THE NEW MILLENNIUM THE NEW MILLENNIUM CAPP PROGRAM CAPP PROGRAM

Overview & IntroductionOverview & Introduction to the to the

Risk Management Program Risk Management Program

Why Risk Management Program?Why Risk Management Program?Congressional response to preventing Congressional response to preventing further major chemical accidentsfurther major chemical accidents–Bhopal, IndiaBhopal, India–Institute, West VirginiaInstitute, West Virginia–Chernobyl, RussiaChernobyl, Russia

In the event of an accidental release:In the event of an accidental release:–OSHA PSM designed to protect on-site OSHA PSM designed to protect on-site

workersworkers–EPA RMP designed to protect nearby EPA RMP designed to protect nearby

communitycommunity

CAA Amendments of 1990CAA Amendments of 1990Clean Air Act (CAA) AmendmentsClean Air Act (CAA) Amendments- General Duty Clause- General Duty Clause- EPA List of Regulated Substances- EPA List of Regulated SubstancesEPA RMP 40 CFR 68 6/20/1996EPA RMP 40 CFR 68 6/20/1996–Amended 8/5/1999 by the Chemical Safety Amended 8/5/1999 by the Chemical Safety

Information, Site Security, and Fuels Information, Site Security, and Fuels Regulatory Relief Act (CSISSFRRA)Regulatory Relief Act (CSISSFRRA)

BASIC GOAL OF RMPROGRAM BASIC GOAL OF RMPROGRAM Reduce the likelihood and severity of Reduce the likelihood and severity of accidental chemical releases by using accidental chemical releases by using hazard assessments, prevention programs hazard assessments, prevention programs and emergency response planningand emergency response planning

EPA's VisionEPA's Vision for Accidental Release Preventionfor Accidental Release PreventionEmphasize Community-Right-to-KnowEmphasize Community-Right-to-KnowLet Information Drive ActionLet Information Drive ActionFocus the Program at the Local levelFocus the Program at the Local levelHave EPA support for State & Local Have EPA support for State & Local activitiesactivities

Coordinate communication at the Local level Coordinate communication at the Local level

EPA's Regulatory ApproachEPA's Regulatory ApproachPerformance based approachPerformance based approachBuild on existing programs and standardsBuild on existing programs and standardsScale requirements to fit riskScale requirements to fit riskCoordinate with OSHA and DOTCoordinate with OSHA and DOT

PURPOSE OF THE RMPPURPOSE OF THE RMPDesigned to identify and remedy deficiencies Designed to identify and remedy deficiencies before an accident happensbefore an accident happens

Prevent accidents and not simply try to find Prevent accidents and not simply try to find better ways to respond to thembetter ways to respond to them

Inform the publicInform the public

WHO IS SUBJECT TO THE RMP?WHO IS SUBJECT TO THE RMP?Stationary sources that have more than a Stationary sources that have more than a threshold quantity of a listed substancethreshold quantity of a listed substance–EPA has developed a list of chemicals:EPA has developed a list of chemicals:

77 toxic77 toxic63 flammable63 flammable

–If a facility stores one of these chemicals at If a facility stores one of these chemicals at quantities > TQ…..FACILITY REQUIRES AN RMPquantities > TQ…..FACILITY REQUIRES AN RMP

GENERAL DUTY CLAUSEGENERAL DUTY CLAUSEIdentify HazardsIdentify HazardsDesign, Maintain & Operate Facility IAW Design, Maintain & Operate Facility IAW Industry StandardsIndustry Standards

Minimize Consequences of an Accidental Minimize Consequences of an Accidental Release Release

FIVE COMPONENTS OF RMPFIVE COMPONENTS OF RMPHazard AssessmentHazard AssessmentManagement SystemManagement SystemPrevention ProgramPrevention ProgramEmergency Response ProgramEmergency Response ProgramRisk Management Plan (describing above)Risk Management Plan (describing above)

HAZARD ASSESSMENTHAZARD ASSESSMENTWorst-Case Release ScenarioWorst-Case Release ScenarioAlternative Release ScenarioAlternative Release ScenarioIdentifying Offsite ImpactsIdentifying Offsite ImpactsFive-Year Accident HistoryFive-Year Accident History

WORSE-CASE RELEASE SCENARIO (68.3)WORSE-CASE RELEASE SCENARIO (68.3)

The release of the largest quantity of a The release of the largest quantity of a substance from a vessel or process line substance from a vessel or process line failure that results in the greatest distance to failure that results in the greatest distance to an endpointan endpoint

TOXIC ENDPOINTTOXIC ENDPOINT (listed in Appendix A)(listed in Appendix A)Emergency Response Planning Guidance Emergency Response Planning Guidance Level 2 (ERPG-2)Level 2 (ERPG-2)

Level of ConcernLevel of ConcernAcute Exposure Guideline Level (AEGLs) Acute Exposure Guideline Level (AEGLs) (being developed)(being developed)

FLAMMABLE ENDPOINTSFLAMMABLE ENDPOINTSExplosive Overpressure of 1 psiExplosive Overpressure of 1 psiRadiant Heat: 5kW/sq. meter for 40 secRadiant Heat: 5kW/sq. meter for 40 secLower Flammable LimitLower Flammable Limit

ALTERNATIVE RELEASE SCENARIO ALTERNATIVE RELEASE SCENARIO (68.28)(68.28)Releases with an offsite impact that are more Releases with an offsite impact that are more likely to occur than the worst-case releases likely to occur than the worst-case releases and that consider active and passive and that consider active and passive mitigation systemsmitigation systems

Worst & Alternative Case End Point DistancesWorst & Alternative Case End Point Distances

FIVE-YEAR ACCIDENT HISTORY FIVE-YEAR ACCIDENT HISTORY Must include all accidental releases of Must include all accidental releases of regulated substances from a covered regulated substances from a covered processes resulting in serious onsite or processes resulting in serious onsite or offsite impacts in the 5 years prior to the offsite impacts in the 5 years prior to the submission of each RMP submission of each RMP

112

2

3

4567

8

9

1011

RMP ProgramsRMP ProgramsProgram 1Program 1Program 2Program 2Program 3Program 3

One source could have processes in one or more programs

Region 3 RMP FacilitiesRegion 3 RMP FacilitiesR3 Total - 828R3 Total - 828–PennsylvaniaPennsylvania

409409–Virginia Virginia

176176–Maryland Maryland 121 121–West Virginia 83West Virginia 83–Delaware Delaware

3737–Washington DC 2Washington DC 2

RMP InspectionsRMP InspectionsRMP regulations provide an inspection RMP regulations provide an inspection component to evaluate the quality of the risk component to evaluate the quality of the risk management programsmanagement programs

Region 3 performed over 50 inspections in Region 3 performed over 50 inspections in FY05 including:FY05 including:–RMP AuditsRMP Audits–General Duty Clause inspectionsGeneral Duty Clause inspections–Accident InvestigationsAccident Investigations

What Are We Finding?What Are We Finding?Out of about 50 scheduled audits…Out of about 50 scheduled audits…– Chlorine 45%Chlorine 45%– Ammonia 35%Ammonia 35%– Chemicals 20%.Chemicals 20%.

That’s not to say they were all in good shape;That’s not to say they were all in good shape; it it seems municipal water/wastewater plants are among the seems municipal water/wastewater plants are among the poorest performers!poorest performers!

Audits in response to accidental releases average:Audits in response to accidental releases average:– Chlorine Chlorine 40%40%– Ammonia Ammonia 50% 50%– Chemicals Chemicals 10%10%

Facility Siting Implications to RMPFacility Siting Implications to RMPDetermine potential receptorsDetermine potential receptorsProactive steps towards mitigation Proactive steps towards mitigation Provides a forum for communicationProvides a forum for communicationAlthough the Federal Government does not Although the Federal Government does not have responsibility for land use planning and have responsibility for land use planning and zoning, which is strictly a local issue, it will, zoning, which is strictly a local issue, it will, however, provide information however, provide information

POTENTIAL RMP BENEFITSPOTENTIAL RMP BENEFITSSTATES-Establish areas of concern to STATES-Establish areas of concern to identify needs and allocate limited resourcesidentify needs and allocate limited resources

COMMUNITIES-Understand local risks and COMMUNITIES-Understand local risks and identify vunerable populations to improve identify vunerable populations to improve community emergency notification and community emergency notification and responseresponse

FACILITIES-Verify risks to help prioritize FACILITIES-Verify risks to help prioritize prevention and mitigation activitiesprevention and mitigation activities

POTENTIAL INDUSTRY BENEFITS POTENTIAL INDUSTRY BENEFITS

Operations & Maintenance EmployeesOperations & Maintenance EmployeesUp-to-Date Operating ProceduresUp-to-Date Operating ProceduresReliable EquipmentReliable EquipmentIncreased Quality ProductIncreased Quality ProductLess Unit Downtime Less Unit Downtime Potential for Greater ProfitabilityPotential for Greater ProfitabilityReduced Insurance Premiums PotentialReduced Insurance Premiums Potential Improved Community & Gov't RelationsImproved Community & Gov't RelationsSafer Operation Safer Operation

LOCAL GOVERNMENT/LEPC LOCAL GOVERNMENT/LEPC BENEFITS BENEFITS

Carry out Emergency Planning req'mts Carry out Emergency Planning req'mts First Responders implement Contingency First Responders implement Contingency Plans during chemical accident responsesPlans during chemical accident responses

LEPCs can be a source of RMP informationLEPCs can be a source of RMP informationCan learn about facilities' accident historyCan learn about facilities' accident historyLEPCs can work with industry and public to LEPCs can work with industry and public to encourage safety, risk reduction and encourage safety, risk reduction and accident prevention accident prevention

PUBLIC BENEFITSPUBLIC BENEFITSIncreased awareness and understanding of Increased awareness and understanding of chemical hazards/industry practiceschemical hazards/industry practices

Enter into a dialouge on an informed basis Enter into a dialouge on an informed basis with facility and/or govermental agencies on with facility and/or govermental agencies on matters of concernmatters of concern

Opportunity to support actions to ensure Opportunity to support actions to ensure public safety and environmental protectionpublic safety and environmental protection

Geographic/Industry Comparative analyses Geographic/Industry Comparative analyses

Concluding RemarksConcluding Remarks1st time for electronic submission1st time for electronic submission Chemical Safety begins at local levelChemical Safety begins at local level System developed with input of various System developed with input of various stakeholders stakeholders

Concluding RemarksConcluding RemarksUsed in combination with other CEPPO Used in combination with other CEPPO tools, e.g., CAMEO, Lanviewtools, e.g., CAMEO, Lanview

RMP*Submit & RMP*Info closes the loop RMP*Submit & RMP*Info closes the loop with EPCRA in emergency preparedness & with EPCRA in emergency preparedness & preventionprevention

CONTACTSCONTACTSWeb page Address Web page Address http://www.epa.gov/ceppohttp://www.epa.gov/ceppo

RMP*Info RMP*Info http://www.epa.gov/envirohttp://www.epa.gov/enviro

EPCRA Hotline (800) 424-9346 or EPCRA Hotline (800) 424-9346 or (800) 535-0202 or (703) (800) 535-0202 or (703) 412-9810412-9810

Mikal Shabazz (215) 814-3281 or Mikal Shabazz (215) 814-3281 or shabazz.mikal@epamail.epa.govshabazz.mikal@epamail.epa.gov