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Fact Sheet

November 2007

Ten Tips to Prepare for EPA Risk Management Program Inspections

This fact sheet was prepared to assist anhydrous ammonia retailers that handle, process or store anhydrous ammonia above a threshold quantity of 10,000 pounds that are subject to chemical safety requirements within the Risk Management Program.

Nurse Wagons  Ammonia Storage Tank  Nurse Tank

  1. Have a copy of your most recent Risk Management Plan (RMP) submittal (should be within the last five years).
  2. Have copies of the most recent material safety data sheet from your anhydrous ammonia suppliers.
  3. Have a copy of the hazard review.  (Does it include all of the hazards relating to your facility?)
  4. Have copies of your compliance audits, which are required every three years.
  5. Have copies of your written operating procedures.
  6. Have copies of incident investigations for any accident, especially if it resulted in injury or off-site evacuation/shelter in place.
  7. Coordinate your accident prevention efforts with local first responders.
  8. Perform equipment maintenance and inspections.
  9. Train employees and provide refresher training.
  10. Demonstrate compliance with current industry standards.  (1999 version of ANSI K61.1).

You want to be certain that you have implemented the new industry standards, planned them, or documented that they are not needed.  Inspectors will look at vehicle barriers, emergency shutoffs, emergency breakaways at risers, proper paint (to avoid excessive rust), hoses/relief valves that are not out of date, warning labels, and emergency water sources.

For guidance:  Please review MYRMP, which was developed by The Fertilizer Institute and reviewed by EPA.  MYRMP is available at http://www.asmark.org/myrmp/agreement.shtmlExit EPA Click for Disclaimer

For additional information contact:

George Hess
EPA environmental Protection Specialist
(913) 551-7540
hess.george@epa.gov

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