PT Notes
EPA RMP Rule 2024 Amendments - Natural Hazards
PT Notes is a series of topical technical notes on process safety provided periodically by Primatech for your benefit. Please feel free to provide feedback.
EPA is making explicit the existing requirement to evaluate natural hazards in hazard evaluations for Program 2 and Program 3 RMP-regulated processes to help ensure that the threats of natural hazards are properly evaluated and managed to prevent or mitigate releases of RMP-regulated substances at covered facilities. The amended RMP rule states that the Program 2 Hazard Review and Program 3 Process Hazard Analysis shall address:
Natural hazards that could cause or exacerbate an accidental release.
Natural hazards, for example, extreme temperatures, high winds, floods, earthquakes, and wildfires, are hazards for chemical facilities because they have the potential to initiate accidents and challenge hazardous chemical process equipment and operations. These hazards can trigger chemical accidents that threaten human health and the environment If not properly managed.
Some RMP accidents are reported as having a natural cause as the initiating event and include unusual weather conditions as a contributing factor. Also, RMP data indicate that the locations of many RMP facilities leave them exposed to natural hazards. Climate change is increasing the threat of extreme weather as a natural hazard and EPA believes that climate change should be taken into account at covered facilities when evaluating hazard frequency and severity.
Studies show that the threat of natural hazards is increasing. There is a scientific consensus that the future holds increased risks of more severe and frequent extreme weather events, including tropical cyclones, coastal flooding, wildfire, tornados, severe thunderstorms, and extreme precipitation.
EPA has defined natural hazards to mean meteorological, climatological, environmental, or geological phenomena that have the potential for negative impact, accounting for impacts due to climate change. Examples of such hazards include, but are not limited to, avalanche, coastal flooding, cold wave, drought, earthquake, hail, heat wave, hurricane, ice storm, landslide, lightning, riverine flooding, strong wind, tornado, tsunami, volcanic activity, wildfire, and winter weather.
The requirement to address natural hazards in hazard analysis covers both the consideration of natural hazards as causes of hazard scenarios as well as their influence in exacerbating accidental releases. In some cases, natural hazards can be a contributing factor for accidental releases, making them more extreme or more likely.
EPA is not requiring the implementation of specific protective measures against natural hazards. Rather, EPA is relying on the existing requirements for Hazard Review and Process Hazard Analysis to produce reasonable decisions based on the information generated.
Of course, natural hazards and process operations vary geographically throughout the United States. Consequently, EPA acknowledges that implementation of protective measures will vary among RMP processes. However, because the RMP rule is performance-based, EPA believes that all regulated RMP facilities can ultimately be successful in addressing natural hazards for their locations within their risk management programs.
EPA plans to update the current hazard evaluation guidance and initiate ways to share natural hazard resources with facility owners and operators to help them identify and evaluate potential natural hazard risks. EPA expects to develop and release this guidance approximately one year after the promulgation of the final rule.
EPA believes that the CCPS guidance, Assessment of and planning for natural hazards, is useful for the evaluation of natural hazards for process safety but recognizes the identification of hazards in FEMA’s National Risk Index and Climate Essentials for Emergency Managers as the most comprehensive foundation to identify, evaluate, and understand relative natural hazard risk, particularly for how natural hazards must account for a changing climate. EPA intends to incorporate and further evaluate other resources in its guidance and expects that information available in these resources can be helpful to complement a facility’s more localized information available from State and local government.
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Disclaimer: This PT Note provides Primatech’s interpretation of regulatory requirements. The actual regulatory requirements can be found at: https://www.epa.gov/rmp
