On February 1, 2011 the Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued it final rule incorporating the special permit SP-13554 into the hazardous materials regulations. As a result of this final rule, anhydrous ammonia nurse tanks with missing or illegible dataplates no longer need to be marked with the special permit sticker, but the requirements outlined in the special permit for continued operation still need to be met. This means for these tanks, there is a five year testing cycle to continue to keep these tanks in service. Click here to review the requirements contained in Section 173.315 (m) (1) and (2) for operating nurse tanks with missing or illegible dataplates.
June 2014 is the renewal date for most facilities regulated under the U.S. EPA Risk Management Plan (RMP) requirements. If your facility RMP is due for the five year renewal in 2014 you should have received a letter from USEPA Region 5 listing the renewal date. If you store bulk anhydrous ammonia, you must have a RMP. The RMP documentation and requirements have received a lot of attention over the last year in the wake of the fire and explosion at the West, Texas ag retail facility. Expect U.S. EPA Region 5 to conduct RMP audits at Illinois ag retail facilities. The Fertilizer Institute and Asmark Institute developed the myRMP web-based program to help facilities comply with RMP requirements. Click here to access the myRMP program. If you have any questions about RMP compliance, contact Kevin Runkle at the IFCA office.
Recently an Environmental Engineer from Region 5 U.S. EPA inspected an ag retail facility in Illinois to review compliance with their Risk Management Program for anhydrous ammonia storage. On August 1, 2013 President Obama issued Executive Order 13650, Improving Chemical Facility Safety and Security, in response to the tragedy at West, TX. The executive order designates agencies with regulatory authority, such as U.S. EPA, to further improve chemical safety and security in coordination with owners and operators of chemical facilities. Since the tragedy at West, TX occurred at an ag retail facility there will be more RMP inspections by U.S. EPA in order to fullfil the requirements outlined in President Obam's Executive Order. Some of the documents U.S. EPA will be looking for in an RMP inspection include: MSDS (SDS) for anhydrous ammonia Maximum intended inventory amount of anhydrous ammonia stored on site Information pertaining to the storage tanks, such as equipment specifications The last two hazard reviews, including recommendations, and resolution to those recommendations Operating procedures for the anhydrous ammonia system Training records of the employees involved in operating the ammonia system Maintenance schedule for the storage tanks, including inspections and ...more
June 2014 is the renewal date for most facilities regulated under the U.S. EPA Risk Management Plan (RMP) requirements. If you store bulk anhydrous ammonia, you must have a RMP. The RMP documentation and requirements have received a lot of attention over the last year in the wake of the fire and explosion at the West, Texas ag retail facility. Expect U.S. EPA Region V to conduct RMP audits at Illinois ag retail facilities. The Fertilizer Institute and Asmark Institute developed the myRMP web-based program to help facilities comply with RMP requirements. Click here to access the myRMP program. If you have any questions about RMP compliance, contact Kevin Runkle at the IFCA office.
June 2014 is the deadline to file the Risk Management Plan with USEPA. Filing the RMP only satisfies a portion of the requirements in order to be in compliance with this regulation. USEPA emphasizes that you must maintain a copy of the Risk Management Plan along with the Risk Management Program and it must be kept on file at each anhydrous ammonia storage location. If the NH3 storage facility is two miles from the main office, the RMP must be kept on file at the storage facility, not the main office. Required Elements of RMP & Justifying Your Data In order for a facility to accurately enter data into the RMP program, it is essential to have in place a Risk Management Program at each anhydrous ammonia storage location. The risk management program helps define and gather certain data that will be entered into the risk management plan database. Most importantly, the person responsible for completing the RMP at the facility must be able to explain and defend to USEPA how you came up with the information in your RMP. Failure to do so can result in substantial penalty. For example: &...more
You may see advertisements for ammonia application systems that introduce air into anhydrous ammonia nurse tanks to increase tank pressure during cold weather. The system is mounted on NH3 toolbars equipped with a hose that attaches to the vapor valve on nurse tanks during cold weather ammonia application. Introducing air into anhydrous ammonia nurse tanks can eventually causes stress crack corrosion compromising the integrity of the metal which could lead to a catastrophic failure. Additionally, once air is introduced into NH3 nurse tanks, the air can travel from the nurse tank, back to the storage tank, rail car or transport semi and eventually back into the distribution chain. Ethanol plants that use anhydrous ammonia as well as distribution facilities have problems such as locked compressors from air being introduced into their ammonia system. Illinois Department of Agriculture regulations specifically prohibit the addition of any additive, including air, due to incompatibility with ammonia system components. This applies to systems used in custom application and by farmers, so please keep an eye out and help us spread the word that any compressed air system utilized in anhydrous ammonia application is ...more
With harvest beginning in some parts of the state, that means anhydrous ammonia application season is right around the corner. Earlier this year IFCA made available an online anhydrous ammonia safety awareness training program specifically for farmers. The program is free and only takes about an hour to complete. There are a total of five training modules focusing on Properties & Characteristics of NH3, Personal Protective Equipment, Transportation To and From the Field of Application, Safe Hook Up in the Field and Emergency Resonse/First Aid Procedures. The program was made possible with a grant from the Illinois Nutrient Research & Education Council (NREC) in cooperation with Illinois Farm Bureau, Illinois Corn Growers Association and Illinios Department of Agriculture. Click here to access the NH3 safety awareness program for farmers. If you have any questions please contact Kevin Runkle at the IFCA office.
By now most IFCA members have received a letter from the Department Of Homeland Security (DHS) requesting each facility to register with DHS and complete a top-screen submission to determine your threat level. Many facilties completed this requirement in 2007 and 2008. If the top-screen submission was completed and submitted to DHS you should have a letter from them describing if your facility is a Tier 1-4, or in most cases a facility was notified and not assigned a Tier level after completing the top-screen, opting out of compliance with Chemical Facility Anti-Terrorism Standards (CFATS). If you do not remember if you completed the top-screen information or received a letter from DHS notifying you of your threat level, you can contact the CSAT help desk at 866.323.2957. Types of chemicals of interest (COI) that would require an ag retail facility to submit top-screen information to DHS include anhydrous ammonia, ammonium nitrate, aluminum phosphide or phosphene to name a few. Appendix A to the CFATS regulations has a complete list of aproximately 322 chemicals along with threshold reporting requirements. Click here to access the COI list and threshold quantities to determine if you must ...more
If your company offers for transportation or transports a shipment of placarded hazardous material, you must complete the annual HAZMAT registration and pay the registration fee by July 1, 2013. The 2013-2014 registration fee for a small business (less than 100 employees) has been reduced to $150. If your company has more than 100 employees the 2013-2014 HAZMAT registration fee is $1300. The annual fee for small businesses and not-for-profit organizations for registration year 2014-2015 and following years will be $250 and $2,575 for all other registrants. If your company already paid for the HAZMAT registration prior to the reduced 2013-2014 fee you are eligible for a refund from PHMSA. Click here to download the HAZMAT registration form, register on-line or submit a request for refund. If you are unable to take advantage of the on-line refund option, you may request the mailed refund option and instructions by calling PHMSA at either 202.366.4109 or 800.942.6990, or email at email@example.com. If you have questions, please contact Kevin Runkle at the IFCA office.
IFCA has received clear guidance from both the Illinois Secretary of State CDL division and the Illinois State Police enforcement division regarding the type of CDL needed to transport anhydrous ammonia nurse tanks. There has been some confusion on this issue which we are happy to clarify as follows: 1. An anhydrous ammonia nurse tank is an implement of husbandry and as such, the weight of the nurse tank is not factored into the CDL weight classification. 2. Anhydrous ammonia is a placarded hazardous material and therefore a CDL with hazmat endorsement is required for a commercial entity (ag retailer) to transport the product. Farmers or farm family members and farm employees are exempt from the CDL requirement when transporting nurse tanks to the farm. 3. A Class B CDL with hazmat endorsement is needed for an ag retail employee to transport anhydrous ammonia nurse tanks, no matter what the weight or combination of the nurse tanks (1,000 or 1,450 gallon nurse tanks pulled in singles, in tandem or mounted side-by-side on a single running gear). 4. A restricted Class B Farm Service CDL is available to ag retail employees on a seasonal basis. ...more
Funded bythe Illinois Nutrient Research & Education Council (NREC), this program consists of five ammonia safety training modules. Go to http://learning.ifca.com. If you have any questions please contact the IFCA office.
IFCA in cooperation with Illinois Farm Bureau, Illinois Corn Growers Association and Illinois Department of Agriculture have developed a new online anhydrous ammonia safety awareness program for farmers. Funded by a grant from the Illinois Nutrient Research & Education Council (NREC), the online program consists of five training modules covering Properties and Characteristics of NH3, Proper Personal Protective Equipment, Transportation to and From the Field, Safe Hook-Up in the Field and Emergency/First Aid Procedures. There is no cost to use the safety awareness program which is specifically designed for use for on-farm employees and family members who work around, transport, or apply anhydrous ammonia. Over the last two years there have been an increased number of anhydrous ammonia releases and hospitalization due to inhalation or skin exposure. The safety awareness program can be accessed 24/7 by going to http://ifca.com and clicking on the link at the top of the IFCA homepage. The training module can also be accessed at http://learning.ifca.com. If you have any questions regarding the online training modules, please contact Kevin Runkle at the IFCA office.
Remember when hauling anhydrous ammonia nurse tanks or other implements of husbandry after sunset, the towing vehicles or implements of husbandry must be equiped with an amber rotating or flashing light. The lights can also be operated during daylight hours but they are required between sunset and sunrise.
There are still a few seats open this fall for the Asmark Institute's Ammonia Technician Course which is geared toward the needs of facility personnel responsible for maintaining the mechanical integrity of anhydrous ammonia installations. This first course of its kind will be offered at the Agricenter Training Complex in Bloomington, IL. The goal of this 3 day long course is to foster a strong preventative maintenance message and prepare participants to return to their facility trained to identify and address weak links in their anhydrous ammonia operation. The course focuses on the following facility issues: Regulations and Standards governing anhydrous ammonia Protective Measures Emergency Preparedness Identification of Risks associated with Inspection, Installation, Repair and Maintenance Ammonia Equipment terminology, design and materials of construction Storage & Plumbing of Ammonia Installations Equipment Inspection, Installation, Repair & Maintenance Classes are limited to 20 participants at a cost of $325 per participant ($425 for non-Asmark Clients). This includes 3 days of interactive training, exercises, course manual, handouts and wallet card with a certificate showing course completion. If you would like to register for the ammonia technician course, please click on the following link https://www.asmark.org/TrainingCourses/ATCourse.cgi
Remember if you have a reportable quantity (RQ) release of anhydrous ammonia equal to or greater than 18 gallons/100 pounds you have 15 minutes of knowledge of the release to contact: The National Response Center at 800.424.8802 Illinois Emergency Management Agency at 800.782.7860 Local Emergency Planning Committee Local Emergency Responders If you have questions about reporting requirements or need assistance, please contact the IFCA office. IFCA would also like to remind companies that receive anhydrous ammonia by rail to follow all distributor and Federal Rail Administration (FRA) requirements when shipping rail cars back to the distributor or manufacturer. According to FRA requirements all vapor and liquid closure plugs must be tool tight rather than hand tight when shipping the railcar. If you have any questions, please contact IFCA. We wold also like to thank all employees who attended the IFCA and Illinois Department of Ag sponsored NH3 safety training classes. IFCA and IDA trained over 600 employees at eight different classes throughout Illinois.
Anhydrous ammonia nurse tanks manufactured between June 2009 and September 2010 by American Welding & Tank, LLC have experienced some defects. American Welding & Tank has asked the industry to distribute information on the inspection and warranty of these nurse tanks. Please click on the attachment to this email view the notice and inspection program. IFCA is here to assist with any issues you have relative to ammonia equipment, operations and safety so please don't hesitate to contact Kevin Runkle.
Taking implements of husbandry, such as NH3 nurse tanks, across state lines has been a controversial topic over the last few years. DOT has just recently clarified that implements of husbandry are not commercial motor vehicles (CMV) and therefore not subject to the CMV regulations. The Federal Motor Carrier Safety Administration's (FMCSA) authority covers persons who operate a commercial motor vehicle in interstate commerce. Therefore, when an implement of husbandry crosses state lines in interstate commerce it is not subject to CMV regulations since it is not a Commercial Motor Vehicle.
The Fertilizer Institute (TFI) reports that on Tuesday, Department of Homeland Security (DHS) conducted a conference call with industry representatives to discuss technical issues with the Risk Assessment methodology used for establishing Tier Rankings in the Chemical Facility Anti-Terrorism Standards (CFATS) program. There was a correction made to the methodology that resulted in a re-evaluation of 360 facilities with final Tier Rankings. These facilities were originally tiered based on Sabotage or Release-Toxic concerns. There will be no change for 100 facilities, a reduction in Tier Ranking to another 150, and 100 facilities will drop/tier out of the CFATS program. If your facility was initially placed in one of the four tier structures by DHS, there is a chance your facility may drop out or lower on the tier structure. Contact Kevin if you have any questions regarding the CFATS regulations or tier structure.
The Fertilizer Institute (TFI) announced today the Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued its long awaited final rule incorporating several long-standing special permits into the federal hazardous materials regulations. Special permit 13554, held by TFI on behalf of its members is now included into rulemaking. As a result of the final rule, nurse tanks with missing or illegible data plates enrolled in the NTIP and operating under SP-13554 will no longer need to be marked with the special permit number, but the requirements contained in the special permit for continued operation will still need to be met. That is, nurse tanks with missing or illegible data plates will still need to undergo the hydrostatic, visual, thickness testing and pass all inspections in order to remain in service. Although the tanks will no longer need to be marked with the SP-13554 sticker, once the tanks have passed the visual, thickness and pressure tests, it must be marked with the month and year the test was completed along with the corresponding tests passed such as V,T,P. NH3 nurse tanks that pass the visual thickness and pressure tests must then be permanently ...more
The Fertilizer Institute (TFI) has informed IFCA that effective immediately, no new company can register for Special Permit (SP) 13554 through TFI’s online Nurse Tank Inspection Program (NTIP). Policy changes within USDOT now prohibit new company requests to be a party to the SP-13554 exemption. Existing companies who have already registered their facility through TFI’s NTIP will continue to use the SP-13554 exemption provided nurse tanks with missing or illegible data plates undergo the proper testing and inspection procedures. Any company that has not previously registered with TFI for exemption status must now submit a request in writing to USDOT at firstname.lastname@example.org. The written request must include the company name, complete mailing address, telephone, e-mail address (if applicable) along with a company contact. Companies requesting party status must also include the number of anhydrous ammonia nurse tanks to be covered by the special permit. USDOT is currently in the process of developing a final regulation which will incorporate SP-13554 into the USDOT regulations, making the special permit obsolete. Final incorporation of the Special Permit into DOT regulations is expected by the end of 2010. If you have ...more
The Fertilizer Institute (TFI) has advised that Special Permit (SP) 13554 has expired. SP-13554 authorizes nurse tanks with a missing or illegible identification plate to continue in operation so long as they are tested and pass an external visual test using the procedures in 49 C.F.R., Section 180.407(d), a thickness test as specified in 49 C.F.R., Section 180.407(i), and a pressure test as specified in 49 C.F.R., Section 180.407(g). If you have party status through The Fertilizer Institute (TFI), you are authorized to operate under SP-13554 after the expiration until the Department of Transportation (DOT) acts on TFI’s request for renewal. In addition, in August, IFCA met with USDOT Pipeline & Hazardous Materials Safety Administration (PHMSA) officials to get a better understanding of the addendum required to be added to inspection forms for the Nurse Tank Inspection Program (NTIP). This information was passed along to IFCA members with instruction how to complete the addendum and add it to your NTIP file. Attached is a copy of the addendum and instructions how to complete the addendum which must be completed and attached to each original inspection form no later than February 3, 2011.&...more
Recently, IFCA met with USDOT Pipeline & Hazardous Materials Safety Administration (PHMSA) officials to get a better understanding of the addendum required to be added to inspection forms for the Nurse Tank Inspection Program (NTIP). Please click on the link to view a copy of the memo that explains how to fill out the addendum and be in compliance with this requirement. If you have any questions about the addendum or have trouble opening the file, please contact Jean Payne or Kevin Runkle at the IFCA office. For your convenience, we have included a copy of the addendum which should be attached to each inspection form for each NH3 nurse tank enrolled in the NTIP.
This year IFCA is offering four NH3 training classes in the fall to prepare our members for a busy fall ammonia season. All persons making or breaking ammonia connections at a facility must attend a certified training class such as this IFCA/IDA school. Registration for all classes begins at 8:30 a.m. and classes start at 9:00 a.m. and go until noon with lunch provided after testing. Be on the lookout for the registration brochure which will go in the mail tomorrow. The brochure is also posted at www.ifca.com and can be downloaded. The dates and locations of the schools are as follows: September 28--Rockford--Best Western Clock Tower September 29--Peoria--Holiday Inn City Center September 30--Jacksonville--Hamilton's Catering October 1--Urbana--Holiday Inn Conference Center
The Fertilizer Institute (TFI) recently sent out a memo to facilities enrolled in the Nurse Tank Inspection Program (NTIP) to help secure the exemption for the industry. Every two years TFI is required to apply for Special Permit (SP) 13554 which allows anhydrous ammonia nurse tanks with missing or illegible data plates to remain in service as long as they pass a series of tests and inspection. TFI's request to renew SP-13554 requires that information regarding nurse tank shipping history be contained in the application for renewal. TFI must provide this information, on behalf of the industry, to USDOT in order to secure renewal of the permit. Once you have received the memo from TFI please follow the instructions and log into the website by submitting your ten digit code unique to your facility. The information provided to TFI is necessary to help renew the permit. If you have any questions regarding the memo or process to submit information, please contact Kevin Runkle at the IFCA office.
Don't forget that if you offer or transport any amount of DOT placarded hazardous material, you must remit your annual hazardous material registration fee to USDOT by July 1. You can register and pay the fee online at www.phmsa.dot.gov and click on "e-payments" to pull up the hazardous materials registration program. If you have questions please contact Kevin Runkle.
In 2005, USDOT Office of Pipeline & HAZMAT Safety Administration (PHMSA) began requiring anhydrous ammonia nurse tanks with missing or illegible data plate to enroll in the Nurse Tank Inspection Program (NTIP) in which the nurse tanks must undergo and pass hydrostatic pressure testing, thickness testing, and a visual inspection once every five years in order to keep them in service. The industry is now coming upon year five of the program in which tanks will need to be retested and pass in order to use the NH3 nurse tanks. If you have any questions about the USDOT requirements or need to find an inspector, please contact Kevin at the IFCA office.
Region 5 USEPA in Chicago has informed the IFCA that they have sent 48 letters to facilities in Illinois requesting additional information regarding the required 5 year Risk Management Program (RMP) update for the facility. We don't know if all of these facilities are agricultural facilities with ammonia, but we expect that many are. Several IFCA members have responded to the request for information, and subsequently also received an Expedited Settlement Agreement (ESA) from Region 5 with a proposed penalty anywhere from $600 - $1100 for failure to either update or properly update their RMP within the 5 year update timeframe. IFCA contacted Region 5 objecting to the penalties if a facility made a good faith effort to update the RMP and simply missed a step in the on-line process that required certification of the RMP update. Region 5 contacted IFCA today (June 8th) and informed us that they would waive the penalty in cases where the facility did attempt to update the RMP as required and simply missed a step in the process. If you received a letter from USEPA regarding your RMP, please contact Kevin Runkle immediately. If in fact you completely forgot to update your RMP, ...more
The IFCA has recently been notified by the Illinois Department of Ag Bureau of Ag Product Inspection that a company in Illinois is calling on IFCA members to sell anhydrous ammonia cartridges to take the place of canisters. Cartridges and canisters are different as they allow for certain levels of exposure. According to the product information on a full face gas mask with a cartridge, they are not to by used in environments that are Immediately Dangerous to Life and Health (IDLH). At 400 parts per million (PPM), NH3 becomes immediately dangerous to life and health making the cartridge useless in an emergency situation. According to the Illinois Department of Agriculture Rules and Regulations Relating to Anhydrous Ammonia, all permanent NH3 storage installations must have on hand one full face gas mask with a spare currently dated canister for emergency purposes. There is nothing wrong with employees using the cartridges with a gas mask when working around anhydrous ammonia, but the facility still must maintain on hand a gas mask with canister which allows for greater exposure over a longer period of time. If you have any questions, please contact Kevin at ...more
If a farmer customer is in possession of anhydrous ammonia and a reportable release of 18 gallons or 100 pounds occurs, it is the farmer's responsibility to immediately notify the proper emergency personnel. There have been several anhydrous ammonia releases in Illinois over last week, many of which occurred while the farmers were in possession of the product and some involving injury. Although your customers may not want to make the calls, or may ask you to make the emergency notifications to IEMA, LEPC and the NRC for them, it is also their responsibility per federal and state regulations to contact these agencies as well if the release occurs while they are in possession of the ammonia. Both IEMA and USEPA have made this very clear. A written follow-up report is also required and must be sent to IEMA and the LEPC as soon as possible following the incident. You can certainly help your customers with the written report and we recommend you do so. If you have any questions about this requirement, please contact the IFCA office. An emergency notification fact sheet is available on the IFCA website by ...more
Click on the link to access the Power Point Presentation and interpretive guidance given by Region V USEPA representatives at the 2010 Regulatory Workshop held in Peoria, IL.
The Fertilizer Institute (TFI) has been notified by the Department of Homeland Security (DHS) that final tier ranking letters have been sent to 544 facilities. Site security plans will be due to DHS no later than June 1, 2010. DHS also advised it is checking the Environmental Protection Agency's (EPA) database of Tier II and Risk Management Plan (RMP) facilities for any facilities that may have triggered the reporting requirements under CFATS. If a facility is on either the Tier II or RMP list, and has not submitted a top screen to DHS, a letter warning of potential enforcement action will be sent. Penalties can be as much as $50,000 per day and/or a shutdown order.
IFCA and the Illinois Department of Agriculture have made available online anhydrous ammonia training for members. Employees or new hires who can not attend the regularly scheduled anhydrous ammonia safety schools now have the opportunity to receive an Illinois Department of Agriculture approved anhydrous ammonia training certificate online. The training consists of a series of power point slides and videos which cover anhydrous ammonia properties, characteristics, safe handling, transportation, unsafe conditions and emergency response. The training satisfies the Illinois Department of Agriculture requirements for a competent attendant. Certificates are only valid for ninety days which should be plenty of time to get through the busy spring or fall ammonia seasons. The temporary online NH3 training is designed for employees to be in compliance until they can attend and complete a regularly scheduled ammonia training course. You can access the online training program by clicking on the link on the IFCA homepage. Once the training and test are completed, a certificate will pop-up in pdf format so please make sure you have your pop-up blockers turned off. If you have problems with the pop-up pdf certificate one ...more
Part time employees without a CDL have the option of submitting an application to the Illinois Secretary of State rather than completing theA fingerprint and background check. Employees must choose between a CDL with HAZMAT or apply for the Restricted Use CDL. A person can not have both a full CDL and the restricted license. The restricted class B license can be used for either two 90 day periods or one 180 day period over a twelve month period. The cost is $50 for the restricted license which only needs to be paid once every four years. Employees with a restricted CDL are limited to hauling up to 1,000 gallons or less of diesel fuel, 3,000 gallons or less of liquid fertilizer (including NH3) or solid fertilizers not mixed with organic substances. Fingerprinting and background checks are not required for the restricted CDL. The application form is on our website under "Regulations" then "Secretary of State" or contact the IFCA office and we can fax you a copy.
It is hard to believe, but it has been four years since the Transportation Security Administration (TSA) began conducting background checks on drivers wanting a HAZMAT endorsement on their CDL. A CDL with HAZMAT endorsement expires every four years in Illinois in which case each time you renew your CDL with HAZMAT endorsement, you will have to submit fingerprints for a background check. Thats right, even though our fingerprints do not change, each applicant will have to submit a new set of fingerprints and undergo another background check prior to issuance of the CDL/HAZMAT endorsement from the Illinois Secretary of State. Estimated cost is around $140 for the background check, CDL renewal and fingerprinting by a third party vendor. If you need step by step instructions submitting information toA or fingerprinting, please contact the IFCA office. You can renew your CDL with HAZMAT endorsement within one year of expiration of the license.
IFCA and the Illinois Department of Agriculture have made available online anhydrous ammonia training for members. Employees or new hires who can not attend the regularly scheduled anhydrous ammonia safety schools now have the opportunity to receive an Illinois Department of Agriculture approved anhydrous ammonia training certificate online. The training consists of a series of power point slides and videos which cover anhdrous ammonia properties, characteristics, safe handling, transportation, unsafe conditions and emergency response. The training satisfies the Illinois Department of Agriculture requrements for a competant attendant. Certificates are only valid for ninety days which should be plenty of time to get through the busy spring or fall ammonia seasons. The temporary online NH3 training is designed for employees to be in compliance until they can attend and complete a regularly schduled ammonia training course. You can access the online training program by clicking on the link on the IFCA homepage. Once the training and test are completed, a certificate will pop-up in pdf format so please make sure you have your pop-up blockers turned off. If you have problems with the pop-up pdf certificate ...more
Today, the U.S. House of Representatives is tentatively scheduled to consider H.R. 2868, The Chemical Facility Anti-Terrorism Act of 2009. Provisions within H.R. 2868 include the use of "Inherently Safer Technology" (IST) which could allow the U.S. Department of Homeland Security to mandate businesses subtitute certain products such as anhydrous ammonia as well as many widely used pesticides. The IST provision is being used by anti-chemical extremists whose primary goal is to drive certain products such as anhydrous ammonia and chlorine out of the marketplace. IFCA is urging our members to contact their US Representative and ask them to vote no on this important piece of legislation. You can find your US Rep. by going to www.ifca.com, click on the Legislation link then click on the "Find Your Legislator" link or contact their Washington D.C. office at the number listed below. Congressman Aaron Schock--202.225.6201 Congresswoman Debbie Halvorson--202.225.3635 Congressman John Shimkus--202.225.5271 Congressman Tim Johnson--202.225.2371 Congressman Phil Hare--202.225.5905 Congressman Jerry Costello--202.225.5661 Congressman Donald Manzullo--202.225.2976 Congressman Bill Foster--202.225.2976 Congressman Peter Roskam--202.225.4561
USEPA Region 5 indicates they will be more diligent in enforcing Risk Management Plan regulations in the near future. In addition to increased enforcement IFCA has seen a substantial increase in monetary fines imposed on some IFCA members for non-compliance with certain regulations. In an attempt to help prepare IFCA members for future RMP audits conducted by USEPA, IFCA will be offering a program for members to contact the association and schedule an RMP audit. Kevin Runkle, IFCA Manager of Regulatory Services, will be available to schedule and conduct the audits with members at their convenience. Companies required to submit a Risk Management Plan to USEPA are also required to have in place a Risk Management Program which consists of a mechanical integrity manual, hazard reviews, compliance audits, training documentation, maintenance documents and inspection documentation. The fee for an RMP audit will be $150 per RMP location plus travel expenses. A company with multiple RMP locations will receive a reduced fee based upon the number of locations. If you are interested in scheduling an IFCA RMP audit please contact Kevin Runkle. &...more
IFCA has an anhydroua ammonia safety video availble on the website for employees and customers to view. All you have to do is go to the website and click on the link to the video or if you are having trouble viewing the video, you can contact the IFCA office and we will send you a DVD copy. The video is only twelve minutes long and outlines safety and regulatory compliance issues when working around NH3. IFCA also has emergency response wallet cards available for members. The cards should be used in the event you have a reportable quanity release of anhydrous ammonia. Please contact the IFCA office if you would like some wallet cards.
This year IFCA printed 15,000 emergency response wallet cards for our members to give to employees and customers in the event of a release of anhydrous ammonia. If you need a supply of these, give us a call. USEPA has been very strict this year regarding the 15 minute rule if a reportable quantity release of NH3 occurs. Some IFCA members are facing fines up to $25,000 for not contacting the National Response Center (NRC) within fifteen minutes of a reportable quantity RQ release (18 gallons or 100 pounds) of NH3. If a customer is in possession of anhydrous and a RQ release occurs, it is their responsibility to make the appropriate phone calls. IFCA has a 12 minute NH3 Safety Video for farmers available on our website. We urge our members to watch this video with their customers prior to the busy fall ammonia season. If you need a DVD copy of the video, please contact Kevin at the IFCA office. Fun Fact! The IFCA video is a finalist in the International "Freddie" award contest for health and training videos! We are competing with a video starring Gary Sinise, the ...more
It has been nearly five years since legislation was introduced requiring mandatory fingerprinting and background check prior to receiving a HAZMAT endorsement on a CDL. Although a person's fingerprint does not change over time, the Transportation Security Administration (TSA) still requires everyone who renews their CDL with a HAZMAT endorsement to resubmit fingerprints in order to conduct another background check. Although the process is much quicker than when it was first introduced, it can still take anywhere from two to four weeks for a background check to clear. A person's license can be renewed up to one year prior to the expiration on the license. IFCA recommends renewing a CDL with a HAZMAT endorsement at least two months prior to the license expiration. IFCA has instructions for renewing a HAZMAT as well as a list of Illinois fingerprint locations on our website or you can contact the IFCA office.
Ethanol plants as well as other petroleum refineries throughout Illinois use anhydrous ammonia in their process. It is used in ethanol plants as a pH balance. Many ethanol plants have called upon IFCA members to supply them with anhydrous ammonia. Some ethanol plants have NH3 storage tanks, but some choose to use nurse tanks as a form of supply to bypass IDA NH3 regulations as well as RMP requirements. If anhydrous ammonia nurse tanks do not have a MC 330/331 stamped on the data plate, they can not be used to supply ethanol plants. Federal hazmat regulations 173.315(m) state that ammonia nurse tanks are exempt from many USDOT requirements only if they are used for agricultural purposes only. USDOT has determined ethanol plants and petroleum refineries are not "agricultural purposes" (i.e. crop production). If you are supplying NH3 to an ethanol plant the tanks must bear the MC330/331 stamp and undergo the same testing and inspection requirements as NH3 cargo tanks. Some pressurized vessel manufacturers do make MC330/331 tanks as small as 2,000 gallons which could be used to supply ethanol plants as long as ...more
The deadline has now passed for the majority of facilities to submit their RMP five year update. If you planned to submit your facility RMP electronically via RMP e-submit and have not received your letter form USEPA, you may not make your deadline. Submitting an RMP electronically requires each facility submit an authorized company signature allowing personnel to submit electronically. This process takes anywhere from a few days to a few weeks to receive final notification and instructions for accessing the e-submit program. IFCA suggests companies should submit their RMP using the old RMP Submit 2004 program then mailing the hard copy to USEPA like you have done in the past. This will allow you to meet your five year submission deadline. This is the last year USEPA will be accepting a hard copy of the RMP produced with the RMP Submit program. Any RMP submitted after January 1, 2010 must be submitted electronically to USEPA. Submitting the five year RMP update to USEPA is just part of the process. Each facility that submits an RMP must also have in place at each ammonia installation a Risk Management Program consisting of a Hazard ...more
As a reminder, facilities with a Risk Management Plan may be up for the five year renewal in June 2009. Depending on the year you submitted the initial RMP, some facilities may not need to conduct their five year update. For facilties that submitted the first RMP in 1999, this year will be the second five year update. USEPA now has online submission available or the RMP can be submitted by mail. After 2009, all RMP submissions and updates must be conducted electronically via the internet. If you need assistance submitting the RMP or updating your facility Risk Management Program, please contact the IFCA office.
I think most of the state is in the same boat, literally, with all the recent rain. Now is a good time to blow the dust off your Risk Management Plan (RMP) and start working on the five year update if applicable. Most IFCA members are receiving letters from USEPA Region 5 reminding them of the five year anniversary date to update your RMP. If your facility RMP was originally filed in June of 1999, your second five year RMP update will be due to USEPA sometime in June of 2009. The Asmark Institute along with The Fertilizer Institute (TFI) have developed the myRMP Suite of Guidance Material to assist ag retailers in complying with the RMP requirements. This program is the only one approved by USEPA to assist with RMP compliance. Why settle for second best when you can get the best for free? To access the myRMP guidance material, go to www.tfi.org and click on myRMP. If you need assistance with your RMP, please contact the IFCA office. Click on the attachment to view some of the information required in the Risk ...more
It is becoming increasingly clear that USEPA is taking a tough stance regarding the requirement to report a release of a reportable quantity immediately. In discussions with officials at Region 5 USEPA, they consider 15 minutes the standard guideline for reporting a release to the National Response Center at 800-424-8802. The Illinois Emergency Management Agency also needs to be notified at this time at 800-782-7860 as well as your local emergency planning committee. We recommend that facility managers keep these phone numbers in your cell phone because if a fire or other incident prevents you from getting to your office files or accessing your emergency plan and that delays the phone call, that is not considered excusable by USEPA. An IFCA member is currently dealing with this very situation and USEPA is not backing down. The base fine for not reporting an incident "immediately" is $32,000 and can be higher in some cases. IFCA has emergency notification wallet cards available for your employees and your customers, just give us a call and we'll mail them to you. IFCA is working with Region 5 to try to inject some reason into ...more
Over the past few years, there have been a substantial increase in the number of farmer owned NH3 storage facilities and farmer owned nurse wagons in Illinois. IFCA, in partnership with Illinois Farm Bureau, Illinois Department of Agriculture and the Illinois Corn Growers Association developed a brochure outlining the regulatory requirements farmers must comply with if they own anhydrous ammonia storage tanks or anhydrous ammonia nurse tanks. To help ensure the safety and long-term viability of anyhydrous ammonia for agriculture production, please pass this informational brochure and the NH3 safety video for farmers to your customers. All it takes is one major accident and anhydrous ammonia for agriculture production can be a thing of past. As an industry, we all need to work together to ensure long-term use of this product. Please click on the e-mail attachment to view the regulatory brochure. The brochure is also available on the IFCA website. IFCA and IDA have also developed an NH3 safety video for farmers. Please take the time to show this twelve minute video to your farmer customers prior to the busey ammonia season. The IFCA office has received ...more
IFCA, in partnership with Illinois Farm Bureau, Illinois Department of Agriculture and the Illinois Corn Growers Association developed a brochure outlining the regulatory requirements farmers must comply with if they own anhydrous ammonia storage tanks or anhydrous ammonia nurse tanks. Please click on the link to access the regulatory brochure.
Region V USEPA is sending Risk Management Plan (RMP) five year update letters reminding regulated facilities to resubmit their RMP. The majority of ag retail facilities are up for the five year renewal June 2009. Facilities should check their RMP file to determine the anniversary date for resubmission. 2009 is the last year USEPA will accepting diskettes. After 2009, the RMP must be submitted on-line, similar to the SARA Tier II reports. Submitting the Risk Management Plan to USEPA is only a small portion of the requirement set forth in the regulation. Each facility must have in place a risk management program on file. The risk management program consists of a hazard review which must be completed once every five years, a compliance audit conducted once every three years and an incident investigation form must be completed if a release of anhydrous ammonia caused or could have caused serious injury or bodily harm. The hazard review, compliance audit an a mechanical integrity manual, consisting of equipment used to store, transfer or transport anhydrous ammonia, must also be kept on file at each ammonia storage location in order ...more
This video is designed to provide farmers with safety information related to handling, transportation, application, first aid and emergency response as it pertains to anhydrous ammonia.
With funding from FREC, IFCA and the Illinois Department of Agriculture have produced an anhydrous ammonia safety video specifically for farmers. Many NH3 releases and accidents occur on the farm, in transport or while the product is in possession of the farmer; therefore, IFCA sees the need to educate farmers about the proper handling, transportation, application and overall stewardship of ammonia. To preview the video go to vimeo.com/moogaloop.swf We will be making this link available to grower organizations and will work with IDA and the media to get the word out and ensure that growers take 12 minutes out of their day to think about and reinforce ammonia safety procedures and emergency response. The video can also be accessed via the IFCA homepage by clicking on the NH3 application picture.
Click here to see the IFCA Regulatory Alert and December 2008 letter from USDOT containing information and photographs on anhydrous ammonia nurse tank compliance issues.
This fall, the Federal Rail Administration (FRA) has been to several IFCA member facilities checking for compliance with employee training records and proper bill of lading for rail shipments being sent back. Make sure your employees receive proper training pertaining to anhydrous ammonia by sending them to one of the eight scheduled IFCA and IDA sponsored NH3 training sessions in February 2009. The training schedule is as follows. Carbondale, IL--February 10 Rend Lake--February 11 Champaign, IL--February 13 Rock Falls, IL--February 17 Monmouth, IL--February 18 Quincy, IL--February 19 Springfield, IL--February 20 Bloomington, IL--February 24 If you need to register employees for the 2009 NH3 safety schools, please contact Kevin at the IFCA office.
The snow has put a damper on a busy two week stretch for ammonia application. Throughout the state, there were about a half dozen serious releases of ammonia that occurred while the farmer was in control of the tank. In nearly all cases, the hoses were stretched and pulled from the tank, the hoses worked lose from the tank or the hoses were caught up in the knives and damaged. We also had several nurse tanks break loose from the running gears while in the field, or even on the roadway while being towed. While no one has been seriously injured, these incidents catch the attention of the regulatory agencies, including the IEPA. Here are some important things to take note of: 1. When a release over 100 lbs occurs while the farmer is in control of the product, the farmer must make the necessary phone calls to IEMA, the National Response Center and the local emergency response agency. IFCA is again printing wallet cards for you to give to your customers to keep in their tractors with these phone numbers on them. We will distribute these cards this winter and in the ...more
During the busy anhydrous ammonia application season we sometimes forget regulatory requirements when hauling NH3 nurse tanks. It's even more difficult this year with the season starting late and the days getting shorter. If your employees or farmer customers will be hauling ammonia nurse tanks after dusk, the tanks must be fitted with an amber rotating/flashing light on the either the nurse tanks or towing vehicle. It is a violation of the Illinois Motor Vehicle Code to transport NH3 nurse tanks on a public roadway after dark without a rotating or flashing amber light. IFCA received news that two farmers were recently issued tickets for pulling NH3 nurse tanks after dark without the proper lighting. In addition to amber lighting, nurse tank wagons must be equipped with brake lights and turn signals (light bar) if the rear lights on the towing vehicle are obstructed from the rear by the vehicle being towed. If you have any questions about these Illinois Motor Vehicle regulations, please contact the IFCA office.
Our industry is constantly under scrutiny regarding fall application of anhydrous ammonia from government regulatory agencies and environmental groups. If our industry fails to work together to promote best management practices of fall applied anhydrous ammonia then we risk the chance of dealing with regulatory oversight and possibly tightened restrictions of fall applied anhydrous ammonia. Professors at Illinois State University have a grant from the Fertilizer Research and Education Council (FREC) to conduct an economic impact study if fall anhydrous ammonia were banned and spring application became the only option. Please take the time to read the attached instructions and fill out the questionnaire and return the information. If you have trouble opening the attachments or have any questions regarding the attached documents, please contact the IFCA office.
Effective Wednesday, October 1, 2008, no person may offer a motor carrier any hazardous material specified in FMCSA 385.403 unless that motor carrier holds a safety permit issued by the Federal Motor Carrier Safety Administration. The HAZMAT safety permit requirement took effect back in January 2005. Anyone hauling a hazardous material such as anhydrous ammonia or hazardous materials listed in FMCSA 49 CFR 385.403 are required to obtain a hazardous material safety permit. According to the new regulation effective October, 1 2008, the ammonia terminal can not load an NH3 transport semi unless the motor carrier shows proof of possessing a HAZMAT Safety Permit issued by the Federal Motor Carrier Safety Administration (FMCSA). HAZMAT permits are good for two years after the issuance date so if it is time to renew your permit make sure you send in the renewal application at least 45 days prior to the expiration of the permit. DOT OFFICERS WILL BE CHECKING FOR COMPLIANCE THIS FALL. Part of the original HAZMAT Safety Permit application required motor carriers to have in place a current security plan, communications plan and hazmat employees must have security awareness training. As part of the communications plan, the motor carrier or driver must&...more
Last week, IFCA mailed out a survey to members asking them to complete an enclosed survey related to the amount of fall and spring anhydrous ammonia applied in their region. The information will be used in an economic impact study to help determine what would happen to the industry if fall applied anhydrous ammonia were eliminated. Recently, media attention has focused on the Gulf of Mexico Hypoxia zone as being the largest in history. Many scientists and government regulatory agencies point their fingers at current agriculture practices in the midwest as the culprit of the hypoxia zone. Please take the time to fill out the survey and mail it to Illinois State University in the self addressed stamped envelope. The survey is confidential, and the more responses we get from IFCA members the more accurate the research project will be. We cant afford to lose fall anhydrous ammonia application. If you have any questions about the survey, please contact Jean or Kevin.
This week, the Department of Homeland Security mailed letters, via Federal Express, placing chemical facilities into a preliminary Tier IV ranking. Some IFCA members with large quantities of anhydrous ammonia near populated areas have already received their letter this week informing them their facility is considered a Tier IV, which is the lowest level of tier ranking. Facilities placed in this level must submit a copy of their SVA to DHS by December 31, 2008. The Asmark SVA model has been determined to meet the Center for Chemical Process Safety (CCPS) security vulnerability assessment design criteria for conducting security assessments. It is recommended your SVA be updated every three years and changes be made to your facility to address weaknesses found in your facility security. If you need to update your SVA or can not locate the original, please contact Kevin at the IFCA office to receive a new username, password and instructions to complete an updated SVA.
As letters from DHS are received by IFCA members, the consensus seems to be most IFCA members will not fall into a tier ranking by DHS and therefore are no longer subject to CFATS regulations. Although the majority of retailers had to register with DHS and submit TopScreen information due to anhydrous ammonia, this fertilizer alone does not appear to be enough to trigger a facility to be placed in any of the four tier rankings. One of the Chemicals of Interest (COI) that triggers a preliminary tier ranking by DHS is phosphine which is used in grain bins as a fumigant. Some IFCA members have been placed in a preliminary Tier 2 due to having this product on site even if only for a short amount of time. If a company is given a tier ranking of one through three, they must complete a site vulnerability assessment (SVA). To gain access to the DHS SVA, go to https://csat.dhs.gov/csat and enter your username and password used to gain access and submit TopScreen information. Click on the “manage my account” link then click on SVA. Since the SVA ...more
On July 22, the Surface Transportation Board (STB) will take testimony at a hearing in Washington D.C. on a petition by the railroads to release them of their federal common carrier obligation to transport hazardous materials, particularly anhydrous ammonia and chlorine gas. For the past few years, the railroads have been making the case that their liability exposure in carrying these products far exceeds the value of the revenue from this service. A major derailment and rupture of chlorine tankers in Graniteville, SC in 2005 served to accelerate the debate. A copy of the STB press release is attached. IFCA's Jean Payne has been asked to present 10 minutes of testimony at the July 22 hearing to explain the importance of this service to Illinois ag retailers, your customers and agriculture. IFCA will also be submitting written comments on this issue and will post them on our website as quickly as possible. We urge IFCA members to also submit comments to STB on this issue and how this would impact your individual company. Even if you do not receive ammonia by rail, you will be impacted if this service is ...more
Online registration is now available for the 2008 National Agronomic Environmental Health and Safety School (NAEHSS) held at the Interstate Center in Bloomington, IL on August 19th and 20th. The national safety school covers a wide variety of industry hot topics including presentations from DHS, USEPA, OSHA, JJ Keller & Associates, USDOT, The Fertilizer Institute and Illinois EPA. Topics of discussion include SPCC, RMP electronic submission, EPA Pesticide Container and Containment Regulations, DOT Drug and Alcohol Compliance, future of NH3 nurse tank testing and Ag-chemical facility fire prevention plan just to name a few. The safety school keynote speaker will be TFI President, Ford West. For a more detailed agenda and to register online, go to www.naehss.org and click on the registration button. The registration fee is $135 per person with lunch provided both days.
The Department of Homeland Security (DHS) has recently sent an email to several IFCA members notifying them they did not complete the required information for Top-Screen Submission. IFCA has learned some companies failed to complete the final step of hitting the submit button at the end of the Top Screen process. If your company received an e-mail from DHS earlier this week stating the information was not submitted, then all you need to do is go back into the Top Screen with your user name and password and go to the very last page of the submission process an click on the submit button. All of the information you have entered for your facility is automatically saved so there is no need to re-enter the required information. If you have any problems finding the submit button in the Top Screen program, please contact Kevin at the IFCA office. In addition, IFCA has learned within the next week, DHS will issue its tier ranking letters to affected chemical facilities. Roughly 6500 facilities are covered, out of 35,000 Top Screen submissions. These facilities will be placed in 4 tiers and submission times for their Site Vulnerability Assessment (...more
A team of scientists from Louisiana State University is forecasting that the hypoxia zone off the coast of Louisiana and Texas will be the largest this summer since they began taking measurements in 1985. The hypoxia zone, sometimes referred to as the "dead zone" because of low level of oxygen in the water is predicted to be the size of Massachusets this July. Dr. Eugene Turner of LSU stated "The intensive farming of more land, including crops used for biofuels, has definitely contributed to this high nitrogen loading rate." There remains much debate on the cause of the hypoxia zone, as many models show the zone growing in size while the loadings of nitrogen and phosphorus have remained stable. This issue will continue to nip at the heels of the agricultural industry. IFCA is working with researchers at Illinois State University to develop an economic impact analysis showing the impact of any legislative efforts to reduce or eliminate fall applied nitrogen in Illinois. This study is being funded by FREC and we hope to have it completed this fall for distribution.
Any company who, between July 1of a year and June 30 of the following year, offers or transports in commerce a shipment of hazardous materials must register for that twelve-month period with U.S. Department of Transportation as an offerer or transporter of hazardous materials. For a copy of the HAZMAT registration application and instructions go to the IFCA website and click on Regulations then DOT. If you would like to register on-line, go to www.hazmatonline.phmsa.dot.gov/services then click on HAZMAT Registration applications. In addition, companies required to register with USDOT are also required to have a written security plan including a risk assessment and measures to address personal security, unauthorized access, and en route security. Companies required to have security plans must also provide security training to all hazmat employees. Through the IFCA’s highly efficient and well balanced working relationship with The Asmark Institute, IFCA can provide timely security plans and security vulnerability assessments (SVA) which satisfy the above mentioned DOT requirements. IFCA has helped several trucking companies who ship anhydrous ammonia to our members as well as many of our ag retail members get out of a ...more
The Department of Homeland Security, through the Transportation Security Administration (TSA) and the United States Coast Guard, is implementing a mandatory program generally requiring that all workers who have unescorted access to secure areas of a covered facility must obtain and carry a Transportation Worker Identification Credential (TWIC) card. A TWIC is a tamper resistant identification credential issued by theA, containing the worker’s biometric information (fingerprint template) to allow for a positive link between the card and the individual. The TWIC regulation affects every facility covered by the Maritime Transportation Security Act (MTSA). Facilities covered under MTSA include but are not limited to facilities that offload anhydrous ammonia, propane, ammonium nitrate, ammonium nitrate fertilizers, fertilizer mixtures, or nitro carbate mixtures described and defined as an oxidizer by the regulations of 49 CFR part 173. According to the US Coast Guard, an estimated one million individuals will be required to obtain a TWIC. This includes Coast Guard-credentialed merchant mariners, port facility employees, longshoremen, truck drivers, and others requiring unescorted access to secure areas of maritime facilities and vessels regulated by MTSA. Some facilities that store fertilizer and anhydrous ammonia in separate locations may designate ...more
Chemical facilities that registered with the U.S. Department of Homeland Security (DHS) earlier this year must also complete Chemical-Terrorism Vulnerability Information (CVI) training. Any information or correspondence from DHS relating to the Chemical of Interest (COI) at your facility such as anhydrous ammonia or ammonium nitrate, which required facilities to register with DHS must also be marked as CVI and be viewed by persons who also have completed CVI training. The training is available online and takes approximately 20 to 30 minutes to complete. Once the training is complete, you can print off a certificate of completion that states you are an authorized CVI user. To access the online training, go to the IFCA website and click on regulations. Then click on ammonia or security and a link will be available which will take you to the DHS on-line training module. If you have problems accessing the training, please contact Kevin at the IFCA office.
TWIC or Transportation Worker Identification Credential is a new identification system required by people entering secure areas at our nations ports. This may include barge terminals that offload dry or liquid fertilizer and anhydrous ammonia. Click on this pdf file to get information regarding how and where to apply for a TWIC.
All facilities that register and submit Top-Screen information to DHS must also complete Chemical-Terrorism Vulnerability Information (CVI) training. This consists of an an online training module which takes approximately twenty minutes to complete. Click on this link to access the CVI training module, complete the training and print a certificate of completion.
Is your company emergency sign faded to the point where you can't read the information anymore? The Illinois Department of Agriculture anhydrous ammonia regulations require an emergency sign with letters of a minimum height of two inches including at a minimum the name and phone number of the owner, manager or agent of the anhydrous ammonia storage location. The sign must be located at the entrance to the site property or apart from the storage tanks. The Asmark Institute emergency sign program goes above and beyond compliance with this regulation. Signs are 39.5" long by 24" wide, are made of wind and weather resistant material and come printed with your company information for just $120 each. If you are interested in purchasing an emergency sign, please contact Kevin at the IFCA office.
Click on this PDF to view R-Stamp Welders and DOT CT facilities that are certified to weld on anyhdrous ammonia nurse tanks in Illinois and perform testing for the Nurse Tank Inspection Program.
The National Fire Protection Association (NFPA) is backing a new rule that prohibits converting ammonia nurse tanks to LP service. The NFPA recommendations states that except for containers used in cargo tank vehicle service, ASME containers of 3,000 gallons water capacity or less used to store anhydrous ammonia shall not be converted to LP gas fuel service. Keep in mind that this new provision is simply a recommendation by NFPA. Unless the state of Illinois adopts the provisions set forth by NFPA, then it is simply considered a recommendation by NFPA and not a regulation that must be followed. If you have any questions about this, please contact Jean or Kevin at the IFCA office.