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The CAA’s Chemical Accident Prevention Program requires that any facility that has listed substances above threshold quantities in any single process prepare a Risk Management Plan (RMP). The listed substances contain 77 toxic chemicals with thresholds ranging from 500 pounds (lb) to 20,000 lb and 63 flammable substances with a threshold quantity of 10,000 lb. […]
Chemical Safety Key in EPA Settlement In 2012, the Environmental Protection Agency (EPA) inspected a Fall River, Massachusetts, chemical facility and found numerous “dangerous conditions” related to the company’s use, storage and handling of ammonia and chlorine. Although the chemicals are manufactured for beneficial use in disinfecting drinking water, wastewater, and swimming pools, they can […]
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 […]
National Highlights from the 2013 Greenhouse Gas Reporting Program Mandatory reporting of GHGs became law in October 2009 for sources emitting 25,000 metric tons or more of carbon dioxide equivalent (CO2e) per year in the United States. Reporting began in 2010 and in 2011, the EPA published the first GHGRP report setting a benchmark for […]
Conclusions from the TSCA Assessment of Dichloromethane According to the EPA, the use of products containing DCM for paint stripping poses some of the highest exposure risks compared to all uses of DCM. The chemical is a volatile organic compound (VOC) and is also considered to have “likely carcinogenic properties.” In 2012, 261.5 million pounds […]
Conclusions from the TSCA Trichloroethylene Assessment Each year, the United States uses 225 million pounds of TCE, a volatile organic compound (VOC) and human carcinogen. TCE is used widely, primarily in industrial and commercial processes as a solvent, degreaser, and fixative. EPA’s Office of Pollution Prevention and Toxics (EPA/OPPT) focused the TCE assessment on characterizing […]
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 […]
RMP Applicability for Propane Storage Facilities As early as November 2013, seven states had already declared states of emergency to allow for delivery of more propane, and that was a month before a massive ice storm struck, affecting power for more than 1.5 million people. By the time winter was over, the National Oceanic and […]
Chemical accidents involving ammonium nitrate are rare, but have the potential for significant property destruction, injury and death. Although the Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), and Department of Homeland Security (DHS) all have regulations in place, they apparently are not adequate to prevent accidents or ensure emergency response is prepared. […]