PT Notes
EPA RMP Rule 2024 Amendments - Power Loss
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.
There are several amendments relating to power loss:
- For both Programs 2 and 3, the safeguards that must be addressed in Hazard Review or Process Hazard Analysis now specifically include standby or emergency power systems.
- The owner or operator must ensure monitoring equipment associated with the prevention and detection of accidental releases has standby or backup power to provide continuous operation.
- Documentation is now required, as part of operating procedures, for the removal of monitoring equipment associated with prevention and detection of accidental releases due to safety concerns during imminent natural hazards.
Power loss can threaten RMP-regulated processes and cause accidental releases if not properly managed. Indeed, power loss has resulted in serious accidental release incidents at RMP-regulated facilities and the backup power provisions target these events.
EPA believes that making more explicit the existing accident prevention program requirement to evaluate hazards of the process will ensure that threats of power loss are properly evaluated and managed to prevent or mitigate releases of RMP-regulated substances.
EPA is not requiring the implementation of standby or emergency power for the entirety of an RMP process but rather requiring sources to consider the appropriateness of backup power for their processes and to explain decisions not to implement backup power. There may be situations where backup power is not critical to chemical release prevention, so the rule provides sources with the opportunity to explain their decision-making. The approach is consistent with the performance-based nature of the RMP rule.
EPA has taken a slightly different approach with respect to backup power for monitors. EPA is requiring standby or backup power for air pollution control or monitoring equipment associated with the prevention and detection of accidental releases from RMP-regulated processes because EPA believes that doing so will ensure that the RMP-regulated substances at covered processes are continually being monitored. EPA believes that once a facility has made and documented the determination that it is appropriate to have monitors for accidental releases, then ensuring their operation through requiring backup power is an appropriate operational requirement.
EPA is requiring documentation of the removal of monitoring equipment for accidental releases during natural disasters to address the concern that the threat of extreme weather events has been used by some owners or operators to justify disabling equipment designed to monitor and detect chemical releases of RMP-regulated substances.
EPA does not believe that all natural disasters should be treated as an exception to the requirement to develop a program that includes monitoring for accidental releases. However, EPA understands that, in some situations, such as hurricane winds, there is a potential for damage to, or by, monitoring equipment if not secured and EPA allows a source to shut down monitoring equipment in such cases provided that an explanation is included in its RMP.
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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
