Reporting NH3 Releases

IFCA recently met with Illinois EPA regarding anhydrous ammonia releases over the past two years.  IEPA and IDA report that NH3 releases at stationary storage locations are down but field of application releases are slightly higher.  Once an anhydrous ammonia release has been reported to IEPA, they will then send an Incident Inquiry Letter (IIL) to the responsible party requesting a detailed description of the incident and cause.  It is extremely important to respond to the Incident Inquiry Letter with detailed information about the incident.  Failure to adequately reply to IEPA with all the proper information requested in the initial letter can result in a non-compliance advisory letter or potentially a notice of violation from IEPA.  The person who is in control of the ammonia at the time of a reportable release must make the call to LEPC, IEMA and NRC.  Even if the farmer reports the release, because retailers own the ammonia equipment, you may also be required to provide information to IEPA if equipment failure is suspected as a cause of the release.  Responding back to IEPA with detailed information about the incident can go a long way to helping resolve an issue and avoiding a violation letter.  As you prepare for fall ammonia season, please review the emergency response procedures with your employees and customers.  IFCA has wallet cards available free of charge for your employees and to give to your farmer customers, just let us know how many you need.  If you have a RQ release of NH3 and you receive an IIL from IEPA please contact Kevin or Jean at the IFCA office for assistance in responding to the letter.