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West Virginia SERC Workshop Charleston, WV August 24, 2017

West Virginia SERC Workshop Charleston, WV August 24, 2017. Overview. Risk Management Program (RMP) Proposed Rule General Duty Clause (GDC) Regional Facilities/Incident Data Current NEI & What To Look For.

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West Virginia SERC Workshop Charleston, WV August 24, 2017

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  1. West Virginia SERC Workshop Charleston, WV August 24, 2017 EPA REGION 3

  2. Overview • Risk Management Program (RMP) • Proposed Rule • General Duty Clause (GDC) • Regional Facilities/Incident Data • Current NEI & What To Look For EPA REGION 3

  3. Risk Management Program 112(r)(7) - 40 CFR Part 68 Facilities Above Threshold Quantity (TQ) EPA REGION 3 3

  4. Rule Summary/Update On June 9, 2017, the EPA Administrator signed a final rule to delay the effective date of the RMP rule amendments for 20 months until February 19, 2019. EPA is conducting a reconsideration proceeding to review objections raised by petitioners to the final RMP amendments rule. This delay of the effective date will allow EPA to complete the reconsideration process and to consider other issues that may benefit from additional comment. EPA REGION 3

  5. Overview of New RMP Provisions EPA REGION 3 5

  6. Information Sharing-LEPC Require summaries of chemical hazard information to be provided to LEPC or local emergency response official, upon request: • Information on RMP regulated substances−names and quantities of regulated substances held in a process • Five-year accident history information (reported under §68.42) • Compliance audits • Incident investigation reports (with root cause findings) • IST implemented or planned to be implemented, if applicable • Exercises, including schedules and reports EPA REGION 3 6

  7. General Duty Clause 112(r)(1) (GDC) 3 Pronged Approach Based on Industry Codes & Standards No Specific Threshold Quantity (TQ) • Designing and maintaining a safe facility to prevent accidental releases • Identify hazards associated with a potential accidental release of an “extremely hazardous substance” using appropriate hazard assessment techniques • Minimizing the consequences of accidental releases that do occur. EPA REGION 3

  8. Industry Codes & Standards EPA REGION 3

  9. EPA REGION 3

  10. Current National Enforcement Initiative (NEI) Ammonia Refrigeration What To Look For EPA REGION 3

  11. Housekeeping as a leading indicator

  12. Corrosion – is it active

  13. Oil Pot No Dead Man Valve Oil Pot Dead Man No Plug

  14. Stavis Seafood-Boston -1 Death -Numerous PSM Violations

  15. Indications of moisture incursion & CUI

  16. Corrosion Steel-Braided Flex hose EPA REGION 3

  17. Mary Hunt-RMP Coordinator R3 (215) 814-3425 Hunt.mary@epa.gov RMP New Rule Info Link: https://www.epa.gov/rmp/final-amendments-risk-management-program-rmp-rule Free webinars: http://rmpcorp.com/events-and-resources/webinars/ EPA REGION 3

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