United States
Environmental Protection
Agency
Office of Solid Waste
and Emergency Response
(5104)
EPA-F-OQ-OQ5
March 2000
www.epa.gov/ceppo/
Anhydrous  Ammonia  Theft

The Environmental Protection Agency (EPA) is issuing this Alert as part of its ongoing effort to
protect human health and the environment by preventing chemical accidents. EPA is striving to
learn the causes and contributing factors associated with chemical accidents and to prevent their
recurrence. Major chemical accidents cannot be prevented solely through regulatory requirements.
Rather, understanding the fundamental root causes, widely disseminating the lessons learned, and
integrating these lessons learned into safe operations are also required. EPA publishes Alerts to
increase awareness of possible hazards. It is important that facilities,  SERCs, LEPCs, emergency
responders, and others review this information and take appropriate steps to minimize risk. This
document does not substitute for EPA's regulations, nor is it a regulation itself. It cannot and does
not impose legally binding requirements on EPA, states, or the regulated community, and the
measures it describes may not apply to a particular situation based upon circumstances. This guid-
ance does not represent final agency action and may change in the future, as appropriate.
  Wh>o should read this Alert? This Alert discusses the potential hazards of anhydrous
  ammonia releases caused by theft, steps facilities can take to prevent theft and how
  to minimize health and safety risks associated with accidental releases.  This Alert
  should be read by individuals who operate and maintain agricultural retail operations,
  facilities with ammonia refrigeration systems and  farmers who apply anhydrous
  ammonia as a fertilizer. Furthermore, this Alert should be reviewed by law enforce-
  ment personnel, emergency responders and members of Local Emergency Planning
  Committees (LEPCs).
 PROBLEM
                   ACCIDENTS
 Anhydrous ammonia is used as an agri-
 cultural fertilizer and industrial refrig-
 erant. The substance is stored and used
 at agricultural retailers and facilities
 with ammonia refrigeration systems.
 Anhydrous ammonia also is a key
 ingredient in the illegal production of
 methamphetamines.  Illegal drug mak-
 ers often steal anhydrous ammonia
 from areas where it is stored and used.
 Anhydrous ammonia is stored as a liq-
 uid under pressure, however, it
 becomes a toxic gas when released to
 the environment. Anhydrous ammonia
 can be harmful to  individuals who
 come into contact with it or inhale air-
 borne concentrations of the gas. When
 stolen, the toxic gas can be uninten-
 tionally released, causing injuries to
 emergency responders, law enforce-
 ment personnel, the public, and the
 criminals themselves.
                   A number of anhydrous ammonia thefts
                   have resulted in accidental chemical
                   releases from agricultural retailers and
                   facilities with ammonia refrigeration sys-
                   tems. The accidents have occurred when
                   valves were left open as anhydrous
                   ammonia was siphoned off; locks were
                   sawed or broken; anhydrous ammonia
                   was transferred inappropriately into
                   makeshift containers such as propane
                   tanks used on barbcquc grills; plugs were
                   removed from anhydrous ammonia lines
                   at refrigeration facilities; or the wrong
                   hoses and/or fittings were attached to stor-
                   age containers, causing leaks and spills
                   that would otherwise not have occurred.

                   Hie following section describes several
                   recent examples in more detail.

                   ^ Apnl 1997 - More than 2,000 pounds
                     of anhydrous ammonia were released
                     from a refrigerated warehouse. A

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Chemical Accident Prevention: Anhydrous Ammonia Theft
March 2000
   fence was cut to gain entry into the facility
   and the anhydrous ammonia was removed
   through a valve on an oil separator. The
   valve was left open.  Fortunately, the release
   was mitigated by a rain storm that knocked
   down the anhydrous ammonia vapor as it
   was being released to the outside air.  The
   warehouse owner replaced the fence,
   installed a valve lock on the oil separator
   valve, and requested enhanced police surveil-
   lance following the incident.

S April 1998 - An individual attempted to steal
   anhydrous ammonia from a nurse tank at a
   retail agricultural dealer in Iowa. The liquid
   withdrawal valve was left open on the nurse
   tank and caused an ammonia release that
   quickly vaporized to the air.  One passerby
   was overcome by the anhydrous ammonia
   fumes and collapsed.  Another nearby resi-
   dent was overcome by ammonia fumes after
   leaving her home. Both individuals were
   hospitalized. Several other area residents
   were evacuated as a precaution. The agricul-
   tural dealer installed security lights following
   the incident.

S April 1999 - A hose on a 30,000-gallon bulk
   storage tank of anhydrous ammonia was cut
   intentionally by thieves which resulted in an
   accidental release at an Illinois fertilizer
   dealer.  One police officer was hospitalized
   and a highway was shut down for a half
   hour.

S May 1999 - One person was killed when a
   makeshift container of anhydrous ammonia
   he was holding exploded. The death
   occurred when two individuals were driving
   on an interstate highway  in Missouri.  The
   driver was severely injured. The ammonia
   was to be used for methamphetamine pro-
   duction. Since the cause of the smoke ema-
   nating from the car was not immediately
   known, one fire-fighter, one emergency med-
   ical technician, and one member of the gen-
   eral public, all of whom stopped to help and
                                 drag the passenger and driver from the car,
                                 were also injured as a result of the ammonia
                                 release.

                              S February 2000 - Approximately  1000 pounds
                                 of anhydrous ammonia were released when
                                 someone intentionally opened a valve in the
                                 middle of the night at a fertilizer dealer in
                                 Missouri. The ammonia release caused 300
                                 residents to be evacuated from their homes
                                 and two persons reported respiratory irrita-
                                 tion problems.  Ammonia theft has been
                                 almost a weekly occurrence at this facility.
                                 A local law enforcement investigation is cur-
                                 rently  underway.

                              HAZARD AWARENESS

                              Anhydrous ammonia is used widely and in large
                              quantities for a variety of purposes. More than
                              80% of the ammonia produced in the United
                              States is used for agricultural purposes; less
                              than 2%  is used for refrigeration. Ammonia is
                              generally safe provided handling, operating, and
                              maintenance procedures are  followed.
                              Anhydrous ammonia is toxic, however, and can
                              be a health hazard. Effects of inhalation of
                              anhydrous ammonia range from lung irritation
                              to severe respiratory injuries, with possible
                              fatality at higher concentrations. Anhydrous
                              ammonia also is corrosive and can  bum the skin
                              and eyes.  Liquefied anhydrous ammonia is
                              stored as  a liquid and has a boiling point of
                              minus 28 degrees Fahrenheit.  At this tempera-
                              ture it can cause freezing bums.

                              When stored for agricultural purposes and for
                              use in refrigeration systems, anhydrous ammo-
                              nia is liquefied under pressure.  Liquid anhy-
                              drous ammonia expands 850 times when
                              released to ambient air and can form large
                              vapor clouds. Also, liquid anhydrous ammonia,
                              if accidentally released, may aerosolize (i.e.,
                              small liquid droplets may be released along
                              with ammonia gas) and behave as a dense  gas,
                              even though it is normally lighter than air.
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Chemical Accident Prevention: Anhydrous Ammonia Theft
March 2000
Anhydrous ammonia may also cause water
vapor to condense in the air forming a visible
white cloud. Therefore, when anhydrous
ammonia is released to the air, it may travel
along the ground in a cloud instead of immedi-
ately rising into the air and dispersing.  This
dense gas behavior may increase the potential
for exposure of workers and the public.

Anhydrous ammonia containers have particular
specifications as required by the Department of
Transportation (DOT).  Storage tank specifica-
tions for anhydrous ammonia ensure that it is
stored properly as a pressurized liquid and a
corrosive chemical.  For example, some storage
containers for anhydrous ammonia must have
rated pressure relief devices to reduce the likeli-
hood of over pressurization of the container.
Because anhydrous ammonia is corrosive,  spe-
cific valves and hoses that do not readily cor-
rode have to be used.

Pure anhydrous ammonia vapors can become an
explosion hazard when in a confined space at
concentrations between 16  and 25 % by vol-
ume.  Mixtures involving anhydrous ammonia
contaminated with lubricating oil (e.g. in a
refrigeration system), however, may lower the
explosive range.

Anhydrous ammonia can be recognized by its
pungent odor.  Odor threshold varies with the
individual but ammonia can usually be detected
at concentrations above 5 ppm. Concentrations
above 100 ppm are uncomfortable to most peo-
ple; concentrations in the range of 300 to 500
ppm will cause people to leave the area and are
immediately dangerous to life and health.

CLANDESTINE USE

Anhydrous ammonia can be as inexpensive as
$200 a ton  for  agricultural purposes, but can
sell for as much as $300 per gallon on the  black
market when obtained illegally. Very small
amounts of anhydrous ammonia are needed to
make a batch of methamphetamine.  In fact,
                              enough "residual" ammonia is left in a typical
                              transfer hose for a criminal to use for metham-
                              phetamine production.

                              Anhydrous ammonia theft appears to occur in
                              waves with thieves stealing the chemical multi-
                              ple times at one location.  Criminals prefer to
                              use anhydrous ammonia to manufacture
                              methamphetamine because many of the other
                              ingredients needed to make the drug are avail-
                              able commercially. Additionally, the fact that
                              anhydrous ammonia speeds up the manufactur-
                              ing process to just a few hours makes it attrac-
                              tive to drug makers.

                              Attempted thefts have occurred at such unlikely
                              places as refrigeration systems holding ammo-
                              nia, underground pipelines carrying ammonia,
                              and rail cars transporting anhydrous ammonia.
                              Often thefts are aborted when thieves are
                              injured or overcome by the toxic gas.  During
                              these aborted attempts, "tools" are often left
                              behind, such as duct tape, inner tubes, buckets,
                              coolers, and/or propane barbeque bottles.
                              Several states have passed legislation making it
                              a felony to tamper with or steal anhydrous
                              ammonia, or hold the substance in a non-
                              approved container.

                              Special note to first responders:
                              Anhydrous ammonia can be found in the DOT
                              Emergency Response Guidebook under Number
                              125.  The UN Number for anhydrous ammonia
                              is 1005 and is placarded Class 2.2,
                              Nonflammable gas.

                              Anhydrous ammonia corrodes brass valving
                              turning the  brass to a blue/green color. When
                              inside inappropriate  pressure cylinders (e.g.
                              propane cylinders), anhydrous ammonia attacks
                              brass valving from the inside out.  In this  situa-
                              tion, it is difficult to assess the integrity of valv-
                              ing from outside physical appearances.
                              Extreme caution should be used when handling
                              inappropriate containers storing anhydrous
                              ammonia. Brass valving that appeared to be
                              physically intact from outside appearance has
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Chemical Accident Prevention: Anhydrous Ammonia Theft
March 2000
been known to break off in the hands of respon-
ders creating an uncontrolled release from the
container. Also, these containers should not be
transported in the trunks of cars or other vehi-
cles where the container and the occupant are in
the same compartment.

Furthermore, responders should take care in
selecting the proper personal protective equip-
ment (PPE) level. Due to anhydrous ammonia's
low boiling point, affinity for water, and inhala-
tion hazard, responders can be  injured if not
wearing proper PPE. Structural fire fighter pro-
tective clothing may not provide adequate pro-
tection during an anhydrous ammonia release.
The use of self-contained positive-pressure
breathing apparatus is appropriate during a
response to an anhydrous ammonia release. In
addition to other appropriate PPE, in some
cases it may be necessary to wear cryogenic
gloves with a moisture barrier to protect against
freezing and/or chemical bums.

HAZARD REDUCTION AND
PREVENTION

Here are some tips to deter anhydrous ammonia
theft:

S Educate your  employees about the theft
   problem.
S Store tanks in well-lit areas.
S Know your inventory to quickly identify
   missing chemicals.
S Visually inspect tanks each morning, espe-
   cially following weekends or other periods
   where the facility is not occupied.
S Consider auditing your facility and setting up
   a valve protection plan for critical valves that
   could cause significant releases if left open.
-S Consider installing valve locks or fencing,
   especially for unattended tanks.*
S Report thefts,  signs of tampering, leaks, or
   any unusual activity to local law enforcement
   officials.
                               -S Consider installing other theft deterrent
                                 measures such as motion detector lights,
                                 motion detector alarms, security patrols,
                                 and/or video surveillance.

                               * The ANSI Standard K61.1 states under section
                               6.7 "Protection of Container and
                               Appurtenances " that "main container shut-off
                               valves shall be kept closed and locked when the
                               installation is unattended. "  Furthermore, it
                               states that "if the facility is protected against
                               tampering by fencing, or other suitable means,
                               valve locks are not required."  Many states have
                               adopted the ANSI Standard K61.1 as law;
                               please check your state regulations or contact
                               your state agricultural department or fire mar-
                               shal for details.  Also, OSHA 's requirement for
                               storage and handling of anhydrous ammonia
                               under 1910.111(c)(6) state  that "valves, regu-
                               lating, gaging, and other appurtenances shall
                               be protected against tampering and physical
                               In addition to the general tips above, agricultur-
                               al dealers or retailers should consider removing
                               hoses during the off-season and storing them
                               separately from tanks.  Also, farmers may con-
                               sider removing nurse tanks from fields when
                               they are no longer needed and returning used
                               tanks, applicators, or toolbars promptly to the
                               dealer after use. Finally, refrigeration facilities
                               may want to evaluate the benefits of installing
                               lockable,  quarter-turn, spring-loaded, ball
                               valves in  series with a manual valve in critical
                               areas such as at the system fill point or oil dis-
                               charge pot.

                               Special note on purchases:
                               Agricultural retail establishments should be aware
                               that they may be approached by individuals want-
                               ing to purchase ammonia for use in the illegal
                               production of methamphetamine. The following
                               list was developed by the Drug Enforcement
                               Administration (DBA) to help you identify indi-
                               viduals who may be seeking to purchase  anhy-
                               drous ammonia for illegal purposes:
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Chemical Accident Prevention: Anhydrous Ammonia Theft
March 2000
4   Customer cannot answer or is evasive about
    agricultural use questions.
4   Customer insists on taking possession rather
    than having it delivered.
4   Customer insists on using cash, money
    order or cashiers check.
4   Customer is a stranger and unfamiliar to
    area or your business.
4   Customer provides suspicious business or
    credit information.
4   Customer is vague or resists providing per-
    sonal information
4   Customer intends to fill their own inappro-
    priate tank (e.g. a 20-pound propane cylin-
    der).  Note: It is unlawful in some states to
    sell anhydrous ammonia unless it is in an
    approved product container.

If a customer fits any of these criteria, wait until
the person has left your business, write down an
accurate description of the person(s), vehicle,
license number and contact the DBA or local
law enforcement authorities immediately.

INFORMATION RESOURCES

EPA has prepared a general advisory on ammo-
nia and a safety alert on the "Hazards of
Ammonia Releases at Ammonia Refrigeration
Facilities."  Both are available at:
www.epa.gov/ceppo

The Agricultural  Retailers Association (ARA)
and The Fertilizer Institute (TFI) have a
brochure "Deter Theft of Anhydrous
Ammonia." www.tfi.org or (202)  675-8250;
www.aral.org or (202) 457-0825

The Agribusiness Association of Iowa has pre-
pared a fact sheet "Anhydrous Ammonia Theft,
What You Need To Know," available at:
www.exnet.iastate.edu/publications/
pg99015.pdf

The Hazardous Materials Emergency
Preparedness Grant Program has a publication
available "Guidelines for Public Sector
                              Hazardous Materials Training" - See Section 2,
                              Special Topics - Illicit Use of Hazardous
                              Materials: First Responder Training Issues.
                              www.fema.gov/emi/hmep

                              STATUTES AND REGULATIONS

                              The following is a list of federal statutes and
                              regulations related to process safety, accident
                              prevention, emergency planning, and release
                              reporting.

                              EPA

                              Clean Air Act (CAA)
                                General Duty Clause  [Section 112(r)(l) of
                                the Act] - Facilities handling extremely haz-
                                ardous chemicals (including anhydrous
                                ammonia) have a general duty to assess haz-
                                ards, design and maintain a safe facility, and
                                minimize the consequences of accidental
                                releases.
                                Risk Management Program (RMP) Rule [40
                                CFR 68] - Facilities that have anhydrous
                                ammonia in quantities greater than 10,000
                                pounds are required to develop a hazard
                                assessment, a prevention program, an emer-
                                gency response program, and submit a risk
                                management plan to EPA.

                              Emergency Planning and Community Right-To-
                              Know Act (EPCRA)
                              -  Emergency Planning  [40 CFR Part 355] -
                                Facilities that have  500 pounds or more of
                                ammonia must report to their LEPC and
                                SERC and comply with certain requirements
                                for emergency planning.
                                Emergency Release Notification  [40 CFR
                                Part 355] - Facilities that release  100 pounds
                                or more of ammonia (other than the normal
                                application of a fertilizer) must immediately
                                report the release to the LEPC and to the
                                SERC.
                                Hazardous Chemical  Reporting [40 CFR Part
                                370] - Facilities that have ammonia at or
                                above 500 pounds must submit an MSDS to
                                their LEPC, SERC, and local fire
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Chemical Accident Prevention: Anhydrous Ammonia Theft
March 2000
   department and comply with the Tier I/Tier
   II inventory reporting requirements.

Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA)
  Hazardous Substance Release Reporting [40
   CFR 302] -  Facilities that release 100 pounds
   or more of ammonia (other than the normal
   application of a fertilizer) must immediately
   report the release to the National Response
   Center (NRC), (800) 424-8802.

DOT

  The Department of Transportation (DOT)
   [49 CFR 100-180] - Research and Special
   Projects Administration has requirements
   covering the transportation of anhydrous
   ammonia containers.

OSHA

-  Process Safety Management (PSM) Standard
   [29 CFR 1910.119] Anhydrous ammonia is
   listed as a highly hazardous substance.
   Facilities that have ammonia in quantities at
   or above the threshold quantity of 10,000
   pounds are subject to a number of require-
   ments for management of hazards, including
   performing a process hazards analysis and
   maintaining mechanical integrity of equip-
   ment.  The PSM requirements do not apply
   to retail facilities per 1910.119(a)(2).
  Hazard Communication [29 CFR 1920.120] -
   Requires that the potential hazards of toxic
   and hazardous chemicals be evaluated and
   that employers transmit this information to
   their employees.
  Storage and Handling of Anhydrous
   Ammonia [29 CFR 1910.111] - Requires
   standards for design, construction, location,
   installation,  and operation of anhydrous
   ammonia systems.
                              CODES AND STANDARDS

                              There are a number of state codes and industry
                              standards that apply to safe handling, use, and
                              storage of anhydrous ammonia. A few exam-
                              ples are given below.

                              American National Standards Institutes (ANSI)
                              K61.1, 1999 - Standards for the Storage and
                              Handling of Anhydrous Ammonia
                              Available from ANSI
                              11 West 42nd Street
                              New York, NY  10036
                              (212) 642-4900
                              Web site: www.ansi.org

                              ANSI/IIAR 2-1992 -  Equipment, Design, and
                              Installation of Ammonia Mechanical
                              Refrigeration Systems
                              Available from International Institute of
                              Ammonia Refrigeration (IIAR)
                              1200 19th Street, NW
                              Suite 300
                              Washington, DC 22036-2422
                              (202)857-1110
                               For More Information:
                               Contact the EPCRA Hotline at:
                               (800) 424-9346 or (703) 412-9810
                               TDD (800) 553-7672
                               Monday -Friday, 9 AM to 6 PM, EST

                               For information on OSHA standards contact
                               OSHA Public Information at (202) 219-8151
                               or visit the web site: www.osha.gov

                               Visit the CEPPO Home Page at:
                               www.epa.gov/ceppo/
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