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The U.S. Government Accountability Office (GAO) released recommendations on February 28, 2022, indicating the EPA should provide more direction to facilities for including climate change risks in their risk management plans (RMPs). Many facilities that manufacture, use, and store hazardous chemicals are regulated by the EPA and are required to have RMPs in place to […]
In response to the EPA’s request for comments on the Risk Management Program (RMP) regulations and related goals, on June 16, 2021, former EPA Administrator and New Jersey Governor Christine Todd Whitman, retired generals Russel Honoré and Randy Manner, former EPA Official Robert Bostock, and former National Security Council and Senate Intelligence Committee staff member […]
Four RMP Documentation Violations to Avoid 1) Failure to include all the required documentation for the alternative release scenarios for the chemical pipe leak and natural gasoline vapor cloud fire as required by 40 CFR 68.39(b). 40 CFR 68.39(b) establishes the offsite consequences analysis documentation requirements for alternative release scenarios that include a description of […]
Recent RMP Settlements Underscore Compliance Pitfalls On September 24 and 29, 2014 the EPA announced settlements with three different companies in two states for violations of to RMP regulations. The first two settlements were at facilities in Idaho, one a corn-based ethanol production facility in Burley and the other a manufacturer of agricultural chemicals in […]
Sector Highlights from the 2013 Greenhouse Gas Reporting Program In 2013 1,572 power plants reported, which is down from 1,589 in 2011 and 1,601 in 2012. This sector consists of facilities that produce electricity by combusting fossil fuels and/or biomass and the emissions from this sector are solely from stationary fuel combustion sources, although carbon […]
How to Qualify for RMP Program Level 1 After determining that a propane storage facility is subject to the RMP regulation, the next step is to identify which program level applies. The U.S. Environmental Protection Agency (EPA) established three program levels that reflect different levels of risk and, subsequently, the level of effort required to […]
