On July 15, 2007 the MDA initiated two changes that will significantly impact NH3 handling or storage facilities. First, MDA has increased enforcement response to violations found during inspections. Second, MDA has established three "Service Status" categories as a fair and reasonable policy for determining compliance status of NH3 equipment and storage systems.
In Service Status
Equipment and storage systems in this category are subject to full inspection and enforcement by the MDA. Equipment and storage systems In Service must always be in full compliance.
Out of Service Status
Equipment (i.e. applicator/nurse tanks and toolbars) in this category is taken out of service in order to correct any non-compliance or for non-use/off-season placement and is subject to limited inspection and enforcement based on the following conditions:
- This service status must be established prior to an MDA inspection;
- Tanks must be at a liquid level of less than 10% and in adequate condition to safely hold product;
- Tagged: Information accurate/complete/legible, listing;
- Locked out valves must be secured with cable ties (i.e. metal, plastic, etc.);
- Emptying/removal of withdrawal hose(s);
- Toolbars must be emptied, pressure relieved, and the removal of non-compliant break-away coupling device assemblies;
- The following items must always be in compliance:
- Welded tank alterations/repairs, and dents (1/2+inch deep) must be inspected, tested, and documented by qualified firms/persons;
- Tank nameplate or equivalent must be legible, etc.;
- Pressure relief valves must be:
- In adequate condition with rain caps; and
- Within the 5 year service life as verified by installation records;
- Fittings, hosing, connections, piping, shut-off valves, and bleeder valves meet code requirements; and
- Hydrostats in adequate condition, with rain caps;
- Correct non-compliance and removal of tag and lock outs before equipment is placed back into service.
Recommend (optional): Maintain a written record of equipment placed in this service status category, available at the facility.
Zero Product/Pressure Status – For both NH3 Equipment & Storage Facilities
This service status category applies to both equipment and storage facilities (storage systems). Equipment and storage systems in this service status category are normally not subject to inspection and enforcement by the MDA under the following conditions:
- This service status must be established prior to an MDA inspection;
- NH3 and vapor pressure must be completely removed - zero product/zero pressure;
- Emptying and removal of all hosing; and
- Remove toolbars items consisting of:
- Pull-away coupler/double swivel, and
- Cold-flow, heat exchange, heat transfer units.
Recommend (optional): (1) affixing tag or “Tag It” Magnet tag on equipment or storage system; and (2) Maintain a written record of equipment and storage systems placed in this service status category, available at the facility.
When Service Status Policy Does Not Apply
The Service Status Policy does not apply when NH3 equipment or storage system is involved in a complaint, incident, or storage facility permit inspection. For more information, contact Ed Kaiser at ed.kaiser@ state.mn.us.
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