Anhydrous Ammonia Incident Reporting Requirements

Who is responsible to report an anhydrous ammonia (NH3) incident?

The person who at the time of the incident has 1) custody of, 2) control of, 3) or responsibility for the anhydrous ammonia or its container (owner of real property) is to immediately report the incident. If the dealer/supplier (dealer) provided the NH3 equipment to a customer, either the dealer or the customer must report the release to the MDO. If a customer calls a dealer to report an NH3 incident/release, the dealer must immediately report the incident to the MDO.

When do I have to report a NH3 release to the MDO?

You must immediately report an incident that releases or immediately threatens to release ammonia into the environment. You must immediately report an incident that injured a person or adversely affected the environment even if the damage was caused by normal use or practice. Please be aware that a reportable incident can have no release of NH3 such as a nurse tank roll over (this is an example of a threatened release – SEE below).

Examples: You must immediately report these incidents to the MDO–

1. A hose end valve is bumped open and a worker is exposed to NH3 vapor. This incident is an event that caused unreasonable effects on the environment. The definition of environment includes humans (MN Stat. 18C.005, Subd. 10).
2. A partially full nurse tank is being delivered to a corn field. When turning a corner too sharp the nurse tank overturns. All valves and gauges are intact. This is an incident that must be immediately reported because an incident includes the threat of a release. The threat exists because of tank damage and the potential release when off-loading and up-righting it.
3. Broken pump seal that releases NH3.

How long do I have to report the incident?

Incidents must be reported immediately upon discovery. Report the incident by contacting the Duty Officer at either 651/649-5451 or 1-800-422-0798 satisfies ALL Minnesota state reporting requirements.

When NOT to report to the MDO?

1. Reporting is not required for releases, resulting from the normal use of a product or practice in accordance with the law; and
2. no one is injured and/or the environment is not damaged.

Example: Do NOT report in this release to the MDO – The release of NH3 via bleeders when disconnecting nurse or transport tank hosing at loading and unloading areas (risers).

IS there a reportable quantity?

NO: State of Minnesota Reporting Requirements via MDO: No specific reportable quantity is detailed in the law. Therefore, NH3 incidents of any amount must be reported to the MDO.

YES: Federal Reporting via the National Response Center (1-800-424-8802): You must notify the Federal authorities when the release is equal or greater than 100 pounds. Remember that reporting an incident to the MDO does NOT satisfy your federal reporting responsibility.

Example: While applying NH3 the nurse tank hitch breaks, and the pull-away coupling fails to release. The withdrawal hose stretches and splits causing a release of NH3 before the withdrawal valve can be manually closed. The resulting uncontrolled release was less than 100 pounds. In this case this incident must be immediately reported to the MDO, but NOT to the National Response Center (federal reporting) because the amount released was less than 100 pounds.

Other – What should I do if I think someone has vandalized or stolen NH3?

Report the NH3 vandalism/theft to the MDO. The MDO will alert the appropriate state agencies such as the Bureau of Criminal Apprehension.

Example: Report this to the MDO and the local authorities - During the early morning you discover that caps have been removed from several parked nurse tanks and you suspect someone has been tampering with the valves. This is not an incident BUT report the vandalism to the MDO and local authorities so that they are aware of the suspected theft and vandalism.