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PT Notes

EPA RFI - Automated Release Detection and Monitoring

PT Notes is a series of topical technical notes provided periodically by Primatech for your benefit. Please feel free to provide feedback.

On July 24, 2014, the U.S. Environmental Protection Agency (EPA) announced a Request for Information (RFI) seeking comments on potential revisions to its Risk Management Program (RMP) regulations and related programs to modernize its regulations. Multiple issues were addressed in the RFI.

One of the issues addresses automated detection and monitoring for releases of regulated substances. The RMP Program 3 Prevention Program requires regulated facilities to conduct a process hazard analysis (PHA). The RMP rule specifically requires that a facility's process hazard analysis (PHA) address engineering and administrative controls applicable to the hazards and their interrelationships, such as appropriate application of detection methodologies to provide early warning of releases. Examples of acceptable detection methods identified in this requirement include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors. Detection methods can eliminate or reduce the severity or likelihood of the release consequences that could occur.

Emergency response procedures also can reduce the severity of a release and protect employees, emergency responders, and the public from harmful exposure to regulated substances. The RMP rule requires regulated facilities to have in place procedures or mechanisms for informing the public and local emergency response agencies about accidental releases.

These PHA and emergency program elements, while addressing detection methodologies, early warnings, and incident notifications, include no specific requirements for automated detection and monitoring systems to be installed. The active use of such systems may enhance both prevention of and response to accidental releases. However, EPA understands that the need for and appropriate deployment of such systems is likely to be highly site-specific, and that facilities already may have appropriate incentives to deploy such systems where warranted and cost-effective. Nevertheless, EPA is requesting information on the need for new or expanded requirements for automated detection and monitoring systems that would supplement either the existing PHA and/or emergency response requirements.

Questions posed by EPA on this issue include:

  1. Should facilities be required to install monitoring equipment or sensors to detect releases of RMP-regulated substances, or the conditions that could lead to such a release? Should the systems provide for continuous detection and monitoring? How should any such requirements be crafted to provide appropriate site-specific flexibility?
     
  2. Are there specific issues that need to be considered for unmanned and/or remote facilities?
     
  3. Should an automated mechanism to notify, alert and warn the local responders and surrounding public of an incident be considered as part of any detection and monitoring system requirement? If so, how should the potential for false alarms be addressed within such a requirement?
     
  4. How can a requirement for automated detection and monitoring systems be best coordinated with the community emergency response plan? What are the advantages/disadvantages between continuous monitoring conducted by automated systems in contrast to third-party alarm agencies?
     
  5. How would a requirement for appropriate detection thresholds best be established for activating alarms and/or alerts?
     
  6. How would the significance and appropriate protective response action of the alarms/alerts best be communicated to responders and the public (including shelter-in-place and evacuations)?
     
  7. What involvement should LEPCs and SERCs have in the development of the emergency response plan, particularly with respect to what actions are to be taken in the event of an incident where an alarm/alert is activated?
     
  8. How frequently should monitoring equipment or sensors used to detect releases of RMP-regulated substances be tested? How should these tests be documented? How long should records of such tests be maintained? Should automated monitoring records for periods of normal operations be maintained, so that past records may serve as an aid in determining what may have gone wrong prior to an accident (e.g. a gradual increase in emissions)? Should EPA specify requirements in this area, or are these aspects of program implementation best left to the facility?
     
  9. Leak detection and repair programs are common under the Clean Air Act's routine emission programs. Can these programs be integrated with the accidental release prevention program to reduce accidental releases and to simplify requirements for stationary sources subject to both the RMP rule and these other programs? Are there jurisdictional issues that prevent integration?
     
  10. What would be the economic impacts of specifying additional monitoring and detection requirements in the RMP rule? Are there any special circumstances involving small entities that EPA should consider with respect to such monitoring and detection requirements?

Further details on this issue are provided in EPA's RFI which can be accessed by clicking here.

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