AG has also been consulted but they have not offered any particular help. None of the agencies that we thought were going to assist have provided any yet.
(After looking at the Teir II reporting requirements Anhydrous would be excluded because it is used in routine agricultural operations and is a fertilizer held for resale.)

Anhydrous Ammonia is not even on the hazardous chemical list. If it were, then farmers would not be able to hook up and pull it down the road.

[jswanek]

In Calfornia, it would be referred to the County Fire Marshal or city fire chief if they had the same statutory authority. Comes up sometimes when industrial users are demolishing anhydrous ammonia chillers, or they have a line break. You have an instantaneous release which can be hazardous. Since sprayed water absorbs most of the airborne gas, my guess is your Fire Code authority will suggest detection levels and levels to begin water spraying.