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AEPA
Publication #550-F98-010
U.S Environmental Protection Agency
Chemical Emergency Preparedness and Prevention Office (CEPPO)
Mail Stop 5104
401 M Street, SW
Washington, DC 20460
(Address label here)
3 S 5
3
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Does This Apply to Me?
What's It All About?
Compliance Tips
Under a new EPA chemical accident
prevention rule, some operators of water
treatment systems will have to implement a
risk management program and Tile a risk
management plan (RMP) with EPA by June
21, 1999. If you handle, store, or use any of
the following above the threshold quantities,
you are likely to be subject to this rule:
Chemical
Threshold Quantity
Chlorine 2,500 pounds
Anhydrous ammonia 10,000 pounds
Aqueous ammonia 20,000 pounds
(concentration 20% or greater)
Chlorine dioxide 1,000 pounds
If you have other chemicals at your facility,
you can get a complete list of substances
regulated under this rule and their thresholds
from EPA, ; ; ; ; -
The risk management program rule (also
known as Clean Air Act section 112(r), the
RMP rule, or part 68) is designed to prevent
serious chemical accidents that could affect
public health and the environment and to
improve the response to any accidents that do
occur.
The rule requires covered facilities to develop
and to implement an integrated system to
identify hazards and manage risks. If you are
subject to this rule, you must analyze worst-
case releases, document a five-year history of
serious accidents, coordinate with local
emergency responders, and file a risk
management plan with EPA. If your worst-
case release could affect the public, you also
must analyze more realistic alternative
scenarios and develop and implement a
prevention program that includes, among
other steps, identification of hazards, written
operating procedures, training, maintenance,
and accident investigation. If your employees
respond to accidental releases, you must
implement an emergency response program.
The RMP you submit to EPA will summarize
your program and will have to be made
available to the public.
The good news is that many water treatment
system operators already are complying with
many of the prevention requirements because
these steps are part of the way you operate
safely. If you are subject to the OS HA
Process Safety Management Standard under
Federal or state law, you are likely to be in
compliance with almost all of the prevention
program requirements and may need to take
no other steps to satisfy this part of EPA's
rule. If you already have an emergency
response plan, you are likely to be in
compliance with that part of EPA's rule as
wejl.
Besides helping you prevent accidents, the
rule can improve the efficiency of your
operation by ensuring that your workers are
trained in proper procedures and by using
preventive maintenance to reduce equipment
breakdowns.
The American Water Works Association
(AWWA) is developing a guidance document
specifically for operators of water treatment
systems that will help you understand the
requirements as they relate to your
operations. The water treatment system
guidance will make compliance less
burdensome by providing industry-specific
information and analyses, ; s^
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