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RE: Emergency release prevention



Most RMP facilities use the EPA methods to derive vulnerability zone distances, but independent modeling confirms some inconsistencies. The absolute number is not so important, in my view. 

Use of RMP information is limited for "covered persons" with access through their official duties (at EPA, etc.), but I am not a covered person. The data taken down off the EPA website had just the facility registration and certain other data, not the off-site consequence analyses. These registration data, however, have been available through rtknet.org for many years. 

In general, I don't view secrecy for industrial chemicals as realistic at all, especially the railcars...

Paul Orum
202-507-3211


--- On Tue, 12/2/08, Callahan, Mike <Mike.Callahan@jacobs.com> wrote:

> From: Callahan, Mike <Mike.Callahan@jacobs.com>
> Subject: RE: Emergency release prevention
> To: "Paul Orum" <paul_orum@yahoo.com>, p2tech@great-lakes.net
> Date: Tuesday, December 2, 2008, 5:59 PM
> Hello Paul,
> 
> This report is very interesting and I do believe that P2
> should be playing a
> major role in reducing risk and improving security. I did
> some work a few
> years ago using RMP data to define action levels as to
> high, medium, and low
> risk.  My thought was that many people define the level of
> risk as some
> arbitrary number (like 100,000 or more), with no
> consideration as to how the
> number is derived.  If you don't define the number, the
> method to derive the
> number, and the basic modeling assumptions, then you often
> end up comparing
> apples to oranges.
> 
> But I'm more curious about the publishing of your data.
>  While RMP reports
> are public documents, I recall that the USEPA prohibits
> what you have done.
> You are not allowed to compile the data from individual
> reports and then
> present a database of the results that allows individual
> sites to be
> identified.  A similar compilation of RMP data was
> available on the internet
> a few years ago but was pulled down due to this issue.  I
> would be interested
> in knowing if the USEPA has lifted these restrictions. 
> Otherwise, a very
> interesting work.
> 
> Mike Callahan, PE
> Jacobs Engineering
> 1111 S. Arroyo Parkway
> Pasadena CA 91105
> Business: (626) 568-7005
> Cell: (213) 359-9805
>  
> 
> -----Original Message-----
> From: owner-p2tech@great-lakes.net
> [mailto:owner-p2tech@great-lakes.net]On Behalf Of Paul Orum
> Sent: Tuesday, December 02, 2008 2:00 PM
> To: p2tech@great-lakes.net
> Subject: Emergency release prevention
> 
> 
> You may be interested in a new report, Chemical Security
> 101, that outlines
> how safer and more secure chemicals or processes can remove
> the possibility
> of a major toxic gas release at high-hazard chemical
> plants.
> 
> Chemical Security 101 is on-line at -
> www.americanprogress.org/issues/2008/11/chemical_security.html
> 
> This side of P2 is underdeveloped, in my experience, yet
> holds opportunities
> to reduce chemical hazards. I am interested to learn of
> further examples and
> experience for preventing the possibility of major
> emergency chemical
> releases.
> 
> Paul Orum (report author)
> 202-507-3211
> 
> 
>       
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A map of P2TECH subscribers can be viewed at http://www.frappr.com/p2tech.

This list is managed by the Great Lakes Regional Pollution
Prevention Roundtable (http://www.glrppr.org), part of the
P2Rx national network of regional P2 information centers
(http://www.p2rx.org ).
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
All views and opinions presented above are solely those of the author or
attributed source and do not necessarily reflect those of GLIN or the Great Lakes Commission.
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *