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Anhydrous Ammonia Storage and Handling
January 1997

TNRCC Rule 116.111(3) in Regulation VI requires that Best Available Control Technology
(BACT) be applied to all facilities that must obtain a permit.  BACT determinations are made on
a case-by-case basis. 

What are the minimum controls that need to be considered and may be required to satisfy
BACT requirements for applications with rural, isolated locations (low nuisance potential)?

    A mitigation plan that describes the methods and procedures utilized by the facility to
     reduce the risk of a catastrophic release of ammonia traveling off-site from the facility.
    A contingency plan that describes the actions used at the facility to notify persons in the
     immediate area of a sudden release of ammonia.
    Venting all vapors back to the host tank when transferring ammonia.
    Bleeding vapors from hoses and connectors into an adequate volume of water after
     unloading operations are performed.
    Barricading around the permanent ammonia storage tanks to keep vehicular collisions
     from occurring.
    Audio, visual, olfactory checks every 4, 6, or 8-hours to ensure there is no leakage
     from the storage tanks and any nurse tanks stored on-site.
    Due to the fact that ammonia is considered a disaster chemical by the Environmental
     Protection Agency (EPA), consult the EPA Prevention Reference Manual: Chemical
     Specific, Volume 11, Control of Accidental Releases of Ammonia, EPA/600/8-87/034k.  It
will be necessary for the facility to be compared to the Baseline, Level 1,
     and Level 2 controls.  If less than Level 2 controls are proposed, justification should be
     provided for the less stringent control option.  Describe any additional equipment or
     operational controls which would reduce the probability or magnitude of a catastrophic
     release from this facility.  Information for obtaining the manual can be received by
     contacting the National Technology Information Service (NTIS) at 1-800-553-6847. 
     The publication number for this manual is PB-87-231262, and its cost is $27.00.

What additional controls should be considered and may be required for facilities in tighter
locations with nearby residences, businesses, schools, etc. (high nuisance potential)?

    Water sprays or fog systems over the permanent storage tanks.
    Diking around the permanent ammonia tanks to funnel ammonia in order to minimize
    Addition of rupture disks and pressure gauges upstream or downstream of the relief
     valves to eliminate fugitive emissions from these sources.
    Addition of a scrubber(s) or equivalent abatement device to reduce ammonia and
     fluoride/fluorine emissions from pipe reactors.

In summary, any changes or additions that are thought to be insignificant and appear that no
permit requirements are necessary should be proposed to the TNRCC for review or comments. 
Permit processing time can be greatly reduced by:

     1)   choosing an isolated location; and 
     2)   submitting a well prepared application with a completed PI-1 or PI-1R form. 
          Refer to document entitled "Supplemental Information Sheet for Anhydrous
          Ammonia Storage/Handling Applications" for more details concerning
          application information; and 
     3)   proposing controls that meet all BACT, regulation, and health effects
          requirements.  Proposals for anything less should be well justified; and
     4)   sending the original application to the Austin Office, one copy of the application
          to the appropriate  regional office, one copy to any appropriate local programs,
          and keeping one copy.  

Activities which require public notice should be planned well in advance to allow for a permit
processing time of around 90 days.  Public involvement such as public meetings and/or public
hearings could greatly increase the processing time.