GPA Midstream's government affairs team submitted two sets of comments regarding new U.S. Environmental Protection Agency's proposed rules related to the Risk Management Program under Section 112(r) of the Clean Air Act.

The first set addresses EPA's information collection request, which would add reporting burdens for more than 14,000 industrial facilities. The total cost of compliance would total more than $79 million per year.

The second filing responds to EPA's proposed rule: Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention.

GPA Midstream communicated opposition to significant portions of the proposed rule, which seeks to implement several new requirements — some previously repudiated in 2019. Broadly speaking, the proposed rule would move the Risk Management Program way from a performance-based standard, which has successfully achieved a steady decline in incidents, to an overly-prescriptive regimen that will overwhelm process hazard analysis systems with additional requirements.

The proposed rule would impose significant new costs and burdens on facilities. EPA's own administrative records show there is no need for these additional regulations.

To read the full text of the comments:

• GPA Midstream comments on EPA's proposed information collection request
• GPA Midstream comments on EPA's proposed Risk Management Program rules

For questions, comments or to get involved, please contact GPA Midstream.