Air Issues and Clean Air Act
In response to air quality concerns at local and national levels, fertilizer manufacturers implement a number of environmental management systems to control air emissions of concern including emissions of nitrogen oxides (NOX), sulfur oxides (SOX), particulate matter and ammonia (NH3).
Wet scrubbers or fabric filters are used to control fugitive emissions from bagging operations and the use of additional technologies control nitrous oxide and sulfur oxide releases. In addition ammonia recovery units, scrubber systems are used to minimize ammonia emissions. Fertilizer production facilities also employ a range of emission control technologies specific to distinct air emissions that result from various production processes.
Clean Air Act Risk Management Program (RMP)
Anhydrous ammonia, which is the basic building block for most nitrogen fertilizers, as well as a finished fertilizer directly applied to farmers’ fields, is comprised of 82 percent nitrogen. As such, under certain climactic conditions (low humidity for example) when accidentally released, ammonia will disperse to the air and return to its atmospheric form. Under certain conditions, a sudden accidental release of ammonia can create a hazardous cloud of gas that can harm members of the affected community. For this reason, ammonia is subject to the accident prevention provision of the Clean Air Act.
When Congress passed the Clean Air Act Amendments of 1990, Section 112r required EPA to publish regulations and guidance for chemical accident prevention at facilities using substances that posed the greatest risk of harm from accidental releases. These regulations were built upon existing industry codes and standards and require companies of all sizes that use certain listed regulated substances including anhydrous ammonia which is used in fertilizer production and as a finished fertilizer, to develop a RMP, which includes a(n):
- Hazard assessment that details the potential effects of an accidental release, an accident history of the last five years, and an evaluation of worst-case and alternative accidental releases scenarios;
- Prevention program that includes safety precautions and maintenance, monitoring, and employee training measures; and
- Emergency response program that spells out emergency health care, employee training measures and procedures for informing the public and response agencies (e.g., the fire department) should an accident occur.
The RMP plans must be revised and resubmitted to EPA every five years. There are other circumstances described in the RMP regulations, however, which may require a more frequent submission. New facilities must submit a completed RMP as soon as they have a covered chemical above the threshold quantity.
The Risk Management Program is about reducing chemical risk at the local level. The RMP information helps local fire, police, and emergency response personnel (who must prepare for and respond to chemical accidents), and is useful to citizens in understanding the chemical hazards in communities.
Throughout the life of the RMP program, TFI has worked with EPA and compliance experts at organizations such as the Asmark Institute to provide fertilizer retailers with RMP compliance tools. Most recently, TFI and Asmark released myRMP, a suite of retail guidance materials which is a revised version of guidance originally published by TFI in 1998 to assist these small businesses in complying with the RMP rule.