INGAA Comments to EPA�s Request for Information concerning Accidental Release Prevention Requirements: Risk Management Programs under the Clean Air Act

INGAA recognizes that most natural gas transmission and storage facilities are not covered by EPA’s RMP standard, as they are not considered stationary sources.  Rather, natural gas transmission facilities are regulated by the U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA).   INGAA, however, is submitting these comments to the limited extent that its member companies own or operate certain facilities that may be considered covered or partially covered by RMP.    
EPA’s RFI directly references the Occupational Safety and Health Administration’s (OSHA) Request for Information regarding its Process Safety Management (PSM) standard (OSHA RFI).  EPA acknowledges that both the OSHA PSM standard and the EPA RMP standard are “closely aligned in content, policy interpretations, Agency guidance, and enforcement.” (See, EPA RFI p. 44605). On March 28, 2014, INGAA submitted comments in response to the OSHA RFI.  For consistency purposes, INGAA reiterates some of these same points in these comments.
  • EPA should not include liquid condensate on its list of regulated flammable substances (Section II.C.1(a) of the EPA RFI).
  • EPA should not revise the definition of Recognized and Generally Accepted Good Engineering Practices (Section II.C.3 of the EPA RFI).
  • Any expansion of the management of change requirements in the RMP rule to include management of organizational change should not be overly prescriptive (Section II.C.5 of the EPA RFI).
  • EPA should not require facility owners or operators to hire third parties to conduct compliance audits (Section II.C.6 of the EPA RFI).
  • EPA should clearly define criteria for risk assessment (Section II.D.1 of the EPA RFI).
  • EPA should consider that natural gas transmission companies are already subject to comprehensive requirements to coordinate with local emergency responders (Section II.D.2 of the EPA RFI).
  • EPA should examine technology and cost limitations as it considers the inclusion of automated detection and monitoring for releases of regulated substances through the process hazards analysis (Section II.D.3 of the EPA RFI).
  • EPA should use a statistical analysis to aid in siting decisions for stationary sources (Section II.D.4 of the EPA RFI).
  • EPA should weigh the security concerns involved prior to permitting public disclosure of RMP information (Section II.D.8 of the EPA RFI).
  • Any revision to the Emergency Response Planning Guidelines should follow the systems currently in place for consistency in reporting thresholds and/or toxic endpoints by using Acute Exposure Guideline Levels (Section II.D.9 of the EPA RFI).
  • EPA should not adopt the safety case regulatory model (Section II.D.11 of the EPA RFI).