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


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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.

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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

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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.

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