The following are key safety measures the EPA will use in its inspection of facilities storing/processing Anhydrous Ammonia (NH3). These are measures that EPA has determined should be in place, regardless of a facility’s age or size. This is not intended to be a comprehensive list of essential safety measures, but rather a subset of easily verifiable items that can help facilities prevent ammonia releases and prepare for any that do occur. This also does NOT replace the obligation to comply with EPA’s Risk Management Program, found at 40 C.F.R. Part 68, or the Clean Air Act General Duty Clause.
The RAGAGEP referenced in this cheat sheet is CGA 2.1 and would be applicable at:
- Ammonia Fertilizer Distribution Facilities
- Ammonia Manufacturing Facilities
- Coal-Fired Power Plants utilizing a Selective Catalytic Reduction (SCR) process that uses NH3
- Nitriding businesses where NH3 is converted to N2 for heat treating
We should consider OSHA’s 1910.111 standard for those with less than 10,000 pounds in the process. When we exceed the PSM/RMP threshold of 10,000 pounds, we now use CGA 2.1 as our baseline RAGAGEP.