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Has EPA established a new selection criteria for RMP inspections? PDF Print E-mail
Safety Info Posts - Chemical Process Safety (PSM/RMP)
Written by Bryan Haywood   
Tuesday, 07 August 2012 10:06

This week EPA put out a news release regarding an RMP inspection at an Ethanol plant in CO.  But this news release had something in it that I had never seen before in the hundreds of RMP news releases I have read since 1999.  The news release contained a breakdown of the demographics within the WCS for the facility.  So this led me to wondering... why does this matter and is EPA now using demographics to choose facilities to inspect?

 The news release stated... "This enforcement action will benefit the community, which includes minority and low-income areas. Minority populations comprise nearly half of the residents within a five-mile radius of the facility and 45 percent are below poverty level. Approximately 35 percent of the area’s population is Hispanic."   Someone in the government took the time to look up this data, but the big questions remain unanswered:

1) did EPA know this data when it decided this facility would be inspected?

2) did EPA base their inspection priorities on the demographics surrounding the facility?

3) what difference does demographics have to play in complying with RMP?

Is this a political move in this year of an election?  Just seems very odd to me that EPA would even spend the time with demographics and why they would put them in a news release. 

I am just thinking out loud here, but I would be willing to bet a years pay that the vast majority of RMP facilities are in low income neighborhoods and that these neighborhoods have a high number of families living below the poverty level, regardless of race or nationality.  About 95% of my time is spent in PSM/RMP facilities and I have yet to drive through a gated Country Club Community to reach any of the plants I travel to!!!!  

So what is EPA trying to say with their change in their news release format?  Are they making RMP compliance a political tool?  In contrast to another RMP Inspection news release yesterday regarding three Water Treatment Plants being cited, there is no mention about the demographics these treatment plants could impact.  Now I do not know this for a fact, but my vast experience working in water treatment plants does tell me that these plants CAN BE IN CLOSE proximity to nice neighborhoods.  In fact, many of the treatment plants built in the more affluent areas have better landscaping that any of us could afford so that it "blends into the neighborhood".  These treatment plants have a much smaller footprint than an ethanol plant so they are easier to put in communities, but ironically, MOST OF THEM will have a larger impact than the ethanol plant's 5 mile radius; yet no mention of their impact or the demographics!!!

This is troubling and I certainly hope that EPA is not making RMP a political issue in this election year.  They should at least be consistent and list the WCS radius and dempgraphics in all of their news releases regarding RMP compliance.

Am I paranoid here or  has anyone else seen this?

Here are the News Release that I am referring to.

Three Utah facilities to pay penalties for Risk Management Program violations

Colorado ethanol plant to pay $5,850 penalty for Risk Management Program violations

 

 

 

Comments  

 
0 #3 DN 2012-08-11 00:36
I briefly worked for David and my understanding is that EPA is just initiating its own NEP for RMP related issues. Most of the facilities in Region 8 contain large volumes of ammonia, hence the intensive investigation in those facilities. The only criteria that I was aware was if the facility had many complaints from local residents or had reported numerous releases.

Unfortunately, bringing the demographics into the picture was not a criteria nor should that have even been brought up in the new release.
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0 #2 Dean 2012-08-07 11:46
Also found this: blog.epa.gov/.../...

Look at: Expanding the Conversation on Environmentalis m and Working for Environmental Justice
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0 #1 Dean 2012-08-07 11:40
Maybe give these guys a call as their names are on the top of the article. Maybe there is new legislation regarding the "benefit" of such governmental programs. My guess is this same plant employs the same population they are referring to.
Contact Information: David Cobb, 303-312-6592; Richard Mylott, 303-312-6654
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