Clean Air Act 112(r) Risk Management Program (RMP
SPCC/FRP
EPCRA
® CHEMICAL EMERGENCY PREVENTION & PUtMNG
November-December 2009
US EPA Region 10
iodide *7fad
•	Managing Change
•	EPCRA Fine
•	RMP Training
Announcement
•	Food Processing
Compliance Assistance
Center
•	RMP: De-registration
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:
ailen.stephanie@epa.gov
$ REPORT
CHEMICAL or OIL SPILLS
to the NATIONAL RESPONSE CENTER
1-800-424-8802
Managing Change -
The Chemical Safety Board (CSB) urges organizations to review their Management of
Change (MOC) policy to be sure it covers operational variances in addition to physical
changes. If your organization doesn't have a systematic method for handling changes,
develop and implement one.
To maximize the effectiveness of your MOC system, the CSB suggests that the
following activities be included:
Define safe limits for process conditions,
variables and activities — and train
personnel to recognize significant
changes. Combined with knowledge of
established operating procedures, this
additional training will enable personnel
to activate the MOC system when
appropriate.
Apply multidisciplinary and specialized
expertise when analyzing deviations.
Use appropriate hazard analysis
techniques.
Authorize changes at a level
commensurate with risks and hazards.
Communicate the essential elements of
new operating procedures in writing.
Communicate potential hazards and
safe operating limits in writing.
Provide training in new procedures
commensurate with their complexity.
Conduct periodic audits to determine if
the program is effective.
Managing Change - Case Study
The following case study from the
Chemical Safety Board (CSB 2001)
illustrates the importance of having a
systematic method for the management
of change. An MOC should be applied
to operational variances in addition to
physical alterations.
Equilon Enterprises,
Anacortes, Washington
On November 25, 1998, a fire at the
Equilon Enterprises oil refinery delayed
coking unit in Anacortes, Washington,
caused six fatalities. A loss of electric
power and steam supply approximately
37 hours prior to the fire had resulted in
abnormal process conditions.
(Read the full story at: http://www.csb.
gov/assets/document/moc082801 .pdf)
Managing Change - Risk Management Program Standards
Management of Change/ Pre-startup
Safety Review
For existing processes that have been
shutdown for turnaround, or modification,
etc., the employer must assure that
any changes other than "replacement
in kind" made to the process during
shutdown go through the management
of change procedures. P&IDs will need
to be updated as necessary, as well as
operating procedures and instructions. If
the changes made to the process during
shutdown are significant and impact
the training program, then operating
personnel as well as employees engaged
in routine and nonroutine work in the
process area may need some refresher
or additional training in light of the
changes. Any incident investigation
recommendations, compliance audits
or PHA recommendations need to be
reviewed as well to see what impacts they
may have on the process before beginning
the startup.
Management of Change Requirements
(Program Level 3)
MOC procedures must address:
•	Technical basis for the change.
•	Impact on safety and health.^
•	Modifications to operating procedures.
•	Necessary time period for the change.
•	Authorization requirements for proposed
change.
continued on page 2
Page 1

-------
continued from pagel
Managing Change - Risk Management Program Standards
RMP/PSM Requirements for
Management of Change
MOC procedures must address:
•	Technical basis for the change
•	Impact on safety and health
•	Modifications to operating
procedures
•	Necessary time period for the
change
•	Authorization requirements for
proposed change
•	Affected employees must be
informed and trained before
startup
•	Update process safety information
if affected by the change
•	Update operating procedures if
affected by the change
Employees affected by the change
must:
•	Be informed of the change before
startup.
•	Trained in the change before
startup.
Update process safety information if:
•	A change covered by MOC
procedures results in a change in
any PSI required under EPA's rule
(see § 67.65).
Update operating procedures if:
•	A change covered by MOC
procedures results in a change in
any operating procedure required
under EPA's rule (see § 67.69).
Source: General Guidance on Risk Management Programs
for Chemical Accident Prevention (40 CFR Part 68). EPA-
550-B-04-001 April 2004
Pre-Startup Safety Review
For new and significantly modified
processes, the employer will find the
PHA helpful in improving the design
and construction of the process from
a reliability and quality point of view.
The safe operation of the new process
will be enhanced by making use of
the PHA recommendations before
final installations are completed.
P&IDs are to be completed along with
having the operating procedures in
place and the operating staff trained
to run the process before startup. The
initial startup procedures and normal
operating procedures need to be fully
evaluated as part of the pre-startup
review to assure a safe transfer into
the normal operating mode for meeting
the process parameters.
Interrelationship of Process Safety
Management (PSM)Elements
An essential part of verifying program
implementation is to audit the flow
of information and activities among
the Process Safety Management
elements. When information in one
element is changed or when action
takes place in one element that affects
other elements, the Safety Compliance
Officers or Health Compliance Officers
(SCO/HCO) shall review a sample
of the related elements to see if the
appropriate changes and followup
actions have taken place.
The following example demonstrates
the interrelationship among the
elements:
During a routine inspection of
equipment (Mechanical Integrity), the
maintenance worker discovers a valve
that no longer meets the applicable
code and must be changed. Because
the type of valve is no longer made,
a different type of valve must be
selected and installed (Management
of Change). The type of valve selected
may mandate different steps for the
operators (Operating Procedures) who
will require training and verification in
the new procedures (Training). The
rationale for selecting the type of valve
must be made available for review by
employees and their representatives
(Employee Participation).
When the new valve is installed by the
supplier (Contractors), it will involve
shutting down part of the process
(Pre-startup Safety Review) as well as
brazing some of the lines (Hot Work
Permit). The employer must review the
response plan (Emergency Planning)
to ensure that procedures are
adequate for the installation hazards.
Although Management of Change
provisions cover interim changes, after
the new valve is in place the Process
Safety Information will have to be
updated before the Process Hazard
Analysis is updated or revalidated,
to account for potential hazards
associated with the new equipment.
Also, inspection and maintenance
procedures and training will need to be
updated (Mechanical Integrity).
In summary, 11 PSM elements can
be affected by changing one valve. A
Health and Safety Compliance Officer
would check a representative number
of these 11 elements to confirm that
the required followup activities have
been implemented for the new valve.
Source: Process Safety Management of Highly Hazardous
Chemicals, Oregon Occupational Safety and Health Division
Department of Consumer and Business Services, Program
Directive A-177, Issued April 5, 1993, Revised August 15, 2000.
Page 2

-------
EPCRA Fine
Aircraft Equipment Manufacturer in Kent, Washington Will Pay Over
$12,000 for Failing to Report Dangerous Chemicals
Company will provide $50,000 for an emergency notification system to the City of Kent for two years as part of
settlement with EPA
(Seattle, Wash. August 2009) GKN
Aerospace Chemtronics, an aircraft
parts manufacturer in Kent, Wash.,
failed to properly report its use and
storage of hazardous chemicals to
EPA, state and local agencies, alleged
a consent agreement and final order
issued by the Environmental Protection
Agency. The actions violated the
Emergency Planning and Community
Right-to-Know Act.
"It's critical that companies report
the storage and release of toxic
chemicals—if they don't, public safety
is jeopardized in an emergency," said
Edward Kowalski, EPA's Director of the
Office of Compliance and Enforcement
in Seattle. "Companies need to
minimize public risk from hazardous
chemicals by following the law."
EPA alleges that in 2006, GKN failed to
report its releases, waste management
activities and transfers of nitric acid, a
dangerous substance that can cause
severe burns and explosions, to the
Toxic Release Inventory. GKN used
approximately 12,000 pounds of nitric
acid in 2006, exceeding the Toxic
Release Inventory reporting threshold
of 1,000 pounds, according to EPA's
order.
In addition, EPA alleges that in 2007
the company stored approximately
8,000 pounds of hydrofluoric acid
and 34,000 pounds of nitric acid,
but did not report this storage to the
appropriate government agencies.
The threshold for reporting storage
of hydrofluoric acid, an extremely
hazardous substance that can cause
severe burns, is 100 pounds.
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.
The company will pay a fine over
$12,000, and has agreed as part of
the settlement to perform a two-year
project worth $50,000. It will provide
the City of Kent with an emergency
telephone notification system that
can quickly warn the public in the
event of a chemical release or other
emergency.
Contact: Suzanne Powers,
EPA Office of Environmental Cleanup,
(360) 753-9475
RMP
Training
Announcement
March 9,10 & 11, 2010
Richland, Washington
The Environmental Protection
Agency (EPA) is offering
FREE RISK Management
Program training, which will
provide information about how to
comply with the RMP reporting and
emergency planning requirements.
This is a one-day training, offered three
times.
Details of training and registration will appear on the EPA Region 10 RMP
webpage.
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
Page 3

-------
Food Processing Compliance Assistance Center
Food processors now have access to an all-encompassing source of
environmental regulatory, pollution prevention and sustainability information.
Home
Meat
Poultry
Seafood
fruits
Vegctf
Dairy
Eggs
Sustainability
Regulations
About
Contact Us
Welcome to FPEAC
The Food Processinq Environmental Assistance Center is committed
to developing and promoting innovative strategies that achieve
better environmental results, reduce costs, and promote
environmental stewardship throughout the rood Processing Industry.
The goal of the center is to become a primary provider of
environmental information, resources, and training to assist small
and medium sized food processors in achieving environmental
compliance and stewardship.
The U.S. food processing sector, as with other industnal and
commercial sectors, faces increasingly stringent environmental rules,
many nf which have their mots in federal statutes and are
implemented through stote laws and regulations by various agencies.
Most of these rules relate to the treatment and disposal of food
processing wastes, often, permitting, monitoring, reporting and
other regulatory requirements are implemented by multiple aqencies
(e.g., composting operations may be regulated by the environmental
protection agency, department of health and department of agriculture).
Food Science
Purdue University
Supported on
Sotim # fanp&nw
COMPLIANCE
ASSISTANCE
vNct r%
p
Industry News
Search FPFAC:
Goi ¦glu
O The Web
0 I his bite
The National Food Processing Environmental Assistance Center (FPEAC)
is now available to food processors and to the public at http://www.fpeac.org
FPEAC is sponsored by the US EPA and created by Purdue University. The
Center contains federal and state regulations and publications aimed at helping
processors address environmental issues related to their businesses.
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.
RMP: De-Registering
Changes may occur at your facility
that make it no longer subject to the
RMP regulations at 40 CFR 68 (e.g.
you replace the regulated substances
in your process with unregulated
substances or reduce the inventory
below the threshold amount.) In that
event, you should submit a letter to
the RMP Reporting Center within
six months and include the effective
date of the de-registration (the date
on which you facility was no longer
covered by the RMP regulation). The
letter should be signed by the owner or
operator and include your RMP Facility
ID number (the 12-digit ID number
assigned by EPA).
You can print a de-registration
form, RMP*eSubmit Users' Manual
Appendix E (PDF) (44 pp, 403K). For
more detailed information see the
RMP*eSubmit Users' Manual Chapter
5 (PDF) (121 pp, 2.7MB).
Page 4
Remember to include the 12-digit
EPA Facility Identification number
(usually beginning with 1000) that
was assigned to your facility. The EPA
Facility ID was given to you in the
notification letter you received from the
RMP Reporting Center regarding the
submission status of your RMP. You
should keep a record of your Facility ID
number upon de-registering.
• 08/31/09 Wal-Mart to develop a global
sustainability index
BENTONVILLE, ARK. I Wal-Mart Stores, Inc.
announced it is developing a global sustainable
product index that will establish a single source of
data tor evaluating the sustainability of consumer
goods products.
• ub/Jl/uy Lap-and-trade concept takes center
stage
The Senate Committee on Agriculture, Nutrition and Forestry plunged into the climate
change debate taking testimony from administration officials and representatives of farm
uiydiiizdLiuiib during a July 22 hearing un Hie lule uf dyrk-ullurt: in glubdl warming leyisldliun.

-------