Clean Air Act 1l2frl Risk Manaaement Proaram (RMR
SPCC/FRP
EPCRA
CHEMICAL EMERGENCY PREVENTION & P
May-June 2011
US EPA Region 10
• MARPLOT Update-
2010 Population Data
• Best Practices -
Mechanical Integrity
• Fines: Ammonia release
• RMP E*submit webinar
• RMP Training for 2011
CHEMICAL EMERGENCY
PREVENTION & PLANNING
Newsletter
US EPA Region 10,
ERU ECL-116
1200 6th Avenue, Suite 900
Seattle, Washington 98101
206.553.1255
Fax: 206.553.0124
R10 RMP Webpage
Newsletter Contacts:
For RMP: Javier Morales at
morales.javier@epa.gov
For SPCC/FRP: AK: Matt Carr at
carr.matthew@epa.gov
WA OR ID: Michael Sibley at
sibley.michael@epa.gov
For EPCRA: Suzanne Powers at
powers.suzanne@epa.gov
For free Subscription:
allen.stephanie@epa.gov
CHEMICAL or OIL SPILLS
to the NATIONAL RESPONSE CENTER
1-800-424-8802
Population data from the 2010 Census is now
available for use in MARPLOT
At this time, only the most detailed census level (Census Blocks) has been
released. As other levels (Block Groups, Counties, and Tracts) are released,
we will make them available in MARPLOT. Note that if you download the new
population files at this time, MARPLOT will only use the 2010 data for "get
population" functions where the radius is less than 25 miles (otherwise it uses
different population levels, such as Tracts, which still have 2000 data).
Existing MARPLOT Users: How to Get the New Population Data
If you've used the "Get Population" feature, then you already have one or more
2000 Census, state-level populations files on your computer. (You may have
also downloaded population files using the Download Manager.) These files
can be updated to the new 2010 census data by following these instructions:
1. Start MARPLOT.
2. Under the Help menu, select the "Check for Updates" option.
3. MARPLOT will display a list of basemap layers (primarily census block data)
that are out of date and should be updated. Note that this list is specific to
your version of MARPLOT; the program looks at the files you've already
downloaded and only looks for updates for those files. Click Start Download.
4. Once the download is complete, exit MARPLOT.
5. Browse to the location of your MARPLOT program folder (e.g., C:\Program
FilesWIARPLOT).
6. Double-click on the "reindex.bat" file, which will allow MARPLOT to
recognize the newly-downloaded population files.
7. You can then restart MARPLOT, and the new population data should be
available.
New MARPLOT Users: How to Get the New Population Data
If you are a brand new MARPLOT user, you do not have to update/reindex your
population files at this time.
When you download census block population files (either with the Get
Population feature or using the Download Manager), they will automatically
be the 2010 census files. However, if you download other census levels (e.g.,
Block Groups, Counties, and Tracts) be aware that those files will still be 2000
data, and you may need to update those to 2010 data at a later date, when
they become available.
If you have questions or problems, please contact CAMEO User Support at
(703) 227-7650 or RMPRC@epacdx.net.
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Chemical Emergency Prevention & Planning Newsletter
May-June 2011
Best Practices from the Field
During RMP training and inspections we meet talented people with innovative ideas. Bill Beadle, CIH, describes
the challenges of one element of risk management - Mechanical Integrity. Then he takes us through the steps
required to develop and budget a Mechanical Integrity Program. In the process he addresses "upper management"
concerns, compliance with regulations and following manufacturer guidelines.
Developing and Implementing Good Mechanical Integrity Programs
Author: Bill Beadie, CIH, 2011 Chair of the American Industrial Hygiene Association Risk Assessment Committee (email: bbeadie@maulfoster.com)
Introduction - Risk Management
Includes Mechanical Integrity as
well as the Political Environment
One of the most important
and difficult elements of a
risk management plan is the
mechanical integrity (Ml)
program. Many of the articles and
presentations about Ml programs
focus on the technical aspects of
the regulations, but it's important
to recognize that lack of technical
expertise is not always the
primary barrier to a good program.
Potentially good plans can be
thwarted by any combination
of technical, economic, and
political factors. Identifying these
challenges as soon as possible
provides the greatest hope for
developing an effective program.
Although this article is written
with the ammonia refrigeration
industry in mind, these concepts
and principles should apply to all
hazardous-chemical processes.
Part 1—Overview of Technical Ml
Requirements
There are many places to learn
about all the technical aspects of
the Ml requirements, starting with
the regulations (yes, you can learn
a lot by reading the regulations!)
and continuing with EPA/OSHA
guidance documents, compliance
directives, official letters of
interpretations, etc. Given the
amount of high-quality information
that is freely available on this
subject, I will spare you all the
details and give a simple overview.
This is not a complete description
of the requirements...for which I
assume you are thankful.
Ml regulations require facilities to
have a good maintenance program
for all the equipment involved in
a hazardous-chemical process.
Facilities must:
1. Identify all of the equipment
involved in the chemical
process.
2. Develop and implement written
procedures for maintaining the
equipment.
3. Train each employee who is
involved in maintaining the
equipment.
4. Inspect and test all of the
equipment in accordance
with manufacturers'
recommendations, industry
standards, and company
experience.
5. Fix broken or deficient
equipment in a safe and timely
manner.
6. Implement a quality assurance
process to ensure that work is
done properly and materials are
appropriate.
At first glance this may seem
relatively easy. It isn't. In reality,
despite dramatic improvements
in the last ten years, very few
ammonia refrigeration facilities
have maintained compliant Ml
programs.
Part 2—Three Common Barriers
to a Good Ml Program
There are several reasons why
facilities may lack a good Ml
program, and some problems
stem from less obvious underlying
factors. Common challenges
include:
1) Lack of knowledge / expertise
This is a broad category that
includes lack of knowledge about
regulatory requirements, lack of
technical information about the
equipment, or lack of general
maintenance expertise. Most
workshops and sessions on Ml
tend to assume that this is the
sole or primary barrier to a good
Ml program, and therefore try to
fill your brain with increasingly
detailed information about rules,
regulations, and checklists. In
some cases this works. More
often, however, lack of knowledge
/ expertise is a symptom of a larger
problem, such as barrier number 2.
2) Lack of management support
While this may simply be lack
of management knowledge /
expertise, it deserves its own
category. People in upper
management don't routinely
attend workshops or read articles
about Ml, so most technical
sessions don't help the industry
overcome this problem. The lack
of management support may be
based on a lack of compelling
reasons to provide more support. If
no one in the company can clearly
describe the requirements and
justify the necessary resources,
why would upper management
feel compelled to dedicate a lot of
time and energy to Ml? There are
several excuses for inadequate
management support, such as
barrier numbers.
3) Lack of resources
Obviously, resources include
money and time. Even if a company
continued on page 3 J
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Chemical Emergency Prevention & Planning Newsletter
May-June 2011
Best Practices from the Field (continuedfrom page 2)
knows all the requirements, they may
have a terrible Ml program because
there are never dollars earmarked
to conduct necessary inspections or
make the repairs. Of course, some
may argue that lack of resources is a
direct result of barrier number 2. Ml isn't
supported by management because
there are insufficient resources, and
there are insufficient resources because
management doesn't support Ml.
Whatever the cause, there is still risk!
Part 3—Expect to Overcome
Challenges
The good news is that facilities can
overcome challenges and develop a
good Ml program. The specific strategy
depends on the situation, but one or
more of the following steps can help a
company get on the right path:
1) Get educated.
I put this first on the list because it is
probably the most defined and simple
step. If your facility lacks knowledge and
expertise about Ml, there are a whole
host of resources available. Many of
them are free! However, this may require
a significant investment in time.
People in charge of managing the
Ml program should become familiar
with the regulations and spend a
significant amount of time compiling
equipment information, manufacturer's
recommendations and industry
standards.
2) Make a specific plan and put it in
writing.
It's easy to write general, meaningless
statements that sound important,
e.g., "Company X will comply with
all applicable regulations and
industry standards to ensure the safe
maintenance and operation of process equipment."
This rarely leads to a good program.
On the other hand, consider the following process,
which is illustrated for an ammonia condenser in
Example 1:
a) Make a detailed list of all process equipment
included in the Ml program.
b) For each piece of equipment, document the
Example 1 Maintenance Recommended Free
Equipment
Number Description
Evaporative
QFEC100 Condenser
Maintenance Task
Clean water filter
Check external condition
Check water conditions
Check bleed-off
Check for proper purging
Clean and drain pan
Check water distribution system
and spray pattern
Check water level and adjust
Check and adjust belts and
inspect fans
Check drift eliminators
Check fan blades for cracks
Lubricate fan motor
Inspect and grease sliding motor
base
Inspect fan motors and guards
Inspect coils
Inspect shaft and shaft bearings
Bulletin 109- Evap. Condenser
Checklist
Independent inspection
uency
Manufacturer
Monthly
Annually
Monthly
Quarterly
Monthly
Monthly
Monthly
Quarterly
Quarterly
Quarterly
Annually
2-3 years
MAR
Weekly
Weekly
Weekly
Weekly
Monthly
Monthly
Monthly
6-month
Annually
Annually
Annually
Company
Weekly
Weekly
Weekly
Weekly
Weekly
Quarterly
Monthly
Monthly
Monthly
Quarterly
6- month
Quarterly
Annually
6- month
Annually
Annually
Annually
5-year
Notes
Weekly inspection, but annual
cleaning
Manual says quarterly or "as
needed."
Manufacturer wrote e-mail
stating it would be acceptable
to perform this inspection as
part of the 6-month inspection.
Example 2 Condenser PM
Person Performing Work:
Employer of Person Performing
Work:
Required Frequency: Annually
Equipment #
EC100
Task
Did you clean water filter 1?
Did you clean water filter 2?
Did you clean and drain pan?
Did you check water level and adjust,
if necessary (water level should be
up to the float)
Did you inspect the heat transfer
section?
Nozzels spraying freely?
Belt tension appropriate?
Is the bleed rate set at 100-200 ppm?
Fan free of unusual noise or
vibration?
Fan blades intact?
Fan rotates freely?
Belts free of excessive cracking and
wear?
Belt tension appropriate?
Motor securely mounted?
Motor free of unusual noise or
vibration?
Exterior of motor in good condition?
Motor plate data legible?
Electrical connections sound and
intact?
Shaft does not have excessive play?
Guards OK?
Did you grease the fan shaft
bearings?
Did you complete the Bulletin 109
checklist?
Y/N
Notes
Follow-up
manufacturer's recommendations for inspection
and maintenance.
c) Similarly document the generally accepted good
engineering practices for each piece of equipment
(e.g., ammonia refrigeration facilities can include
recommendations from MAR Bulletin 110).
d) List recommendations from facility maintenance
personnel.
continued on page 4 i
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Chemical Emergency Prevention & Planning Newsletter
May-June 2011
Best Practices from the Field (continuedfrom page 3)
Example 3.
Equipment ID
e) Finally, if the company thinks
it's important to deviate from a
manufacturer's recommendation listed in
an equipment manual, get documentation
from the manufacturer that an alternative
is acceptable.
Once the list of recommended inspections
is complete, the facility can develop
checklists to track compliance with the Ml
program. Ideally, these tasks are tracked
electronically with a database and work
orders, but there are still many companies
that use paper checklists. Example 2
illustrates an annual maintenance checklist
for an ammonia condenser. Note that
this example consolidates all of the more
frequent tasks on the annual checklist
to minimize paperwork. In other words,
the weekly, monthly, and quarterly tasks
are added to the annual checklist so the
technician doesn't have to remember to
grab four checklists. This concept works for
an electronic database as well as a paper-
based system.
The process of identifying appropriate
maintenance schedules and developing
tools to track planned maintenance may
take several weeks. It is essential for a
compliant Ml program.
3) Communicate clearly with upper
management.
I strongly recommend having a clear
message if you expect to get management
support for Ml. Lay out the requirements
in simple terms and identify the resources
necessary to achieve your goals. This
will be impossible if you haven't educated
yourself and identified the specific tasks
necessary to implement your Ml program.
If you made a specific plan with all scheduled
maintenance tasks, you can put time and budget
estimates next to each job. Example 3 illustrates this
process for the annual maintenance of an ammonia
condenser. Note that several of the tasks on the
annual maintenance checklists are also included in the
weekly, monthly, and semiannual inspections, so this
process actually takes less time than you might expect.
Although your estimates may not be perfect on the
first try, they can be very powerful tools to justify the
resources needed to implement a program. Consider
the following message:
"The law requires us to follow recommended
Estimated Time and Budget for Annual Condenser Preventative Maintenance
#EC100
Task
Did you clean water filter 1?
Did you clean water filter 2?
Did you clean and drain pan?
Did you check water level and
adjust, if necessary (water
level should be up to the float)
Did you inspect the heat
transfer section?
Ensure nozzles spraying
freely?
Belt tension appropriate?
Is the bleed rate set at 100-200
ppm?
Fan free of unusual noise or
vibration?
Fan blades intact?
Fan rotates freely?
Belts free of excessive cracking
and wear?
Belt tension appropriate?
Motor securely mounted?
Motor free of unusual noise or
vibration?
Exterior of motor in good
condition?
Motor plate data legible?
Electrical connections sound
and intact?
Shaft does not have excessive
play?
Guards OK?
Did you grease the fan shaft
bearings?
Did you complete the Bulletin
109 checklist?
Logistics, mobilization, etc
(Includes LOTO and confined
space reclassification
procedure)
Total
Estimated
Personnel Time
(hours)
0.25
0.25
1
0.5
0.15
1.5
0.1
0.05
0.05
0.05
0.05
0.1
0.05
0.05
0.05
0.05
0.05
0.1
0.1
0.05
0.25
0.5
1
6.3
Estimated
Budget
(Materials)
$1.00
$1.00
Notes
Estimated service life and annual
costs provided separately.
Estimated service life and annual
costs provided separately.
Estimated service life and annual
costs provided separately.
Estimated service life and annual
costs provided separately.
Estimated service life and annual
costs provided separately.
Estimated service life and annual
costs provided separately.
Estimated service life and
annual costs provided separately.
maintenance schedules. The following report shows
that all of the recommended maintenance requires X
hours per year and a budget of X dollars. Our current
staff can perform Y hours per year on the current
budget of Y dollars. I'm requesting an adjustment to
ensure that we can comply with the requirements."
Similarly, if there is an expansion or staff cutbacks, you
can clearly demonstrate its impact on the Ml program.
If your facility lacks a fully compliant Ml program, I
strongly recommend that you look at what is holding
you back and develop a plan for compliance. And don't
be discouraged if it takes time! Good Ml programs are
not developed overnight.
Page 4
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Chemical Emergency Prevention & Planning Newsletter
May-June 2011
Spokane Cold Storage Company Fined
for Ammonia Release
(Seattle - March 28, 2011) Empire
Cold Storage, a Spokane cold storage
warehouse and packaged ice producer,
will pay the U.S. Environmental Protection
Agency $67,142 for its failure to report
an estimated 400 pounds of anhydrous
ammonia release at their Spokane facility.
On July 14, 2007, the Empire facility
released approximately 400 pounds
of ammonia into the environment at its
facility located at 1327 N. Oak Street
Spokane, Washington according to
the EPA settlement. Empire uses large
quantities of anhydrous ammonia at the
facility as a refrigerant.
"When toxic gases like ammonia get
released, prompt reporting can save
lives," said Edward Kowalski, Director
of EPA's Office of Compliance and
Enforcement in Seattle. "These cases
are about protecting workers, emergency
responders and the community."
The leak occurred when a failed pressure
gauge caused a release of anhydrous
ammonia that lasted up to three hours.
EPA alleges that Empire then failed
to immediately notify local and state
agencies about the release. While no
injuries were reported at the time of the
accident, ammonia is a pungent, toxic gas
that attacks skin, eyes, throat, and lungs
and can cause serious injury and death.
The ammonia release and the failure
to notify appropriate agencies are
violations of the federal Comprehensive
Environmental Response, Compensation
and Liability Act (CERCLA) and the
Emergency Planning and Community
Right-to-Know Act (EPCRA).
For information on EPA's Emergency
Planning and Community Right to Know
Act, visit http://www.epa.gov/compliance/
civil/epcra/epcraenfstatreq.html
Contact:
Suzanne Powers, EPA Emergency
Response Program, (360) 753-9475,
powers.suzanne@epa.gov
Tony Brown, EPA Public Affairs, (206)
553-1203, brown.anthony@epa.gov
RMP*eSubmit
Internet Webinars
For those not familiar with
RMP*eSubmit, EPA periodically
holds internet Webinars on the
RMP*eSubmit system. Please
check back here occasionally
for announcements on future
Webinars and registration
information. The eSubmit
webinars fill quickly.
RMP*eSubmit allows facilities
to submit, correct, and access
their RMPs online, 24 hours
a day, 7 days a week. EPA
requests that all facilities use
this new method to submit
RMPs because it is easy to use
and will improve data quality.
Plan to attend the FREE EPA Risk
Management Training Day in your area
RISK
MANAGEMENT
PROGRAM
(RMP) Training
Boise, Idaho - May 16, 2011
Seattle, Washington - November 16, 2011
Additional information can be found on
EPA Region 10's RMP Website: Training Information
Where Do I Go For
More Information?
http://wwvv.epa.goy/emergencies/
rmp will be updated as new
information becomes available.
EPA maintains numerous listservs
to keep the public, state and local
officials, and industry up to date,
including several that pertain to
emergency management. You
can sign up for our list serve
to receive periodic updates:
https://lists.epa.gov/read/all_forums/
subscribeVname=callcenter_oswer
EPA Region 10 RMP Coordinator:
Javier Morales 206-553-1255
EPA Region 10 RMP Website:
http://yosemite.epa.gov/R10/
CLbAN U K NSh-/sites/rmp~
Superfund, TRI, EPCRA, RMP
& Oil Information Center - The
Information Center can also
answer questions related to
Clean Air Act section 112(r) and
RMP reporting requirements.
(800) 424-9346 or TDD
(800) 553-7672
(703) 412-9810 orTDD (703) 412-
3323 in the Washington, D.C. area
Normal Hours of Operation:
Monday - Thursday 10:00 a.m.
- 3:00 p.m. Eastern Time
Extended Hours of Operation
(May, June, and July):
Monday - Friday 9:00 a.m. -
5:00 p.m. Eastern Time
Closed Federal Holidays
http://www.epa.gov/superfund/
contacts/infocenter/
Risk Management Program (RMP)
Reporting Center - The Reporting
Center can answer questions about
software or installation problems.
The RMP Reporting Center
is available from 8:00 a.m. to
4:30 p.m., Monday through
Friday, for questions on the Risk
Management Plan program.
(703) 227-7650 (phone)
RMPRC@epa.cdx.net (e-mail)
This newsletter provides information
on the EPA Risk Management
Program, EPCRA, SPCC/FRP and
other issues relating to Accidental
Release Prevention Requirements.
The articles contained herein are
provided for general purposes only.
EPA does not accept responsibility
for any errors or omissions or
results of any actions based upon
this information. Please consult
the applicable regulations when
determining compliance. Mention of
trade names, products, or services
does not convey, and should not
be interpreted as conveying official
EPA approval, endorsement, or
recommendation. The information
should be used as a reference
tool, not as a definitive source of
compliance information. Compliance
regulations are published in 40 CFR
Part 68 for CAA section 112(r) Risk
Management Program, 40 CFR
Part 355/370 for EPCRA, and 40
CFR Part 112.2 for SPCC/FRP.
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