PT Notes
EPA RMP Rule 2024 Amendments - Stationary Source Siting
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.
Stationary source siting has been made a specific requirement under the Program 2 Hazard Review and explicit requirements for stationary source siting are now specified for both Program 2 and Program 3. Hazard Review and Process Hazard Analysis must address:
Stationary source siting, including the placement of processes, equipment, and buildings within the facility, and hazards posed by proximate stationary sources, and accidental release consequences posed by proximity to the public and public receptors.
The siting of processes and equipment within a stationary source can impact the surrounding community, not only through the proximity of the accidental release to offsite receptors adjacent to the facility boundary, for example, people, infrastructure, and environmental resources, but also through increasing the likelihood of a secondary ‘‘knock-on’’ release or domino effect by compromising nearby processes.
EPA notes that it is making more explicit what is already required for stationary source siting evaluation. EPA is expounding on the current regulatory text to ensure that siting evaluations properly account for hazards resulting from the location of processes, equipment, buildings, and proximate facilities, and their effects on the surrounding community.
With regard to proximate stationary sources, EPA notes that facility owners and operators need to be aware of and consider the apparent presence of facilities within the release impact zones of their facility, and how releases would be affected because of the presence of nearby facilities.
While EPA encourages sharing of chemical and process information between facilities, particularly for emergency response purposes, EPA does not believe this sharing of information is required in order to comply with the requirement to address proximate facilities in stationary source siting. Nevertheless, when conducting siting evaluations, EPA expects sources to consult publicly accessible information on nearby sources, such as RMPs and information available through LEPCs.
EPA notes that there is a breadth of guidance on siting, and believes there is adequate information available for facilities to comply with the requirements in the amended rule. EPA expects facilities to continue to use available resources and any additional industry-specific guidance to properly evaluate siting hazards.
The amended rule does not mandate that existing sources modify their footprint as a result of a siting analysis. The approach taken is similar to how hazard evaluations have proceeded in the past, that is, they require the analysis of hazards and rely upon owners and operators to use the information reasonably when determining what measures should be undertaken. The siting requirement in the amended rule does not provide any restrictions on location, such as minimal setbacks or other specific location restrictions.
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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
