Clean Air Act 112(r) Risk Management Program (RMP'
SPCC/FRP
EPCRA
March - April 2010
US EPA Region 10
•	Managing Chemical
Reactivity Hazards
•	Fines
•	5-year eSubmit
Webinar
•	Harry Bell Retires
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 ://yosem ite. epa. gov/R 10/
airpage.nsf/Enforcement/rmp
Newsletter Contacts:
For RMP: Javier Morales at
morales.javier@epa.gov
For SPCC/FRP: AK: Matt Carr at
carr.rmatthew@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
©REPORTll
CHEMICAL or OIL SPILLS
to the NATIONAL RESPONSE CENTER
1-800-424-8802
Georgia Pacific after the September 10, 1997 plant explosion.
Managing Chemical Reactivity Hazards
Many materials used in industrial
facilities can pose chemical
reactivity hazards. Conventional
management systems frequently do
not adequately address the unique
behavior of materials that may react
to cause excessive temperature
or pressure excursions or toxic or
corrosive emissions.
The consequences of a reactive
chemical incident can be severe.
In a 2002 study, the U.S. Chemical
Safety Board (CSB) collected
detailed information on 167 serious
incidents that occurred between
1980 and 2001, EPA reviewed
CSB's information and identified
the most commonly reported
management deficiencies. In
order of frequency, the reported
management deficiencies are:
•	Operating Procedures, Safe
Operating Limits and Training *
•	Hazard Identification and
Evaluation *
•	Human Factors
•	Management of Change *
•	Emergency Relief Equipment and
Controls *
•	Process Design
•	Process Knowledge
•	Incident Investigation *
•	Process Hazard Analysis *
•	Safety Auditing
•	Equipment Maintenance *
•	Key Risk Management Program Prevention
Program elements,
continued on page 3
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Chemical Emergency Prevention & Planning Newsletter
March - April 2010
Harry Bell Retires
Harry Bell has been an inspector in EPA's Risk Management
Program (RMP) since its inception in June, 1999. He received a
Ph. D. in analytical chemistry and has had 25 years experience in
the drinking water, industrial and sanitary wastewater treatment
fields. To realize his personal commitment to protecting the health
of communities in EPA's Region 10, Harry has worked with industry
on operating safe facilities, conducting inspections, and providing
compliance assistance and training.
Harry's significant contributions to EPA is highlighted by his training
on the 2009 release of RMP*eSubmit at the annual RMP Training
conducted at the HAMMER facility. Harry's professionalism, technical
skills and experience will be greatly missed. His friends at EPA wish
him the best in the next phase of his life.
RMP*eSubmit Webinars
In March 2009, EPA provided
new Web-based software called
RMP*eSubmit for facilities to use
for online Risk Management Plan
(RMP) reporting. RMP*eSubmit
allows facilities to submit, correct,
and access their RMPs online, 24
hours a day, 7 days a week. EPA
asks that all facilities use this new
method to submit RMPs because
it is easy to use and will improve
data quality.
For those not familiar with
RMP'eSubmit, EPA will hold a
Webinar during which we will
explain how to submit an RMP
using the new software. There will
be time for questions and answers
during the Webinar.
Future Webinars for
RMP*eSubmit are scheduled in
April, June, August, and then
quarterly/as needed.
Registration is required for the
Webinar. We have limited lines
available, so registration will
be on a first come / first serve
basis. Register online via http://
www.epa.gov/emergencies/ Find
webinar details under "Highlights".
Once registered, you will receive
a confirmation e-mail with
instructions on how to sign into
the Webinar.
Where Do I Go For More Information?
http://www.epa.gov/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/subscribe?name=callcenter_oswer
EPA Region 10 RMP Coordinator:
Javier Morales 206-553-1255
EPA Region 10 RMP Website:
http://yosemite.epa.gov/R10/CLEANUP.NSF/sites/rmp
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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Chemical Emergency Prevention & Planning Newsletter
March - April 2010
Managing Chemical Reactivity Hazards
continued from Page 1
Process Safety
Information
Risk Management Program
facilities are required to address
this potential hazard several ways.
Process safety information should
provide at least the following:
•	Toxicity information
•	Permissible exposure limits
•	Physical data
•	Reactivity data
•	Corrosivity data
•	Thermal and chemical stability
data; and
•	Hazardous effects of inadvertent
mixing of different materials that
could foreseeably occur
Material Safety Data Sheets
meeting the requirements of
29 CFR 1910.1200(g) (OSHA)
may be used to comply with this
requirement to the extent they
contain the information required
above [40 CFR 68.65(b)]. Read
MSDS forms carefully as the
information varies depending on
the source with some reactivity
information missing.
The NIOSH pocket guide is an
excellent source for chemical
reactivity and can be accessed
online. Other sites include OSHA
chemical reactivity site; Office of
Emergency Management (OEM),
and CAMEO chemical reactive
hazard. See sidebar for links to
these resources.
EPA Alert
Phenol-formaldehyde Reactions
Phenol-formaldehyde reactions
are common industrial processes
found throughout EPA Region 10.
The reaction of phenol with an
aldehyde, such as formaldehyde,
in the presence of an acidic or
basic catalyst is used to prepare
phenolic resins. Phenolic resins
are used in adhesives, coatings,
and molding compounds. The
type of catalyst used, the ratio
of reactants, and the reaction
conditions determine the
molecular structure and physical
properties of the resin produced.
Typically, phenol-formaldehyde
reactions are highly exothermic
and sensitive to a variety of
physical and chemical conditions.
Once a reaction is initiated,
heat generated by the reaction
increases the reaction rate
generating more heat.
Case Study
Columbus, Ohio Sept. 10, 1997
At approximately 10:42 a.m., an
explosion occurred in a resins
production unit at Georgia-Pacific
Resins, Inc. in Columbus, Ohio.
The blast was reported to be felt
at least 2 miles and possibly as
far as 7 miles away according
to various news accounts and
other reports. As a result of the
explosion, one worker was killed
and four others injured. The
explosion extensively damaged
the plant. (Read more)
Resources:
NIOSH Guide
Chemical Reactivity Worksheet
(CRW) sponsored by NOAA
OSHA Chemical Data Base
Georgia Pacific after the September 10, 1997 plant explosion.
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Chemical Emergency Prevention & Planning Newsletter
March - April 2010
Ocean Protein LLC Pays nearly $22,000 for Failure to Properly
Report Hazardous Chemicals
Ocean Protein, LLC has settled
with the Environmental Protection
Agency and agreed to pay a
$13,166.00 penalty for violating
the federal Emergency Planning
and Community Right-to-Know
Act (EPORA). The company failed
to properly report the storage
of Sulfuric Acid at its fish waste
processing facility located in
Hoquiam, Wash.
Ocean Protein failed to file
Emergency and Hazardous
Chemical Inventory Forms with
local emergency response
entities in Washington. Located in
Hoquiam, Wash., Ocean Protein
The City of St. Maries, Idaho has
agreed to pay $9,220 penalty and
spend an estimated $113,550 to
settle a case for violations of the
U.S. Environmental Protection
Agency's policies on emergency
prevention requirements. Region
10 settled with the City of St.
Maries for violations of the
Clean Air Act (CAA) § 112(r)
risk management program
requirements at its wastewater
treatment plant in St. Maries,
Idaho. The violations have since
been corrected by St. Maries.
The settlement came after
EPA found that the city lacked
an emergency prevention
program to protect the public
and the environment from an
off-site release of chlorine at
its wastewater treatment plant.
EPA's Risk Management Program
is designed to protect public
health and the environment from
produces fish meal, fish oil, and
bone meal from fish wastes
using sulfuric acid, among other
chemicals.
In addition to the penalty, Ocean
Protein agreed to provide over
$8,800 for training and equipment
to the City of Hoquiam Fire
Department that will improve
the department's capabilities
in responding to hazardous
materials emergencies in a safe
and effective manner.
Facilities that store significant
quantities of certain hazardous
chemicals are required to
accidental releases of harmful
chemicals.
As part of the settlement, the city
will spend an estimated $113,550
to implement the following
Supplemental Environmental
Projects. St. Maries will purchase
and install the following:
•	Treated wastewater flow
monitoring system;
•	Chlorine analyzer and flow
proportional chlorinator;
•	Chlorine scale monitoring
system; and
•	Enhanced leak detection and
notification system.
These projects will provide added
protection to the community and
improve the efficiency of the
wastewater treatment process,
thereby reducing the impact of the
wastewater treatment plant on the
environment.
submit an inventory of each
chemical to the State Emergency
Response Commission, the Local
Emergency Planning Committee,
and the local fire department.
Emergency responders rely on
this information for their safety
and to help protect nearby
residents during an emergency,
such as a fire or earthquake.
Citizens can also access the
information to find out what
chemicals are being stored and
used in their neighborhoods.
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
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)
St. Maries, Idaho Agrees to spend over
$122,000 to settle EPA Risk Management
Program Violations
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