pressure vessels - rapture hazard & prevention

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Newsletter

Clean A ir Ac t 112(r) Risk Management Program (RMP) E P C R A

Ma rch-April 2008 US EPA Region 10

Inside This Issue

1 Ima ge s of Pressure

Vessel Failu res

2 Rupture Hazard of

Pressure Ve ssel

4 Case History: Fau ltyWelds caused

Pressure Vessel

Explosion and Fire

5 Proc ess Safety

Informatio n for Pressure

Vessels and o ther

Process Equip ment

6 Pressure Vessel Hazard

Reduction

7 Atmo sphe ric Tank is

Not a Pressure Vessel

8 Safe ty Ale rt: Liqu ified

Gas Cylinder Failure

9. Free RMP Portla nd

Training

9 DHS CFATS do no t

Impact EPCRA or 112r

Reporting

9. EPCRA Tier2 Reports

due March 1st

CEPP Newsletter

US EPA Reg ion 10, ERU ECL-116

1200 6th Avenue, Suite 900

Sea ttle, Washingto n 98101

206.553.1679 • Fax: 206.553.0124

http://www.epa.gov/r10earth/1

12r.htm

For RMP : Kelly Huynh at

[email protected]

For EPCRA: Suzanne Powe rsat

[email protected]

For free Subscription :

allen.step hanie@ep a .gov

This issue fea tures:

Pressure Vessels: Rupture Hazards and Prevention

Images of Pressure Vessel

Failures

An internal non-co de w eld had

we akene d the she ll of this vessel. The tank explode d c ausing the release

of anhyd rous am monia to the

atmosphere.

This vessel exploded killing one

op erator and triggering the release

of aq ua a mmo nia. The tank had no

relief device for overpressure

protec tion, nor did it have b asic

proc ess c ont rol or alarm

instrumentation.

The sc ene follow ing a vessel fa ilure

and fire. The vessel ruptured due to overpressurization, releasing

flam ma ble mat erial whic h then

ignited . Four workers we re killed .

(Photo of t ank b efore explosion). The

propane ta nk that c aught fire a nd

explode d after a vehicle p lowed

into the ta nk’s unprotec ted piping.

The explosion killed two voluntee r

firefighters and injured several

emergency responders.



PAGE 2 Chemica l Emer enc Prevention & Plannin Newsletter

ProblemImproperly operated or maintained pressure vessels

can fail catastrophically, kill and injure workers and

others, and cause extensive damage even if the

c ontents are b enign.

Example of Accidents

Three workers were killed and a numb er of othe rs

were injured when a high-pressure vessel containing

air and wa ter rup tured . The ve ssel that ruptured wa s

originally designed with a working pressure of 1740

pounds per square inch (psi), but was operatingbetween 2000-3000 psi. After a number of years of

service , the vessel deve loped a p in-ho le leak. The

leak was repaired but not in adherence with

recognized codes. About a month later, the vessel

failed c ata strop hic ally at the we ld a rea . The ve ssel

ripped apart and rocketed through the roof. Major

pieces of shrapnel weighed from 1000 to 5000

po unds. Som e p iece s we re thrown a half mile aw ay.

Fortunately, people on a nearby highway and a

nearby commuter railway narrowly missed injury.

Dama ge to the p lant w as extensive a nd a po rtion of

the state was without phone and electrical servicesfor ma ny ho urs.

Hazard Awareness

This ac c ident d em onstrate s the p otential dange r of

pressure vessels if they are not properly designed,

constructed, operated, inspected, tested, or

rep a ired . The higher the op erat ing p ressure and the

larger the vessel, the more energy will be released in

a rupture a nd the wo rse t he c onseq uenc es. It should

be emphasized that the danger exists even if the

vessel contents are not flammable, reactive, or

explosive. In the c ase ab ove , a vessel c onta ining onlywater and air ruptured and released great energy.

Had the contents of the vessel been flammable

and/or toxic, the consequences would probably

have b een ma gnif ied.

Factors in Pressure Vessel Failure

The following conditions and factors have played

major roles in pressure vessel accidents:

Operation above the maximum allowable

Rupture Hazard of Pressure Vessels

working a nd test p ressures. Improper sizing or pressure setting of relief

devices.

Improper operation of relief devices due to

faulty maintenance and failure to test

regularly.

Failure of the vessel due to fatigue from

repeated pressurization, general thinning

from c orrosion o r erosion, loc a lized corrosion,

stress corrosion cracking, embrittlement,

ho les and leaks.

Fa ilure to inspe c t freq uently enoug h.

Improper repair of a leak or other defect

involving welding and annealing that

embrittles and further weakens the vessel.

Hazards posed by a vessel can be worse if

repair welds are made without shutting

down and de-inventorying the vessel. If a

pressure vessel is repaired without removing

the water, the quench effect of the water

c an e mb rittle the stee l.

Overpressuring and failure of the vessel due

to e xothe rmic rea c tion or po lymeriza tion.

Vessel expo sure to fire.

Pressure Vessel Laws

Requirements for pressure vessels vary widely from

sta te to sta te. Many stat es have a b oiler law, but

others do not. Even for those states that have a

boiler law, typical practices (e.g., inspecto

requirements) for pressure vessels may vary. State

boiler laws that require general adherence to

Am eric an Soc iety of M ec hanica l Eng ineers (ASME)

codes or National Board Inspection Code (NBIC)

usually require the following for each pressure

vessel: Registering with the state boiler and pressure

vessel d ep a rtme nt.

Designing and constructing in accordance

with Sec tion VIII of the ASME Boiler a nd

Pressure Ve ssel Code (ASME Code), Rules fo

Construc tion o f Pressure Vessels, Division 1

which covers vessels operating between 15

psi and 3000 psi.

Ma rking the ASME Co de o n the vessel w ith- more -



PAGE 3Chemica l Emer enc Prevention & Plannin Newsletter

specified information that includes the

ma nufac turer, the serial num ber, the yea r built,

and the maximum allowable working pressure

for a specific temperature, and any special

suitability such as for low temperature and

poisonous gases or liqu ids.

Having the vessel approved for installation with

the submission of drawings, specifications,

welding d etails and ca lc ulations, and having a n

authorized inspector be satisfied with the

we lding a nd witness the testing.

Operating at pressures below the maximum

allowable working pressure with pressure

relieving d evice s set a c c ording to the A SME

Co de; testing a t reg ular inte rva ls.

Periodically inspecting for corrosion and

defects, and testing according to the NBICMa nua l for Boiler and Pressure Vessel Inspec to rs

or American Petroleum Institute (API) 510,

"Pressure Vessel Inspec tion C ode," for vessels in

the p etrochem ic al industry.

Repairing or altering only according to a plan

approved by an authorized inspector and

cond uc ted by test-qua lified we lders. The

inspector must be satisfied that the repairs are

performed according to NBIC or API 510 and

specify any necessary nondestructive and

pressure testing. Increasing the maximum

allowable working pressure or temperature is

considered an alteration whether or notphysica l work is done.

In states with no pressure vessel law, good safety

prac tices req uire that simila r preca utions be follow ed

in the design, construction, welding, testing, marking,

operation, inspection, and repair of any pressure

vessel. The ASME Cod e should b e used for the design,

construction, initial testing, and operation of pressure

vessels. The NBIC or API 510 should be used for

maintenance and inspection and subsequent testing.

Boiler and machinery insurance companies, some

pressure vessel sup p liers, or jurisd ic tion-licensedindependent contractors can provide authorized

inspec to rs.

Evaluating Potential Explosion Hazard

Facilities, particularly those without formal pressure

vessel inspection programs, should survey their

vessels, review pertinent history and data to identify

hazards, and prevent vessel rupture or catastrophic

failure.

Among the questions to be asked and answered are

the follow ing:

1) Does the vessel op erate a bo ve 15 psi, and wa s

it designed, fabricated, and constructed

ac c ording to the ASME Cod e o r othe

app lica ble c ode?

Is the vessel co de lab eled or stamp ed ?

Is the operating pressure and size of the vesse

known?

2) Is the vessel maintained, inspected, and

rep a ired acc ording to the NBIC a nd / or API 510?

3) Are the ratings and settings of the relieving

de vic es ap propriate?

Are the devices tested regularly and howrecently?

4. Is the vessel inspec ted period ica lly?

What a re the c riteria fo r inspe c tion freq uenc y?

When w as it last inspec ted externa lly?

When w as it last inspec ted internally?

Did the inspection disclose general thinning of

walls due to corrosion, localized corrosion, stress

corrosion cracking, embrittlement, holes, leaks

or any other defects that required follow up?

Were they followe d up?

5. Has the ve ssel be en repa ired ?

Were the plan of repair, welding techniques

and safety tests approved by a certified o

authorized inspector?

Was the welding done by a qualified welder?

Were the welding performance qualification

tests ap proved by an inspe c tor?

Was the vessel tested after the repair was

completed?

6. Was the vessel down rated and were the

nec essary cha nge s in ope ra ting c ond itions andrelief d evice settings ma de?

7. Are exothermic reactions carried out in the

vessel?

Does the vessel have an emergency relief

system to hand le runaw ay rea c tions?

(Referenc e: EPA Public a tion 550-F-97-002A)




This incident provides information regarding an

explosion and fire that occurred at the Marcus Oil

fac ility in Houston, Texa s in Dec em ber 2004.

Investigators determined that the explosion resulted

from fa ulty weld s in a steel p roc ess p ressure ve ssel.

The w eld used to c lose the te mp orary op ening on

Tank 7 failed du ring the inc ident b ec ause the rep ai

weld (see figure) did not meet generally accepted

industry quality standards for pressure vesse

fab rica tion. The o riginal, flame -cut surfac e was no tground off the plate edges before the joint was re-

welded, and the weld did not penetrate the ful

thickness of the vessel head. Furthermore, the welds

c onta ined exce ssive po rosity (holes from ga s bub b les

in the we ld). These de fec ts significantly deg rade d the

streng th of the we ld.

o Design Issues – Relief Valves

Inve stiga to rs found tha t Tanks 5, 6, 7, and 8, the

nitrogen storage vessels, and the compressed-ai

storage vessel were not equipped with pressure-reliede vices, as req uired by the Ame ric an Soc iety o

Me cha nica l Eng inee rs (ASME) Boiler a nd Pressure

Vessel Code. However, this was not a factor in

causing the incident.

o Process Changes

Marcus Oil installed a connection between the

nitrogen and compressed-air systems to provide rapid

pressurization of the nitrogen system when the- more -

Case History: Faulty Welds Caused Pressure Vessel

Explosion and Fire

o Discussion

In its final investigation report on the explosion, the

U.S. Chemical Safety Board (CSB) describes the

violent explosion of a 50,000-pound steel pressure

vessel a t the Ma rc us Oil and Che mica l fac ility. The

explosion was felt over a wide area in Houston andignited a fire tha t b urned for seve n hours. Seve ra l

residents were c ut b y flying gla ss.

Building and car windows were shattered, and

nearby buildings experienced significant structural

and interior da ma ge.

The Ma rcus Oil fac ility refines polyethylene wa xes for

industria l use. The c rud e w axes, which a re ob ta ined

as a byproduct from the petrochemical industry,

contain flammable hydrocarbons such as hexane.

The w axes a re p roc essed and purified inside a va riety

of steel p roc ess vessels. The vessel tha t exp lod ed wasa horizontal tank 12 feet in diameter, 50 feet long,

and operated at a pressure of approximately 67

po unds per squa re inch.

The c ase study rep ort and acc om pa nying safe ty

rec omm enda tions have be en p osted to the CSB web

site (http://www.csb.gov).

o Welding Issues

Investiga tors dete rmined tha t the fa iled vessel, known

The sc ene following t he explosion

as Tank 7, ha d b ee n mo d ified by Ma rcus Oil to insta l

internal heating coils, as were several other pressure

vessels at the facility. Following coil installation, each

vessel wa s resea led by we lding a stee l plate over the

2- foot-d iame ter temp orary opening. The repa ir we lds

did not meet accepted industry quality standards fo

pressure ve ssels. Ma rcus Oil did no t use a qua lified

welder or proper welding procedure to reseal the

vessels and did not pressure-test the vessels after the

welding was co mp leted .

Rec overed p atc h plate weld from failed Tank 7




The EPA Risk Management Program (RMP) requires the facility to complete a compilation of written process

sa fety informa tion ……. This p roc ess sa fety informa tion sha ll include informa tion p ertaining to the haza rds of

the regulated substances used or produc ed by the p roc ess, informat ion pe rta ining to the tec hnology of the

proc ess, and information p ertaining to the equipment in the process. (40 CFR 68.65.)

For equipment in the process, you must include information on:

Materials of construction

Piping and instrument diagrams (P&IDs)

Elec tric a l c lassific a tion

Relief system design and design b asis

Vent ila tion system design

Design c od es & standa rds em ployed

Safety systems

Ma terial and ene rgy ba lanc es for proc esses built a fter June 21, 1999

nitrog en p ressure w as too low to move m olten wa x

from the tanks to the p roc ess unit. The c om pa ny

assumed that compressed air was an acceptable

substitute for nitrogen during processing. However,

investiga tors de termined tha t ma nag eme nt d id not

evaluate the hazards that resulted from this process

change. Pressurizing the nitrogen system with

compressed air contaminated the nitrogen gas

with as much as 18 percent oxygen — a level

sufficient to support combustion.

Marcus Oil used air instead of nitrogen to boost the

pressure of the vessel, and the oxygen inside the

tank allow ed the ignition o f the flamma ble m aterial,

mo st likely by sparks from the m eta l fragme nts. The

fire spread back into the damaged tank and

c aused a v iolent explosion, which p rop elled the 25-

ton vessel mo re than 150 feet.

o Pressure Vessel Codes

The ASME Boiler a nd Pressure Vessel Co de provides

rules for pressure ve ssel design, fa bric a tion, we ld

procedures, welder qualifications, and pressure

testing. In addition, the National Board of Boiler and

Pressure Ve ssel Inspec to rs ha s esta b lished the

National Board Inspection Code for pressure vesse

rep a irs and a lterations. The c od e req uires a lterations

to pressure vessels to be inspected, tested, certified

and stamp ed.

"If the provisions of internationally recognized pressure

vessel safety codes had been required and

enforced, this accident would almost certainly not

have oc curred ," CSB Boa rd Memb er John S. Bresland

said.

o Implications

The inc iden t a t the Ma rcus Oil fac ility unde rsc ores theimportance of compliance with pressure vessel and

inspection codes and the use of qualified welders

Equally important is understanding the potentia

hazards introd uced with p roc ess c hang es.

(Referenc es: CSB; DOE/ Richa rd Higg ins)

Process Safety Information for Pressure Vessels

and other Process Equipment




Pressure ve ssels must c om p ly with a ll reg ulations,industry codes, and standards to keep vessels in

safe condition to handle design pressures and

temperatures. Areas to review could include, but

are not limited to, the follow ing:

Design

At a minimum, pressure vessels should be designed

in ac c orda nce with the Americ an Soc iety of

Mechanica l Eng ineers (ASME) Cod e for ma teria l

c ontents of va rying cha rac te ristics. Fac ilities shou ld

address any added concerns about the

temperature and characteristics of vessel contents

(e.g., toxic, corrosive, reactive, or flammable

contents). When the vessel contents are changed

from those the vessel as designed for, a risk analysis

should be c onduc ted to d ete rmine if it is still sa fe for

the ne w m ate rials.

Certification of Vessels

Ma ny sta tes have a b oiler law , but othe rs do no t. Instates with a pressure vessel law, all pressure vessels

must be certified by the relevant state authority as

me eting req uirem ents of the ASME Co de. When apressure vessel cannot be constructed to comply

fully with the ASME Code, how eve r, the Na tional

Board Inspection Code (NBIC) provides a

procedure by which the pressure vessel may get

sta te app rova l without b ea ring the ASME symbol.

This p roc ed ure includ es submitta l of d rawings,

calculations, welding procedures, service

conditions, welding qualification and performance

tests, and professional engineering certifications.

This should be d one befo re a ny construction b eg ins.

When a fac ility finds an unm arked vessel or is about

to b ring one into a sta te , simila r informa tion p lus therepair history should be submitted to the state

pressure vessel authority for review and approval

befo re use b eg ins or co ntinues.

On the other hand, when a pressure vessel is

located in a state without a pressure vessel law, is

not ma rked with the ASME symb ol, and there a re

doubts about the safety of the vessel, the

information listed above should be submitted to a

pressure vessel consulting engineer and authorized

inspec tor for a sa fety review.

Inspection of Vessels

The NBIC a nd Am erican Pet roleum Institute (API) 510

require that vessels be periodically inspected externally

and internally. External inspections are made more

frequently and Involve visual and nondestructive

examination. An internal inspection is more difficult to

perform because it usually requires a confined space

entry and the vessel must be taken out of service

cleaned, and prepared. General or localized thinning

of the internal walls due to corrosion or erosion is a

po tential problem a nd must b e m onitored , with rec ords

kep t of the rate o f thinning . When the vessel is rea c hing

the e nd of its useful life, the p eriod be twe en inspe c tionsis shortened so that the vessel may be taken out of

service before it can become dangerous. An interna

test may also reveal stress corrosion, cracking, pitting

embrittlement, and other defects that could weaken

the vessel. In addition to the vessel itself, the relieving

devices must also be tested. When practical, this can

be do ne in plac e for vessels conta ining non-haza rdo us

substances, but for vessels containing hazardous

substances without special controls (e.g., scrubbers)

safety relief valves must be taken off to ascertain

whether their settings are correct. How this can be

do ne sa fely and c onveniently should be c onside red .

Maintenance

In a dd ition to m aintena nce requirem ents, the NBIC a nd

API 510 include specific preheating and postheating

requirements. Large temperature differences between

the outside and inside surfaces of the vessel - during

repair or other welding - must be avoided to minimize

embrittling or stressing the metal. Nondestructive

examinations may include radiographic, ultrasonic

liquid penetrant, magnetic particle, eddy current

visua l che cks, and leak testing.

Operation of Vessels

Operators should consider process start-up and

shutdown conditions, possible process upsets, and any

other unusual conditions that might cause overpressure

prob lems. The ASME Co de includ es rec om me nded

pressure d ifferentia ls betw ee n sa fety va lve set p ressures

and maximum allowable working pressure, as well as

the pressure differential settings of the relieving devices

whe n there are multiple d evice s.(Reference: EPA)

Pressure Vessel Hazard Reduction




Train maintenanc e p ersonnel to a ntic ipate

c onditions that could je opardize their safety o r the

safety of others.

A Ma intenanc e Supe rvisor indica ted he d id not know

pressurizing the tank was a dangerous practice or that

anything could go wrong. Working with pressurized

equipment requires a level of care and engineering

knowledge which was not available in theMaintenance Department. Maintenance workers need

safe ty training be c ause they are continually p resente d

with a complex and constantly changing set of

activities. Maintenance workers travel throughout the

entire plant in the c ourse o f their work. Prope rly trained

they can provide information that is beneficial to the

other plant activities while conducting their work.

Inform employees that no equipment is to be

altered or retrofitted. Establish a procedure for a

qua lified p erson(s) to review propo sed equipmen

changes. Conduct periodic plant audits

spec ifica lly for non-standa rd use o f equipm ent.

When equipment is retrofitted, altered or used in a way

for which it was not designed or for a purpose othe

than originally intended, unintentional consequences

may result. A procedure for a qualified person(s) to

review equipment change, modification or use should

be de velope d a nd impleme nted . Since there is alwa y

pressure to “make do” with what is at hand or adapt

what is available, periodic plant audits to detect

unapp roved equipment c hange or mod ifica tion should

be c onducted.(Referenc e: MSU)

On June 21, 2001, a worker died when a 500-gallon

at mospheric storage ta nk he wa s em pt ying o f wa ste o iland water exploded from its base. He was pressurizing

the c ontents of ta nk using c om pressed a ir to spe ed up

dra ining . Comp ressed a ir a t 120 psi wa s used . The ta nk

was not approved for use as a pressurized vessel.

According to a co-worker, the practice of pressurizing

the tank had been going on for 6 years without

ma nag eme nt’s aw areness. The p roc ed ure had be en

passed from maintenance worker to maintenance

worker.

The forc e of the explosion p rop elled the ta nk 500 feet in

the air over the p lant fenc e a nd a nearby ba nk pa rking

lot o nto a busy road . The event resulted in OSHA issuing

one serious c itation und er the G ene ra l Duty Clause for

failing to establish, train on and enforce use of a

procedure to empty waste oil containers which would

prohibit application of air pressure to a container not

designed or rate d as a p ressure vessel.

What Can You Do

Conduct job safety a nalyses and establish standard

operating procedures for routine ma intenanc e tasks

and train the maintenance personnel in these

procedures.

A job hazard analysis is a procedure used to review each

job, identify potential hazards, and design actions and

p roc ed ures to e liminat e or control the hazards. Input from

workers who usually perform the tasks is important. Of

primary importance is the recognition that hazards exist.

Even though maintenance work is complex and

c onstantly cha nging , there a re routine ta sks. The

transferring of waste oil and water was a routine task. A

job hazard analysis may have identified the potential for

employee injury pressurizing a tank that was not

approved as a pressurized vessel.

Do not pressurize a container not approved as a

pressure vessel.

This fata lity involved the improp er use of e qu ipme nt. The

task was commonly conducted, yet no one associated

with the practice was aware of the consequences of

pressurizing a vessel not approved for use under pressure.

OSHA ha s regulations rega rding the use a nd inspe c tion of

p ressure ve ssels. ASME, the Com pressed Ga s Assoc iat ion,

and the A meric an Petroleum Institute a mo ng others have

standards and guidelines governing the use of pressure

vessels.

Atmospheric Tank is Not a Pressure Vessel!




Safety Alert

Liquefied Gas Cylinder Failure

A liquid nitrog en cylinder in a university chem istrylabo rat ory cata strop hica lly failed due to ove r pressurizat ion,

causing substantial dam ag e. Fortunately the incident oc c urred

at 3 AM a nd the building w as not oc c upied, so there were no

injuries. The ove r pressuriza tion b lew out the bottom of the

c ylinder and prop elled the c ylinde r upw ards. The c ylinder

pressure relief va lve a nd rupture

disc had been replac ed b y two

brass p lugs a t som e t ime in the

pa st by a n unknown p erson.

Before the inc ident, the c ylinder

ma y have b een leaking through

an old g asket, providingsufficient relea se of g as to

preve nt o ver p ressure.

Ap proxima tely twelve ho urs be fore the e xplosion, the leaking ga sket ha d

be en replac ed and the c ylinder refilled w ith liquid nitrog en. With the new

ga sket, the cylinder wa s now com pletely sea led, and pressure c ould b uild

up . The cylind er ruptured when its internal p ressure rose a bove 1000 psi. The

c at astrop hic failure o f the nitrog en c ylinder wa s a result of the removal of

the ressure relief dev ice s.

Intac t c ylinde r and rem ains of ruptured c ylinde r

Laboratory Damage

Did you know?

Lique fied and p ressurized gas c ylinders a re

c om monly used in lab orato ries and in

manufacturing plants.

In this incident , the force relea sed by the

failure o f the c ylinder wa s estimated at

250,000 pound s (~ 113,000 kilog ram sforce ).

Cryog enic storag e m ust e ither be

refrigerated to m aintain the low

tem perature a nd p ressure, or slowly blee d

off eno ugh vapo r to ma intain pressure

and coo l the rem aining inventory.

An incide nt this po we rful ca n relea se

other hazardous ma terials in nea rbyconta iners, vessels, and p iping, c ausing a n

even more seve re incide nt.

What can you do?

Never mod ify any eq uipm ent c ontaining ha zardous

ma terials or energy w ithout qualified eng ineering

evaluation, and a lwa ys co nduct a mana gement of

cha nge review.

If you observe a high p ressure o r liquefied ga s c ylinder

that a pp ea rs to ha ve b een m od ified , or is co rrod ed or

othe rwise da ma ge d , rep ort it to supe rvision

immed iately so it ca n be rem oved from servic e.

Ensure that cylinders are properly maintained and

period ica lly inspec ted , includ ing the p ressure relief

devices.

If you use p ressurized gas c ylind ers, ma ke sure you a re

p rop erly trained in the sa fe ha nd ling of high p ressurecylinders.

Share th is incident with your co llea gues in the

lab oratory who ma y use p ressurized gas c ylind ers.(Refe renc e: Proc ess Safe ty Beac on)

This newsletter prov ides information on the EPA Risk Manage me nt Program, EPCRA a nd other issues rela ting to the

Ac c idental Relea se Prevention Requirem ents of the Clea n Air Ac t. The information should b e used a s a referenc e too l, no

as a definitive source of compliance information. Compliance regulations are published in 40 CFR Part 68 for CAA section

112(r) Risk M ana em ent Pro ram, a nd 40 CFR Part 355/ 370 for EPCRA.




Department of Homeland Security

Chemical Fac ility Anti-Terrorism

Standards (CFATS) d o not im pac t EPCRAor CAA 112(r) Rep orting

In a new regulation (6 CFR Part 27) the

Depa rtment of Home land Sec urity (DHS) beg an

(January 22, 2008) requiring vulnerability

assessme nt and sec urity p lanning fo r loca tions

tha t sto re ha zardous c hem ica ls. Inc lusion und er

the reg ulation is de pe ndent up on the type and

amo unt o f chem ica ls stored . The thresho lds for

inclusion are g ene rally lowe r than o ther

reg ulat ory p rog ram s.

Rec ently, seve ral fac ilities sub jec t to Fed eral

rep orting req uirem ents unde r the Emerge ncy

Planning a nd C om munity Right to Know Ac t

(EPCRA) or Clean Air Act section 112(r) have

inquired ab out the a pprop ria teness of filing

rep orts und er the se legislative req uirem ents.

Fac ilities have c ited nond isc losure or

confidentiality ag reement s relating to

imp lementa tion o f the Depa rtment o f Home land

Sec urity's new Chem ica l Fac ility Anti-Terrorism

Sta nd ards (CFATS).

It should b e no ted that nothing in the ne w C FATSregulations alters the requirements that apply to a

fac ility c ove red und er b oth CFATS, EPCRA and

CA A 112(r).

In the p rea mb le to the reg ulation, DHS further

c larifies this p rovision, spec ifica lly indic a ting tha t

CFATS ha s no a ffec t o n EPCRA, CAA sec tion

112(r), and other law s administered by EPA:

"At this time, we do no t intend to d isplac e o r

otherwise a ffec t any provisions of Fed eral

sta tutes, inc luding the Eme rge nc y Planning a nd

Co mm unity Right to Know Ac t, 42 U.S.C. 11001 e

seq ., or sec tion 112(r) and 114 of the Clea n Air

Ac t of 1990, as amende d,."

The regulation and preamb le langua ge arec onsistent with similar langua ge c onta ined in the

sta tute a uthorizing the C FATS program (Pub lic

Law 109-295, Sec tion 550).

At the hea dqua rters level, EPA a nd DHS officia ls

have had rec ent d isc ussions to c onfirm that the

c urren t intent o f the CFATS regulat ions rema ins i

ac co rda nce with this understand ing a nd tha t

information currently req uired to be submitted

und er EPCRA and CAA Sec tion 112 (r) is no t

Chem ica l-Terrorism Vulnerab ility Info rmation

(CVI).

RISK MANAGEMENT PROGRAM (RMP) TRAINING – PORTLAND, OR – JUNE 3, 4, 5

Sec tion 112(r) of the Clean Air Ac t m and at es that fac ilities that hold or use ve ry toxic or flamm ab le

substa nc es a t or ab ove threshold quantities deve lop Risk Mana ge me nt Prog rams. The Environme nta l

Prote c tion A ge nc y (EPA) is offe ring FREE one-day RMP Tra ining , whic h w ill provide informa tion a bout how to

c om ply with the RMP rep orting a nd e merge nc y planning requireme nts.

This one -day training is be ing offered three sep arate da ys. Informa tion c an be found at

(http :// yosem ite.epa .gov/ R10/ CLEANUP.NSF/ sites/ rmp). To reg ister o r for mo re informa tion c ont ac t:

allen.step hanie@ep a.go v

REGULATORY UPDATES

Tier 2 Annua l Rep orts Were Due Ma rch 1

Tier 2 annua l rep orts we re d ue M arc h 1. 2008. Sta te rep orting requ irem ents a re a va ilab le a t

http://www.epa.gov/emergencies/content/epcra/tier2.htm

pressure vessels - rapture hazard & prevention

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