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THE NEW MILLENNIUM CAPP PROGRAM

THE NEW MILLENNIUM CAPP PROGRAM . Overview & Introduction to the Risk Management Program . Why Risk Management Program?. Congressional response to preventing further major chemical accidents Bhopal, India Institute, West Virginia Chernobyl, Russia

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THE NEW MILLENNIUM CAPP PROGRAM

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  1. THE NEW MILLENNIUM CAPP PROGRAM Overview & Introduction to the Risk Management Program

  2. Why Risk Management Program? • Congressional response to preventing further major chemical accidents • Bhopal, India • Institute, West Virginia • Chernobyl, Russia • In the event of an accidental release: • OSHA PSM designed to protect on-site workers • EPA RMP designed to protect nearby community

  3. CAA Amendments of 1990 • Clean Air Act (CAA) Amendments • - General Duty Clause • - EPA List of Regulated Substances • EPA RMP 40 CFR 68 6/20/1996 • Amended 8/5/1999 by the Chemical Safety Information, Site Security, and Fuels Regulatory Relief Act (CSISSFRRA)

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

  5. EPA's Vision for Accidental Release Prevention • Emphasize Community-Right-to-Know • Let Information Drive Action • Focus the Program at the Local level • Have EPA support for State & Local activities • Coordinate communication at the Local level

  6. EPA's Regulatory Approach • Performance based approach • Build on existing programs and standards • Scale requirements to fit risk • Coordinate with OSHA and DOT

  7. PURPOSE OF THE RMP • Designed to identify and remedy deficiencies before an accident happens • Prevent accidents and not simply try to find better ways to respond to them • Inform the public

  8. WHO IS SUBJECT TO THE RMP? • Stationary sources that have more than a threshold quantity of a listed substance • EPA has developed a list of chemicals: • 77 toxic • 63 flammable • If a facility stores one of these chemicals at quantities > TQ…..FACILITY REQUIRES AN RMP

  9. GENERAL DUTY CLAUSE • Identify Hazards • Design, Maintain & Operate Facility IAW Industry Standards • Minimize Consequences of an Accidental Release

  10. FIVE COMPONENTS OF RMP • Hazard Assessment • Management System • Prevention Program • Emergency Response Program • Risk Management Plan (describing above)

  11. HAZARD ASSESSMENT • Worst-Case Release Scenario • Alternative Release Scenario • Identifying Offsite Impacts • Five-Year Accident History

  12. WORSE-CASE RELEASE SCENARIO (68.3) • The release of the largest quantity of a substance from a vessel or process line failure that results in the greatest distance to an endpoint

  13. TOXIC ENDPOINT (listed in Appendix A) • Emergency Response Planning Guidance Level 2 (ERPG-2) • Level of Concern • Acute Exposure Guideline Level (AEGLs) (being developed)

  14. FLAMMABLE ENDPOINTS • Explosive Overpressure of 1 psi • Radiant Heat: 5kW/sq. meter for 40 sec • Lower Flammable Limit

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

  16. Worst & Alternative Case End Point Distances

  17. FIVE-YEAR ACCIDENT HISTORY • Must include all accidental releases of regulated substances from a covered processes resulting in serious onsite or offsite impacts in the 5 years prior to the submission of each RMP 12 11 1 10 2 3 9 4 8 5 7 6

  18. RMP Programs • Program 1 • Program 2 • Program 3 One source could have processes in one or more programs

  19. Region 3 RMP Facilities • R3 Total - 828 • Pennsylvania 409 • Virginia 176 • Maryland 121 • West Virginia 83 • Delaware 37 • Washington DC 2

  20. RMP Inspections • RMP regulations provide an inspection component to evaluate the quality of the risk management programs • Region 3 performed over 50 inspections in FY05 including: • RMP Audits • General Duty Clause inspections • Accident Investigations

  21. What Are We Finding? • Out of about 50 scheduled audits… • Chlorine 45% • Ammonia 35% • Chemicals 20%. • That’s not to say they were all in good shape; it seems municipal water/wastewater plants are among the poorest performers! • Audits in response to accidental releases average: • Chlorine 40% • Ammonia 50% • Chemicals 10%

  22. Facility Siting Implications to RMP • Determine potential receptors • Proactive steps towards mitigation • Provides a forum for communication • Although the Federal Government does not have responsibility for land use planning and zoning, which is strictly a local issue, it will, however, provide information

  23. POTENTIAL RMP BENEFITS • STATES-Establish areas of concern to identify needs and allocate limited resources • COMMUNITIES-Understand local risks and identify vunerable populations to improve community emergency notification and response • FACILITIES-Verify risks to help prioritize prevention and mitigation activities

  24. POTENTIAL INDUSTRY BENEFITS • Operations & Maintenance Employees • Up-to-Date Operating Procedures • Reliable Equipment • Increased Quality Product • Less Unit Downtime • Potential for Greater Profitability • Reduced Insurance Premiums Potential • Improved Community & Gov't Relations • Safer Operation

  25. LOCAL GOVERNMENT/LEPC BENEFITS • Carry out Emergency Planning req'mts • First Responders implement Contingency Plans during chemical accident responses • LEPCs can be a source of RMP information • Can learn about facilities' accident history • LEPCs can work with industry and public to encourage safety, risk reduction and accident prevention

  26. PUBLIC BENEFITS • Increased awareness and understanding of chemical hazards/industry practices • Enter into a dialouge on an informed basis with facility and/or govermental agencies on matters of concern • Opportunity to support actions to ensure public safety and environmental protection • Geographic/Industry Comparative analyses

  27. Concluding Remarks • 1st time for electronic submission • Chemical Safety begins at local level • System developed with input of various stakeholders

  28. Concluding Remarks • Used in combination with other CEPPO tools, e.g., CAMEO, Lanview • RMP*Submit & RMP*Info closes the loop with EPCRA in emergency preparedness & prevention

  29. CONTACTS • Web page Address http://www.epa.gov/ceppo • RMP*Info http://www.epa.gov/enviro • EPCRA Hotline (800) 424-9346 or (800) 535-0202 or (703) 412-9810 • Mikal Shabazz (215) 814-3281 or shabazz.mikal@epamail.epa.gov

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