Clean Air Act 112(r) Risk Management Proqram (RMP SPCC/FRP EPCRA January - February 2010 US EPA Region 10 • The Bhopal Tragedy • RMP Update Requirements • Cameo/Tier2/Marplot Updates • SPCC Rule Amendments • RMP Training The Bhopal Tragedy - 25 Years Ago 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 http://yosemite.epa.gov/R10/ airpage.nsf/Enforcement/rmp 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 3 REPORT CHEMICAL or OIL SPILLS to the NATIONAL RESPONSE CENTER 1-800-424-8802 Union Carbide Bhopal Plant One of the worst tragedies in the history of the process industries occurred 25 years ago. A highly toxic gas, Methyl Isocyanate (MIC), was released from a pesticide plant in Bhopal, India shortly after midnight on December 3, 1984. The number of fatalities may never be known, but estimates have been in the range of 2000-4000, with estimated injuries of 100,000 or more people. The International Medical Commission on Bhopal estimated that, as of 1994, more than 50,000 people remained partially or totally disabled as a result of exposure to MIC. Bhopal was a reactive chemistry incident. MIC reacts exothermically with water. A MIC storage tank was contaminated with water, and the reaction generated heat and pressure causing a relief valve to open. Safety systems had been taken out of service without doing a management of change evaluation, or they were unable to deal with the release. Approximately 40 tons of highly toxic MIC was released into the community, exposing tens of thousands of people. Do You Know? • Reactive chemistry incidents continue to occur in the process industries. For example, on September 15, 2009, the US Chemical Safety and Hazard Investigation Board released a report on a runaway chemical reaction incident in Florida which killed 4 people and injured 32 (www.csb.gov). • Material released from a relief valve, rupture disk, or other pressure relief device must discharge to a safe location or treatment system. • Critical safety systems must always be properly maintained and fully operational. What You Can Do • Never become complacent about the hazards in your facility - remember what can go wrong! • More than any other in the history of the chemical industry, this incident demonstrates why robust safety systems are critical when handling hazardous materials. This incident was also one of the driving forces which defined process safety management as we know it today. • Understand the reactivity hazards of all materials in your process. Read the reactivity section of your MSDS's, fully understand all reactivity instructions in your operating procedures and be knowledgeable about why your safety systems (e.g. interlocks, relief devices, scrubbers) are there and how they work. • If a material in your area reacts with water: 1) be cautious when washing equipment for maintenance or whenever a water hose is used, and 2) remember that compressed air may contain condensed water - be sure process air is free of water before blowing lines. continued on page 3 The abandoned Union Carbide Methyl Isocyanate (MIC) plant in Bhopal India ------- Updates of CAMEO, MARPLOT and Tier2 Submit New versions of CAMEO, MARPLOT and Tier2 Submit are now available Download CAMEO 2.1 at http://www.epa.gov/emergencies/content/cameo/ cameo.htm Note: If you're upgrading to CAMEO 2.1 from a previous version of CAMEO, follow the instructions in the guidance document (provided on the download page) to ensure that you don't lose your current data. ffc EiH VHw Ovetlor* Extras Hwng Heb Window Width » 4.53 miles <* c | Map | Satellite j Topo ] llfflLOHH-l | CAMEO ~ | ¦: <> "i o cm mmrm Bnft-Crt i aloha; Red Threat Zone lp pprrV= AEGL-3(60 mm) win- I Kr'in Orange Threat Zone 2 ppm = ALCL-2(6u mm) Constitution Ave NV I'i Hmry 50- N Arlington Btv-. - « . 1 1 Wn Rene Sir g ?::: Washington Yellow Confidence (60^rninK ^ \ Vya^iir^oton Oinnl- Arlington ) \ __ ^ G^nytjesW.asJrfngton-Memo m Arlington Click Point » 38°54t)4*N 77°02'17"W What's changed in CAMEO 2.1? • Added ability to include site plan files in CAMEO export files • Improved interface for adding/ removing site plan files • Updated to ailow import of Tier2 Submit 2009 files • Added support for Google's KML file type • Only for Facilities module • KML file includes facility names, addresses, lat/longs, and 24- hour emergency contact phone numbers (using the data in your Facilities records) • Enlarged window contents to improve readability • For Windows users only • Turn this feature on/off using the Preferences menu item in the Edit menu • Removed demo records • Fixed minor bugs What's changed in MARPLOT 4.1.1 (for Windows)? • Fixed a bug where circle objects weren't printed correctly • Fixed a bug that kept aerial photos of Washington, D.C. from loading for the default Satellite layer • Added population files for the U.S. territories Download the Windows version at http://www.epa.gov/emergencies/ content/cameo/marplot.htm What's changed in MARPLOT 3.3.3.1 (for Macintosh)? • Modified code so that it is compatible with Snow Leopard (OS X 10.6) • Fixed a few minor bugs Download the Macintosh version at http://www.epa.gov/emergencies/ content/cameo/marplot_mac.htm What's changed in Tier2 Submit 2009? • Added ability to view site plans • Updated state-specific fields • Fixed minor bugs Download Tier2 Submit 2009 at http:// www.epa.gov/emergencies/content/ epcraZtier2.htm Page 3 Remember! Tier H Chemical Inventory Annual Reports Due March 1 Facilities covered by Emergency Planning and Community Right-to- KnowAct (EPCRA) requirements must submit an Emergency and Hazardous Chemical Inventory Form to the Local Emergency Planning Committee (LEPC), the State Emergency Response Commission (SERC), and the local fire department annually. Facilities provide either a Tier I or Tier II form. Most States require the Tier II form. Some states have specific requirements in addition to the federal Tier II requirements. Many accept Tier2 Submit. State reporting requirements are available at http://www.epa.gov/emergencies/ content/epcra/tier2.htm#state continued from page 1 The Bhopal Tragedy • Understand the emergency procedures you are to take if the temperature or pressure increases quickly in vessels storing hazardous materials, especially those which are reactive. • Encourage your management and technical group to have a discussion about the "worst case" for the facility you work in and what safeguards have to be maintained to prevent that scenario from occurring. • Understand the "worst case scenario" and "layers of protection" for your facility! Source: Process Safety Beacon 2003 to subscribe: http://www.aiche.org/CCPS/ Publications/Beacon/index.aspx) For more information: RMP Guidance for worst-case scenario ------- EPA Announces Final Amendments to the Oil Spill Preven and Countermeasure On November 5, 2009, the EPA Administrator signed a notice amending certain requirements of the Spill Prevention, Control, and Countermeasure (SPCC) rule in order to address additional areas of regulatory reform that have been raised by the regulated community. This action promulgates revisions to the December 2008 amendments as a result of EPA's review of comments and consideration of all relevant facts. EPA is either taking no action or providing minor technical corrections on the majority of the December 2008 provisions. However, this action modifies the December 2008 rule by removing the provisions to: exclude farms and oil production facilities from the loading/ unloading rack requirements; exempt produced water containers at an oil production facility; and provide alternative qualified facilities eligibility criteria for an oil production facility. Additionally, because of the uncertainty surrounding the final amendments to the December 5, 2008, rule and the delay of the effective date, EPA will propose to extend the compliance date. This rule is effective January 14, 2010. Regulation: Oil Pollution Prevention; Spill Prevention, Control, and Countermeasure Rule - Final Amendments Additional information about the 2009 amendments Risk Management Program (RMP) 2010 Training The Environmental Protection Agency (EPA) is offering FREE Risk Management Program training, providing information about how to comply with the RMP reporting and emergency planning requirements. The instructors are experienced EPA staff with decades of collective RMP compliance assistance and inspection experience. One-day training is being offered on three separate days: March 9,10, or 11, at the HAMMER Training Center, Richland, WA Details and Registration: http://yosemite.epa.gov/R10/airpage.nsf/Enforcement/rmp_training For More Information 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 or TDD (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 htt p ://www.epa .go v/su perf u nd/ 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 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. ------- |