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)? þ 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. þ A contingency plan that describes the actions used at the facility to notify persons in the immediate area of a sudden release of ammonia. þ Venting all vapors back to the host tank when transferring ammonia. þ Bleeding vapors from hoses and connectors into an adequate volume of water after unloading operations are performed. þ Barricading around the permanent ammonia storage tanks to keep vehicular collisions from occurring. þ 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. þ 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)? þ Water sprays or fog systems over the permanent storage tanks. þ Diking around the permanent ammonia tanks to funnel ammonia in order to minimize vaporization. þ Addition of rupture disks and pressure gauges upstream or downstream of the relief valves to eliminate fugitive emissions from these sources. þ 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.